Privacy Policy — 98tp Platform

This Privacy Policy ("Policy") describes how 98tp ("we", "us", "our"), the operator of the online gaming information platform located at https://98tp.cam (the "Platform"), collects, uses, stores, shares and protects the personal data of individuals who access or use the Platform ("User", "you", "your").

This Policy forms part of the broader legal framework governing use of the 98tp Platform, alongside our Terms & Conditions. By accessing the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein, to the extent that consent is the applicable legal basis for processing.

If you do not agree with any part of this Policy, you should cease using the Platform immediately. For questions or to exercise any data rights, please refer to Section 15 (Contact Us).

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can reasonably be used to identify a natural person — including but not limited to name, email address, IP address, device identifiers, payment reference details and account credentials.
• "Processing" means any operation performed on personal data, including collection, storage, retrieval, consultation, use, disclosure, restriction or deletion.
• "Data Controller" means 98tp, the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party that processes personal data on behalf of 98tp in accordance with our instructions.
• "Cookies" means small text files placed on your device by the Platform to store and retrieve information about your browsing activity and preferences.
• "KYC" means Know Your Customer — the identity and age verification process that may be required to access certain platform features or to comply with applicable regulations.
• "Third-Party Operator" means any licensed gambling platform or service referenced on or accessible through 98tp. 98tp is not itself a licensed gambling operator and is not responsible for Operator data practices.
• "Special Category Data" means sensitive categories of personal data requiring enhanced protection, including health data, financial vulnerability indicators or information about self-exclusion status.

98tp collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Account & Registration Data

• Full legal name as provided during registration.
• Date of birth (for age verification purposes).
• Email address.
• Residential address (city, province, country — relevant for Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar).
• Account username and encrypted password.
• Account preferences and notification settings.

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., CNIC, Passport).
• Proof of address documentation.
• Selfie or biometric verification image (where applicable and required).

3.3 Technical & Usage Data

• IP address and approximate geographic location.
• Browser type, version and operating system.
• Device type (mobile, tablet, desktop) and screen resolution.
• Pages visited, session duration, navigation paths and feature interactions.
• Referral source (e.g., how you arrived at the Platform).
• Error logs and crash reports.

3.4 Communication Data

• Content of support tickets, live chat transcripts and email correspondence submitted to 98tp.
• Survey responses and feedback submissions.
• Any personal data you voluntarily include in communications with us.

3.5 Transaction Reference Data

• Records of deposit and withdrawal activities where 98tp acts as an information intermediary.
• Payment method type references (e.g., mobile wallet, bank transfer) — note that 98tp does not store full payment card numbers, mobile wallet credentials or bank account details.

98tp collects personal data through the following channels:

• Directly from you — when you register an account, complete forms, contact our support team, participate in surveys or provide information voluntarily through Platform features.
• Automatically via technology — when you browse the Platform, cookies, web beacons, pixels and server logs automatically collect technical and usage data. See Section 10 for full cookie details.
• From third-party analytics providers — we may receive aggregated or pseudonymised data from analytics service providers that help us understand Platform performance and user behaviour patterns.
• From KYC verification services — where identity verification is required, data may be cross-referenced with third-party identity verification providers to confirm eligibility and authenticity of submitted documents.
• From fraud prevention services — we may receive risk indicators from fraud detection partners to protect the Platform and its users from fraudulent account activity.

98tp processes personal data only where a valid legal basis exists for doing so. The applicable legal bases are:

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

98tp uses collected personal data for the following purposes:

• To create, manage and authenticate your Platform account.
• To verify your age and identity in accordance with eligibility requirements.
• To deliver the services, content and features of the 98tp Platform.
• To process and respond to support queries, complaints and feedback.
• To send transactional communications — including account notifications, security alerts and policy updates — that are necessary for the operation of your account.
• To send promotional or marketing communications where you have provided explicit opt-in consent. You may withdraw this consent at any time.
• To analyse how users interact with the Platform in order to improve functionality, content quality and user experience.
• To detect, investigate and prevent fraudulent, abusive or illegal activity on the Platform.
• To comply with applicable laws, regulatory requirements or enforceable requests from competent authorities.
• To enforce our Terms & Conditions and protect the rights and interests of 98tp and its users.

