98bat Privacy
Policy

1.1 This Privacy Policy is published by 98bat, the online sports betting and casino platform operated at 98bat.org. References to "98bat," "we," "us," or "our" throughout this Policy refer to the platform operator and its affiliated entities responsible for processing personal data in connection with the 98bat platform.

1.2 98bat is an internationally licensed online gaming platform serving players across Pakistan, including Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Multan, and all other cities and regions. The platform offers cricket betting, live casino, slots, sportsbook, and related gaming products.

1.3 For the purposes of applicable data protection law, 98bat acts as the data controller for personal data collected from users of the 98bat platform. This means we determine the purposes and means of processing your personal data and are responsible for ensuring that processing is carried out in accordance with applicable law and this Privacy Policy.

2.1 98bat collects personal data in several categories depending on the nature of your interaction with the platform. The table below summarises the categories of data collected and the primary purpose for each:

2.2 Sensitive Data. 98bat does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data. CNIC scans are collected exclusively for identity and age verification purposes and are not used for any biometric processing or profiling beyond confirming the authenticity of the document.

3.1 Direct Collection. The majority of personal data held by 98bat is provided directly by you through the following interactions:

• Completing the account registration form on 98bat.org
• Submitting KYC identity verification documents
• Making a deposit using JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, or cash OTC channels
• Submitting a withdrawal request
• Contacting support via live chat or email
• Participating in promotions, surveys, or feedback requests
• Setting responsible gaming preferences in your account dashboard

3.2 Automated Collection. 98bat's platform automatically collects certain technical data when you access or interact with the website, including your IP address, device identifiers, browser type and version, operating system, session timestamps, pages visited, and features interacted with. This data is collected via server logs and first-party analytics tools.

3.3 Third-Party Sources. In limited circumstances, 98bat may receive data about you from third-party sources, including payment providers (transaction status and verification data), identity verification service providers (document authenticity checks), and fraud prevention databases (to check against known fraudulent identities or payment methods). Data received from third parties is handled in accordance with this Privacy Policy.

4.1 98bat processes your personal data only where a valid legal basis exists. The legal bases relied upon for different processing activities are as follows:

• Contract Performance: Processing your identity data, contact data, financial data, and account activity data is necessary to fulfil our contractual obligations to you under the 98bat Terms and Conditions — specifically, to operate your account, process your deposits and withdrawals, make games available, and pay out winnings.
• Legal Obligation: Processing your identity data and financial data for KYC verification, age verification, and anti-money-laundering checks is required by the licensing conditions under which 98bat operates. We are legally required to verify your identity and retain transaction records for defined periods.
• Legitimate Interests: Processing your technical data and account activity data for fraud prevention, platform security, responsible gaming monitoring, and dispute resolution is justified by 98bat's legitimate interests in protecting the platform, its users, and its regulatory standing. These interests have been assessed and determined not to override your fundamental privacy rights.
• Consent: Processing your contact data for marketing communications — including promotional SMS and email — is based on your explicit consent given during registration. Consent is freely given, specific, informed, and revocable at any time without detriment to your account.

5.1 98bat uses your personal data for the following specific purposes:

• Account Management: Creating and maintaining your registered 98bat account, verifying your identity and age, managing your PKR Wallet, and providing access to all platform features.
• Payment Processing: Authenticating and processing deposit and withdrawal transactions via your registered payment method (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, or cash OTC).
• KYC and Compliance: Meeting identity verification, age verification, and anti-money-laundering obligations required by 98bat's gaming licence and applicable regulatory standards.
• Fraud Prevention and Platform Security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, bonus abuse, and other integrity violations using automated and manual review processes.
• Responsible Gaming: Monitoring account activity to identify patterns consistent with problem gambling behaviour and enabling responsible gaming tools including deposit limits, session timers, and self-exclusion at your request or proactively where warranted.
• Customer Support: Providing assistance via live chat and email, maintaining records of your support interactions for quality assurance and continuity of service, and resolving disputes using your account history.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates via SMS and email where you have provided consent. These communications can be opted out of at any time.
• Platform Improvement: Analysing anonymised and aggregated usage data to improve platform performance, identify popular features, and develop new betting markets and game offerings relevant to Pakistani players.

5.2 98bat does not use personal data for automated decision-making that produces legal or similarly significant effects on you without human review, except where such processing is required by regulatory compliance obligations and appropriate safeguards are in place.

6.1 No Sale of Data. 98bat does not sell, rent, or otherwise trade your personal data to any third party for commercial gain. This is an absolute position — it is not conditional on circumstance or jurisdiction.

