as88 Privacy Policy

This Privacy Policy ("Policy") is published by as88 ("we", "us", "our", "the Platform") and governs the collection, processing, storage, and transfer of personal data belonging to all users ("you", "Player", "User") who access, register on, or otherwise interact with the as88 website and associated gaming services.

This Policy applies to all personal data collected through the as88 website, mobile interface, live chat support, email correspondence, KYC verification procedures, payment processing workflows, and any other touchpoint through which you interact with as88. It covers both registered account holders and unregistered visitors to the Platform.

This Policy should be read alongside the as88 Terms and Conditions and Responsible Gaming Policy. In the event of any conflict between this Policy and our Terms and Conditions on a data-related matter, this Policy shall take precedence.

For the purposes of applicable data protection legislation, as88 acts as the Data Controller in respect of the personal data collected from users of the Platform. As Data Controller, as88 determines the purposes and means of processing your personal data in connection with the operation of the Platform and the provision of gaming services.

If you have any questions, concerns, or requests relating to the processing of your personal data by as88, or if you wish to exercise any of your data subject rights as described in Section 10 of this Policy, please contact the as88 Data Protection team at the email address provided in Section 14 of this document.

as88 collects personal data from you in the following categories, depending on how you interact with the Platform:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification document.
• Date of birth (used to verify that you meet the 21+ age requirement for Platform access).
• Email address (used as your primary account identifier and communication channel).
• Mobile number (used for account security and optional two-factor authentication).
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad).
• Username and encrypted account password.

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents (CNIC, passport, or equivalent).
• Proof of address documentation (utility bill, bank statement, or equivalent).
• Source of funds documentation where required by AML compliance procedures.
• Selfie or liveness verification images where required for enhanced identity verification.

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, dates, and payment method references.
• Payment method identifiers such as JazzCash wallet numbers, EasyPaisa numbers, bank account details (HBL, UBL, Meezan Bank), and masked card numbers for Visa/Mastercard.
• Account balance history and bonus transaction records.

3.4 Gaming Activity Data

• Game session logs including games played, bet amounts, wagering history, and game outcomes.
• Sports betting selections, stake amounts, and settlement records.
• Responsible gaming tool usage including deposit limits, session limits, and self-exclusion records.

3.5 Technical & Device Data

• IP address and approximate geolocation derived therefrom.
• Device type, operating system, and browser type and version.
• Session timestamps, login history, and platform navigation data.
• Cookies and similar tracking technologies as detailed in Section 9 of this Policy.

3.6 Communication Data

• Content of live chat conversations with as88 support agents.
• Email correspondence sent to or from as88 support addresses.
• Player feedback, complaint records, and dispute correspondence.

as88 processes your personal data for the following specific purposes. We only process data where we have a valid legal basis to do so, as set out in Section 5 of this Policy.

as88 processes your personal data on the following legal bases as recognised under applicable data protection legislation:

• Contractual Necessity: Processing required to fulfil our obligations to you under the as88 Terms and Conditions — including operating your account, processing payments, and delivering gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including KYC/AML procedures mandated under our gaming licence and applicable financial regulations.
• Legitimate Interests: Processing carried out to pursue our legitimate business interests, including fraud detection, platform security, responsible gaming monitoring, and internal analytics — where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we rely on your freely given, specific, and informed consent — for example, in connection with optional marketing communications. You may withdraw consent at any time by contacting the as88 support team.

as88 does not sell, rent, or trade your personal information to any third party for their own commercial purposes. We share personal data only in the following limited and controlled circumstances:

6.1 Service Providers & Data Processors

as88 engages carefully selected third-party service providers who process personal data on our behalf and under our instruction. These include KYC and identity verification providers, payment gateway operators (including local Pakistani payment processors), game platform providers, customer support software providers, and fraud detection and cybersecurity partners. All such providers are bound by contractual data processing agreements that require them to maintain appropriate security standards and use personal data only for the purposes specified by as88.

6.2 Regulatory & Legal Disclosures

as88 may be required to disclose personal data to regulators, licensing authorities, law enforcement agencies, courts, or other governmental bodies where required or permitted by applicable law. Such disclosures will always be made in accordance with our legal obligations and documented appropriately.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the as88 business, personal data held by as88 may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

Given the international nature of the as88 gaming platform, your personal data may be transferred to and processed in countries outside of Pakistan. Where such transfers occur, as88 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that provided under applicable data protection law.