98tp does not sell your personal data to third parties. We may share your data in the following limited circumstances:

• Service Providers (Data Processors): We engage carefully selected third-party service providers — including cloud hosting, analytics, KYC verification, fraud detection and customer support tools — who process data on our behalf under contractual data processing agreements. These providers are bound to use your data only as directed by 98tp and may not process it for their own purposes.
• Legal Compliance: We may disclose personal data to competent regulatory authorities, law enforcement agencies or courts where we are legally required or compelled to do so. We will, where permitted, notify affected users of such requests.
• Business Transfers: In the event of a merger, acquisition, sale of assets or corporate restructuring involving 98tp, personal data may be transferred to the acquiring or successor entity. Users will be notified of any such transfer and provided an opportunity to object where applicable law requires.
• Safety & Security: We may share data where necessary to protect the vital interests of Platform users or the general public, or to detect and prevent fraud or abuse.

98tp retains personal data for no longer than is necessary for the purposes for which it was collected, subject to legal and regulatory requirements that may mandate longer retention periods. Our general retention approach is as follows:

• Account data: Retained for the duration of your active Account and for a period of up to five (5) years following account closure, to comply with anti-money laundering, fraud prevention and identity verification obligations.
• KYC documentation: Retained for a minimum period required by applicable legal and regulatory obligations, typically five (5) years from the date of verification.
• Support correspondence: Retained for up to three (3) years from the date of the last interaction, to assist in resolving disputes and improving service quality.
• Technical and analytics data: Aggregated or anonymised data may be retained indefinitely for statistical and research purposes. Personally identifiable technical data is typically retained for up to twenty-four (24) months.
• Marketing preferences: Retained until consent is withdrawn or the account is closed, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

98tp implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and our servers.
• Encryption at rest for stored personal data.
• Role-based access controls limiting which internal personnel can access personal data.
• Regular internal security assessments and vulnerability scanning.
• Two-factor authentication requirements for internal administrative systems.
• Contractual data security obligations imposed on all Data Processors.

Whilst 98tp maintains robust security practices, no online system can be guaranteed to be completely secure. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify affected users in accordance with our obligations under applicable data protection regulations.

98tp uses cookies and similar technologies (including web beacons and local storage) to operate the Platform effectively, analyse usage patterns and personalise your experience. The following categories of cookies are deployed:

Essential cookies are required for the Platform to function and cannot be disabled without significantly impairing your experience. Analytics and functional cookies can be managed through your browser settings or any cookie preference tool available on the Platform.

Most web browsers allow you to control cookies through their settings. Disabling certain cookies may limit some Platform functionality. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

Subject to applicable law and the conditions under which we process your data, you have the following rights in relation to your personal data held by 98tp:

To exercise any of these rights, please contact us using the details provided in Section 15. We will respond to valid requests within thirty (30) days of receipt. In complex cases or where a high volume of requests is received, this period may be extended by a further sixty (60) days, with notification provided.

We may require verification of your identity before processing a data rights request, to protect against unauthorised data disclosure. Identity verification requests are handled securely and your verification data is not retained beyond what is necessary for that purpose.

Where personal data collected from Pakistani users is transferred to, processed in, or stored in a jurisdiction outside Pakistan, 98tp takes steps to ensure that an appropriate level of data protection applies. Such steps may include:

• Transferring data only to countries that provide an adequate level of data protection as assessed by the applicable regulatory framework.
• Using contractual data processing agreements incorporating standard contractual clauses or equivalent protective mechanisms between 98tp and its international Data Processors.
• Applying supplementary technical measures (such as additional encryption) where required to maintain the security of transferred data.

By using the 98tp Platform from Pakistan, you acknowledge that your data may be processed in jurisdictions outside Pakistan as described in this Policy. If you have concerns about international data transfers, please contact us via the details in Section 15.

The 98tp Platform is intended exclusively for adults aged 18 or older — or the higher minimum age required by the applicable operator license jurisdiction. We do not knowingly collect, store or process personal data from individuals who are under the applicable minimum age.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected] (plain text — not a link) so that we can take appropriate action.

98tp reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or Platform features. When material changes are made — meaning changes that significantly affect how your data is collected, used or shared — we will take steps to notify registered users, such as displaying a prominent notice on the Platform or sending an email notification to the address registered with your account.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how we protect your data.

Your continued use of the Platform following the publication of an amended Policy constitutes your acknowledgement of the changes and, where applicable, your consent to the updated data practices described therein.

If you have any questions, concerns or requests regarding this Privacy Policy or the way 98tp handles your personal data — including requests to exercise your data rights as described in Section 11 — please contact us using the following details:

For related legal documents, please also review our Terms & Conditions and our Responsible Gambling page. Our FAQ page may also address common questions about data and account management.