6.2 Service Providers. 98bat shares personal data with carefully selected third-party service providers who process data on our behalf under written data processing agreements that require them to protect your data in accordance with applicable privacy standards. These service providers include:

• Payment processing providers (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other financial institutions) — to process your deposit and withdrawal transactions
• Identity verification and KYC service providers — to authenticate your CNIC and verify your age and identity
• Cloud infrastructure and hosting providers — to store platform data securely
• Fraud prevention and anti-money-laundering screening services — to cross-check transactions against known fraud databases
• Gaming software studios — limited technical data for game session management purposes only, strictly governed by provider agreements

6.3 Regulatory and Legal Disclosure. 98bat may disclose your personal data to regulatory authorities, gaming licence holders, law enforcement agencies, or courts where required by law, court order, or binding regulatory instruction. Such disclosures are made only to the extent strictly required and are logged for accountability purposes.

6.4 Business Transfers. In the event of a merger, acquisition, or sale of all or part of 98bat's business, personal data may be transferred to the acquiring entity as part of the transaction. In such cases, 98bat will provide reasonable notice and ensure that the acquiring entity commits to protecting your data under terms no less protective than this Privacy Policy.

7.1 98bat uses cookies and similar technologies on the 98bat.org website to support platform functionality, maintain your session state, and analyse usage patterns. Cookies are small data files stored on your device that allow the platform to recognise you between page loads and sessions.

7.2 Types of Cookies Used:

• Essential Cookies: Required for the platform to function correctly — including maintaining your login session, remembering your language and currency preferences, and enabling secure transactions. These cannot be disabled without impairing platform functionality.
• Analytics Cookies: Used to understand how visitors interact with the platform — which pages are visited most, how long sessions last, and where users navigate from. Analytics data is processed in anonymised and aggregated form and is not linked to your personal identity.
• Functional Cookies: Used to remember your preferences — such as game layout preferences, notification settings, and responsible gaming configurations set in your account dashboard.
• Security Cookies: Used to support fraud detection and account security functions, including tracking unusual login patterns and flagging suspicious session behaviour.

7.3 98bat does not use third-party advertising cookies or allow external advertising networks to place tracking cookies on 98bat.org. The platform does not serve targeted advertising to users based on browsing history or third-party profiling data.

7.4 Most browsers allow you to control cookie settings through browser preferences. Disabling essential cookies will affect platform functionality including your ability to log in and complete transactions. 98bat's cookie configuration can be reviewed via the cookie preferences panel accessible from the platform footer.

8.1 98bat implements a layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Security measures in place include:

• 256-bit SSL/TLS encryption on all data in transit between your device and 98bat servers
• AES-256 encryption for personal data and KYC documents stored in databases
• Role-based access controls ensuring staff access only the data necessary for their specific function
• Multi-factor authentication for all administrative and operations staff accessing production systems
• Intrusion detection systems and real-time security monitoring
• Regular third-party security audits and penetration testing
• Incident response procedures with defined response times for potential data breaches

8.2 Data Breach Notification. In the event of a personal data breach that poses a risk to your rights and freedoms, 98bat will notify affected users within 72 hours of becoming aware of the breach where technically feasible, and will take all reasonable steps to contain the breach, assess the impact, and prevent recurrence.

8.3 While 98bat takes extensive security measures, no internet-connected system can be guaranteed to be completely secure. You are responsible for keeping your own login credentials confidential and for ensuring the devices you use to access 98bat are not compromised. If you suspect your account has been accessed without your permission, contact support immediately.

9.1 98bat retains personal data for no longer than is necessary for the purposes for which it was collected, subject to legal and regulatory requirements. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active account, plus a minimum of five years following account closure to meet gaming licence and anti-money-laundering record-keeping obligations.
• KYC Documents: Retained for the period specified by the applicable gaming licence jurisdiction's regulatory requirements, typically five years from the date of submission or account closure, whichever is later.
• Financial Transaction Records: Retained for a minimum of seven years following the transaction date to meet financial record-keeping and anti-money-laundering compliance obligations.
• Betting and Game History: Retained for the duration of your active account plus five years following account closure to support dispute resolution and compliance audits.
• Support Communications: Retained for three years from the date of the communication to support quality assurance and continuity of support service.
• Marketing Consent Records: Retained for the duration of your account. If you opt out of marketing, your opt-out preference is retained permanently to ensure no future marketing is sent to you.
• Technical and Session Data: Retained for a maximum of 24 months unless retention is required for active fraud investigations or regulatory reporting obligations.

