Privacy Policy — 998com

This Privacy Policy ("Policy") is published by 998com, accessible at https://998com.cam ("Platform", "we", "us", "our"). It explains how we collect, use, store, share and protect personal data in connection with your use of the Platform, and describes the rights available to you with respect to your personal information.

998com is an English-language online betting information platform serving users in Pakistan and other applicable jurisdictions. We take data privacy seriously and are committed to ensuring that personal information entrusted to us is handled responsibly and in accordance with applicable data protection principles.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling policy. By accessing or using the Platform, you acknowledge that you have read and understood this Policy.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including but not limited to name, email address, IP address, location data and online identifiers.
• "Processing" means any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission or deletion.
• "Data Controller" means 998com, which 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 998com in accordance with its instructions.
• "User" / "you" means any individual who accesses or uses the Platform.
• "Cookies" means small text files placed on your device when you visit the Platform, used to recognise your device and remember preferences.
• "KYC" means Know Your Customer — the identity verification procedures required to confirm the identity of users for compliance, anti-money laundering (AML) and age-verification purposes.
• "PKR" means Pakistani Rupee, the national currency of Pakistan.

We collect personal data in the following ways and categories:

3.1 Data You Provide Directly

• Registration Data: When you create an account, we collect your full name, email address, date of birth and, where required, a username and password.
• KYC / Identity Verification Documents: To comply with anti-money laundering (AML) regulations and to verify your age, you may be required to submit a copy of a valid national identity card, passport, or proof of residential address (for example, a utility bill or bank statement). These documents are processed solely for verification purposes.
• Financial Information: Where payment transactions are processed through the Platform or a linked Operator, transaction records including deposit amounts, withdrawal requests and payment method references may be collected. For Pakistani users, this may include references to familiar payment methods such as bank transfers via HBL, UBL, Meezan Bank or Bank Alfalah, and mobile wallet references such as Easypaisa, JazzCash and Raast. These are referenced for contextual transaction identification only — 998com does not store full payment card details or mobile wallet credentials.
• Support Communications: If you contact our support team, we retain records of your communications to enable resolution of your query and to improve our services.

3.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, time zone setting and language preferences.
• Usage Data: Pages visited, features accessed, time spent on pages, session duration, referring URLs and navigation paths within the Platform.
• Cookie Data: Data collected through cookies and similar tracking technologies, as described in Section 7 of this Policy.
• Approximate Location Data: Derived from your IP address for the purpose of jurisdictional compliance checks. We do not collect precise GPS-level location data unless explicitly required and consented to.

3.3 Data Received from Third Parties

We may receive personal data from third-party partners, including payment processors, identity verification service providers and fraud prevention services. Data received from third parties is used solely for the purposes described in this Policy and is handled with the same standard of care as data collected directly.

We process personal data only where we have a valid legal basis to do so. The legal bases on which we rely include:

• Performance of a Contract: Processing is necessary to fulfil our contractual obligations to you — for example, managing your account, processing transactions and delivering the services you have requested.
• Compliance with Legal Obligations: Processing is required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, age verification obligations and financial reporting duties.
• Legitimate Interests: Processing is necessary for the legitimate interests of 998com, such as fraud prevention, security monitoring, platform improvement and responsible gambling management — provided those interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent as a legal basis (for example, for certain marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.

We use the personal data we collect for the following purposes:

• Account Management: To create, maintain and secure your account, including authentication and access control.
• KYC & Identity Verification: To verify your identity and age in compliance with applicable regulations, and to prevent underage access to gambling services.
• Transaction Processing: To process deposits, withdrawals and related financial transactions in PKR or other applicable currencies.
• Fraud Prevention & Security: To detect, investigate and prevent fraudulent activity, money laundering, identity theft and other security threats.
• Responsible Gambling: To monitor account activity for signs of problem gambling and to apply responsible gambling tools, limits and interventions where appropriate.
• Customer Support: To respond to your enquiries and resolve issues reported through our support channels.
• Platform Improvement: To analyse usage patterns and improve the functionality, content and user experience of the Platform.
• Legal & Regulatory Compliance: To fulfil obligations imposed by applicable law, regulatory requirements and court orders.
• Marketing Communications (with consent): Where you have opted in to receive marketing communications, to send relevant promotional information. You may opt out at any time.