Safeguards for international data transfers used by as88 include contractual clauses approved by relevant data protection authorities, transfers to jurisdictions that have been determined to offer an adequate level of data protection, and the use of binding corporate rules or equivalent mechanisms where applicable.

as88 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, as described in this Policy, or for as long as required by applicable legal or regulatory obligations. The following general retention principles apply:

• Active Account Data: Personal data associated with an active as88 player account is retained for the full duration of the account's active status.
• KYC & AML Records: Identity verification and transaction records are retained for a minimum of five (5) years following the closure of an account, in compliance with anti-money laundering regulatory requirements.
• Financial Transaction Records: Deposit, withdrawal, and betting transaction records are retained for a minimum of five (5) years following the date of the transaction.
• Communication Records: Support chat and email correspondence records are retained for a period of up to three (3) years following the date of the communication.
• Marketing Preferences: Records of your marketing consent status and opt-out history are retained for as long as necessary to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with as88's internal data disposal procedures. Anonymised and aggregated data that cannot be used to identify any individual may be retained indefinitely for statistical and analytical purposes.

The as88 platform uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage objects) to deliver and improve platform services, personalise your experience, and support security and fraud prevention functions. By using the as88 platform, you agree to our use of cookies as described in this section.

9.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the operation of the as88 platform, including session management, login authentication, and security token validation. These cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Remember your preferences and settings to provide a personalised experience, such as your preferred language and game display options.
• Analytics Cookies: Collect aggregated data about how players use the as88 platform to help us improve performance, navigation, and game discovery.
• Security & Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including bot detection and IP reputation analysis.

9.2 Managing Cookies

You can manage and withdraw your consent for non-essential cookies at any time through your browser settings or through the cookie preference centre available on the as88 platform. Please note that disabling certain cookies may affect the functionality of some features on the Platform.

Subject to applicable data protection law and certain limited exceptions, you have the following rights in respect of your personal data held by as88:

• Right of Access: You have the right to request a copy of the personal data that as88 holds about you, along with information about how it is used.
• Right to Rectification: You have the right to request that inaccurate or incomplete personal data held by as88 be corrected or completed without undue delay.
• Right to Erasure: In certain circumstances, you have the right to request that as88 delete your personal data. This right is subject to as88's legal obligations to retain certain categories of data (e.g., KYC and AML records).
• Right to Restriction: You have the right to request that as88 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to its processing.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where as88 relies on legitimate interests as the legal basis for processing. You also have an absolute right to object to the use of your data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact the as88 Data Protection team at the contact details provided in Section 14. as88 will respond to verified data subject requests within the timeframe required by applicable law.

as88 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, and destruction. Our security infrastructure includes the following key measures:

• Transport Security: All data transmitted between your device and as88 servers is encrypted using TLS 1.2 or higher (SSL encryption), ensuring that data in transit cannot be intercepted by third parties.
• Data Encryption at Rest: Sensitive personal data stored on as88 servers is encrypted using AES-256 encryption, the same standard used by leading global financial institutions.
• Access Controls: Access to personal data within as88's internal systems is strictly limited to authorised employees whose roles require such access. All internal access is logged and audited.
• Penetration Testing: as88 engages independent security specialists to conduct regular penetration testing and vulnerability assessments of the Platform's infrastructure.
• Incident Response: as88 maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, as88 will notify you and the relevant regulatory authority as required by applicable law.

The as88 platform is strictly intended for adults aged 21 years and older. as88 does not knowingly collect, process, or retain personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close any associated account.

If you are a parent or guardian and believe that your child has registered an account or provided personal data to as88, please contact the support team immediately at the details provided in Section 14. We will investigate the matter and take appropriate action, including account closure and data deletion.

as88 reserves the right to update, amend, or replace this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or the services we offer. When material changes are made to this Policy, as88 will notify registered players via email to the address associated with their account and will display a prominent notice on the Platform.

The updated Policy will display a revised "Effective Date" at the top of this document. Continued use of the as88 platform following notification of any amendments constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes made, you should discontinue use of the Platform and may request account closure.

We recommend that you review this Privacy Policy periodically to stay informed about how as88 collects, uses, and protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by as88, or if you wish to exercise any of your data subject rights as described in Section 10, please contact the as88 Data Protection team:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Data Protection Request" in the subject line of your email to ensure your request is routed to the appropriate team.
• Response Time: as88 will acknowledge your data protection request within 72 hours and provide a substantive response within the timeframe required by applicable data protection law (typically 30 days).

14.1 Complaints to a Supervisory Authority

If you believe that as88 has processed your personal data in a manner that violates applicable data protection law, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. as88 encourages you to contact us directly in the first instance so that we may attempt to resolve your concern before you escalate the matter to a regulatory body.

This Privacy Policy was last reviewed and updated on 1 January 2026. This version supersedes all previous versions of the as88 Privacy Policy.