88wine Privacy Policy

88wine ("we", "us", "our", "the Company") is committed to protecting the privacy and personal data of every player who uses the 88wine platform, accessible at https://88wine.bet and any associated mobile interface. This Privacy Policy ("Policy") sets out in clear and transparent terms how we collect, use, store, share, and protect your personal data when you interact with 88wine.

This Policy applies to all users of the 88wine platform, including visitors who browse without registering and registered players who hold an active account. By accessing the 88wine platform or registering an account, you acknowledge that you have read and understood this Privacy Policy in its entirety and consent to the processing of your personal data as described herein.

This Policy should be read together with the Terms & Conditions and the Responsible Gaming Policy, both of which are published on the 88wine platform. Where any term in this Policy is in conflict with the Terms & Conditions, the Terms & Conditions shall prevail in matters of account use, and this Policy shall prevail in all matters relating to personal data processing.

For the purposes of this Privacy Policy, the data controller responsible for your personal information is the operating entity behind the 88wine platform, which holds an International Gaming License authorising the operation of online casino and sports betting services. The controller determines the purposes and means of processing your personal data in connection with the 88wine platform.

All data protection enquiries, subject access requests, and complaints should be directed to our Data Protection contact via the details set out in Section 15 of this Policy. We will acknowledge all data-related correspondence within five (5) business days and provide a substantive response within thirty (30) days of receipt.

88wine collects only the personal data that is necessary for the specific purposes outlined in this Policy. We do not collect data speculatively. The categories of personal data we may collect include:

88wine collects personal data through the following channels:

• Direct submission: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or participate in a promotion, you provide data to us directly.
• Automated collection: When you visit the 88wine platform, our servers automatically log technical data including your IP address, device identifiers, browser fingerprint, and session activity. This data is collected via server logs, cookies, and similar tracking technologies described in Section 10.
• Third-party payment processors: When you deposit or withdraw using JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or USDT TRC20, our payment processing partners share transaction confirmation data with us to credit or debit your PKR wallet accordingly.
• Identity verification providers: We use third-party KYC providers to cross-reference CNIC data and perform facial liveness checks. These providers return a verification result to 88wine; raw biometric data is not stored on 88wine servers beyond the period required for verification.
• Fraud and security partners: We receive risk signals from licensed fraud detection providers to protect against account takeover, bonus abuse, and financial crime. These signals do not contain personally identifiable information in isolation.

88wine uses your personal data strictly for the following purposes:

• Account management: Creating, maintaining, and securing your 88wine player account, including password resets and OTP authentication.
• Identity and age verification: Confirming that you are who you say you are and that you meet the minimum age requirement of 21 years before allowing access to real-money gaming services.
• Payment processing: Crediting deposits to your PKR wallet and processing verified withdrawal requests to your nominated payment method.
• Regulatory compliance: Meeting our obligations under Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) standards, and the requirements of our International Gaming License, including filing Suspicious Activity Reports where legally required.
• Customer support: Responding to your enquiries, resolving disputes, and improving the quality of our support service based on interaction history.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour and proactively offering support tools or intervention where appropriate.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates — but only to players who have explicitly opted in to receive such communications. You may opt out at any time.
• Platform security and fraud prevention: Detecting, investigating, and preventing fraudulent transactions, account takeovers, collusion, and other prohibited conduct described in the Terms & Conditions.
• Analytics and improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and the overall player experience.

88wine processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to enter into and perform the contract between you and 88wine — including account registration, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML/KYC obligations and our gaming licence conditions.
• Legitimate interests: Processing carried out for 88wine's legitimate interests where these are not overridden by your fundamental rights — including fraud prevention, platform security, and responsible gaming monitoring.
• Consent: Processing based on your freely given, specific, and informed consent — principally in relation to direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

88wine does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your data only in the following limited circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and our USDT processing partner receive the minimum data necessary to execute your financial transactions.
• KYC and identity verification providers: Licensed third-party providers receive your identity documents and biometric data solely to perform age and identity verification on our behalf.
• Game suppliers: Third-party game providers powering casino games on the 88wine platform receive anonymised session identifiers to deliver game content and certify RNG integrity. They do not receive your name, CNIC, or financial details.
• Fraud detection and cybersecurity providers: Technical risk signals are shared with specialist providers to protect your account and the platform from abuse.
• Legal and regulatory authorities: We will disclose personal data to law enforcement, regulatory bodies, or courts where we are legally compelled to do so, or where we believe disclosure is necessary to protect the rights, property, or safety of 88wine, our players, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of our assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party processors are bound by data processing agreements requiring them to process your data only for the specified purpose and to maintain appropriate security measures consistent with international data protection standards.