9.2 At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised such that you can no longer be identified from it. Deletion is conducted using industry-standard secure deletion protocols that ensure data cannot be recovered.

10.1 You have the following rights in relation to the personal data 98bat holds about you:

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed. Standard data access requests are fulfilled within 30 days and free of charge for the first request in any 12-month period.
• Right to Rectification: You have the right to request correction of any personal data that is inaccurate or incomplete. You can update your contact details and communication preferences directly in your account settings. For other corrections, contact support with the corrected information.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances, including where the data is no longer necessary for the purposes it was collected, where you withdraw consent, or where the processing is unlawful. Note that this right is subject to legal and regulatory record-keeping obligations — we cannot delete data we are legally required to retain.
• Right to Restriction: You have the right to request that we restrict processing of your personal data in certain circumstances, such as while a dispute about data accuracy or lawfulness is being resolved. During the restriction period, the data can be stored but not actively processed except with your consent or for legal claims.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format (such as CSV or JSON) and to transmit that data to another service provider where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where the legal basis is legitimate interests. If you object, 98bat must stop processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for legal claims.
• Right to Withdraw Consent: Where processing is based on your consent (specifically, marketing communications), you have the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal. Opt-out controls are available in your account settings and at the bottom of every marketing email.

10.2 Exercising Your Rights. To exercise any of these rights, contact 98bat support at [email protected] with the subject line "Data Privacy Request" and specify which right you wish to exercise. You will be asked to verify your identity by providing your registered mobile number and account details to ensure your data is released only to you.

10.3 98bat will respond to data rights requests within 30 days of receipt. In complex cases, this period may be extended by an additional 60 days with notification to you explaining the reason for the delay.

11.1 98bat's services are not intended for, and may not be used by, individuals under the age of 21. We do not knowingly collect personal data from anyone under 21 years of age. Age verification is mandatory before any withdrawal is processed, and accounts found to belong to persons under 21 are closed immediately.

11.2 If 98bat becomes aware that personal data has been collected from a person under the age of 21, that data will be deleted without undue delay, the account will be permanently closed, and any deposited funds will be returned to the source payment method where no fraud is involved.

11.3 Parents and guardians are encouraged to monitor the online activities of minors in their care and to use parental control software to prevent access to online gambling websites.

12.1 The 98bat platform may contain links to third-party websites, including payment provider sites (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) and gaming studio sites. 98bat is not responsible for the privacy practices or content of these external sites. When you leave 98bat.org, you are subject to the privacy policies of those third-party services.

12.2 Games on the 98bat platform are provided by certified third-party gaming studios. While game sessions are technically hosted by these providers, 98bat's data processing agreements with studios strictly limit the data they can collect to technical session data required for game operation. Studios are prohibited from using your data for marketing or profiling purposes.

13.1 Your personal data may be transferred to, stored in, and processed in jurisdictions outside Pakistan where 98bat's service providers and infrastructure are located. Where data is transferred internationally, 98bat ensures that appropriate safeguards are in place to protect your data in accordance with applicable privacy standards.

13.2 Such safeguards include ensuring that the receiving jurisdiction is recognised as providing an adequate level of data protection, or that the recipient is bound by standard contractual clauses approved by recognised data protection authorities, or that the recipient is certified under a recognised privacy framework.

14.1 98bat reserves the right to update this Privacy Policy from time to time to reflect changes in our processing activities, legal obligations, or best practices. Material changes will be notified to you via email to your registered address and via prominent notice on the 98bat platform at least 14 days before the changes take effect.

14.2 The effective date of the current version of this Privacy Policy is displayed at the top of this page. Continued use of the 98bat platform following notification of a change constitutes acceptance of the updated Policy. If you do not accept the changes, you may request account closure and data deletion subject to our legal retention obligations.

15.1 Privacy Queries. For any questions, concerns, or clarifications regarding this Privacy Policy, or to exercise any of your data rights, contact 98bat support:

• Email: [email protected] with subject line "Privacy Inquiry"
• Live Chat: Available 24/7 via the in-platform support widget — select "Privacy & Data" from the topic menu for priority routing to privacy-trained support staff

15.2 Complaints. If you are not satisfied with how 98bat has handled your personal data or responded to a data rights request, you have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction. 98bat is committed to resolving privacy concerns directly and encourages you to contact us first so we have the opportunity to address your concern before escalation.