88wine retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming licence obligations. The following retention guidelines apply:

• Active account data: Retained for the full duration of your account relationship with 88wine plus a minimum period of five (5) years following account closure, as required under AML and gaming licence regulations.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later, in compliance with financial crime prevention regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support and communication records: Retained for three (3) years from the date of the interaction to support dispute resolution and quality assurance.
• Marketing preference data: Retained until you withdraw consent or for two (2) years of inactivity, after which preferences are reset.
• Technical and usage logs: Retained for thirteen (13) months on a rolling basis for security and analytics purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

88wine implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• 256-bit TLS encryption for all data in transit between your device and 88wine servers
• AES-256 encryption for sensitive data at rest, including financial records and identity documents
• Multi-factor authentication (OTP via registered Pakistani mobile number) for account login and sensitive account changes
• Role-based access controls ensuring that 88wine staff can only access player data on a strict need-to-know basis
• Regular independent penetration testing and security audits of platform infrastructure
• Automated intrusion detection and real-time alerting systems
• Segregated storage of player funds in accounts held separately from operational funds

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, 88wine will notify affected players without undue delay and take all reasonable steps to mitigate the impact of the breach.

The 88wine platform uses cookies and similar tracking technologies to ensure the platform functions correctly, to keep you securely logged in, and to improve your experience. The types of cookies we use are as follows:

• Strictly necessary cookies: Essential for the platform to function. These enable session management, security token validation, and load balancing. They cannot be disabled without rendering the platform non-functional.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and display options to personalise your experience on return visits.
• Analytics cookies: Collect anonymised, aggregated data about how players use the platform — which pages are visited most, how long sessions last, and where players encounter difficulties. This data is used solely to improve platform performance.
• Security cookies: Help detect and prevent fraudulent activity, bot traffic, and account takeover attempts by identifying anomalous session behaviour.

88wine does not use third-party advertising or behavioural profiling cookies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to use the platform.

Subject to applicable law and our legitimate operational and regulatory obligations, you hold the following rights in respect of your personal data held by 88wine. To exercise any of these rights, contact our support team via live chat or email as described in Section 15.

The 88wine platform is strictly intended for use by persons aged 21 years and above. We do not knowingly collect, store, or process any personal data belonging to individuals under the age of 21.

During registration, all users are required to confirm their date of birth and submit a valid CNIC for age verification. Any account found to belong to a person under the age of 21 will be immediately and permanently closed. All data associated with such an account will be securely deleted except where retention is required by law for fraud prevention or AML reporting purposes.

If you believe that a minor has successfully registered an account on the 88wine platform, please notify us immediately at [email protected] so that we may take prompt action.

As an internationally licensed platform, 88wine may transfer your personal data to third-party service providers located outside Pakistan. Such transfers may be necessary for the provision of KYC verification services, payment processing, fraud detection, and game delivery.

Whenever we transfer personal data internationally, we ensure that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to process your data in a manner consistent with international data protection standards. We do not transfer data to jurisdictions that lack adequate legal frameworks for data protection without implementing compensating controls.

88wine reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services we offer. When material changes are made, we will notify registered players by email to their registered address and display a prominent notice on the 88wine platform no fewer than seven (7) calendar days before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy will always reflect the most recent revision. We encourage you to review this Policy periodically. Your continued use of the 88wine platform after an amended Policy takes effect constitutes your acceptance of the revised terms.

If you wish to exercise any of your data rights, submit a subject access request, raise a concern about how your personal data is being processed, or make a formal complaint, please contact us through the following channels:

• Live Chat: Available 24/7 — average response time 3–5 minutes. This is the fastest way to reach our Data Protection team for urgent requests.
• Email: [email protected] — please include "Privacy Request" or "Data Complaint" in the subject line so your message is routed correctly. We aim to respond within 30 days.

When submitting a data rights request, please provide your registered email address and sufficient information to allow us to identify your account and verify your identity. We will not action data requests from unverified individuals, as doing so could itself constitute a breach of another person's privacy.

If you are unsatisfied with our response to a privacy complaint, you have the right to escalate your complaint to the supervisory authority or regulatory body in the jurisdiction applicable to your circumstances.