998com does not sell your personal data to third parties. We may share personal data in the following limited circumstances:

• Service Providers: We engage trusted third-party service providers to support our operations — including payment processors, KYC verification providers, cloud hosting providers, analytics services and customer support tools. These parties act as Data Processors under contractual obligations that restrict their use of your data to the purposes we specify.
• Operator Partners: Where the Platform is connected to or facilitates access to a licensed Operator's gambling services, certain account and transaction data may be shared with that Operator to enable service delivery, account management and responsible gambling monitoring.
• Regulatory & Law Enforcement Authorities: We may disclose personal data to government authorities, regulators or law enforcement agencies where required by applicable law, court order or where we believe disclosure is necessary to protect the legal rights, property or safety of 998com, its users or the public.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of our business, personal data may be transferred to the relevant successor entity, subject to the same privacy protections described in this Policy.
• With Your Consent: We may share your data for any other purpose with your explicit prior consent.

The Platform uses cookies and similar tracking technologies to enhance your experience and to support Platform operations. The categories of cookies we use are as follows:

7.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function correctly. They enable core features such as session management, authentication and security functions. Strictly necessary cookies cannot be disabled.

7.2 Performance & Analytics Cookies

These cookies collect anonymised information about how users interact with the Platform — such as which pages are visited most frequently and how users navigate between sections. This data helps us improve the Platform's performance and usability. Analytics cookies are only set where you have given your consent.

7.3 Functionality Cookies

Functionality cookies remember your preferences — such as language settings and display options — to personalise your experience across sessions. These are optional and may be disabled through your browser settings.

7.4 Managing Cookies

Most browsers allow you to control cookie settings through their privacy or settings menus. You can block or delete cookies at any time, though doing so may affect Platform functionality. By continuing to use the Platform without adjusting your cookie settings, you consent to our use of non-essential cookies as described above.

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Account Data: Retained for the duration of your active account and for a period thereafter as required to satisfy legal, compliance and dispute resolution obligations.
• KYC Documents: Retained in accordance with AML regulatory requirements, which typically mandate a minimum retention period of five (5) years following account closure or the completion of a transaction.
• Transaction Records: Financial transaction data is retained for the period required under applicable financial services and AML regulations.
• Support Communications: Retained for as long as necessary to resolve the relevant issue and for a reasonable period thereafter for quality assurance and audit purposes.
• Marketing Preferences: Retained until you withdraw consent or opt out of communications.

When data is no longer required, it is deleted or anonymised in a secure manner. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes, as it no longer constitutes personal data.

998com takes the security of your personal data seriously and implements appropriate technical and organisational measures to protect it against unauthorised access, loss, alteration or disclosure. Our security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser and the Platform is encrypted using industry-standard HTTPS/TLS protocols.
• Access Controls: Access to personal data is restricted to authorised personnel who require it to perform their job functions. Role-based access controls and multi-factor authentication are applied to internal systems.
• Secure Storage: Personal data is stored on secure servers with physical and logical access controls. Payment card details and full mobile wallet credentials are not stored by 998com.
• Regular Security Reviews: We conduct periodic security assessments and vulnerability testing to identify and remediate potential risks.
• Incident Response: We maintain a data breach response plan. In the event of a security incident that poses a risk to your rights, we will notify affected users and relevant authorities in a timely manner in accordance with applicable data protection law.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You also have a responsibility to keep your account credentials confidential and to report any suspected unauthorised access immediately.

As an internationally accessible platform, 998com may process or store personal data in jurisdictions outside Pakistan. When personal data is transferred internationally, we ensure that appropriate safeguards are in place to protect your data to a standard at least equivalent to that provided by this Policy, including:

• Transfer to jurisdictions recognised as providing an adequate level of data protection;
• Use of contractual clauses or other approved transfer mechanisms that impose equivalent data protection standards on recipient parties;
• Obtaining your consent where required by applicable law.

If you have questions about international transfers of your personal data, you may contact us using the details in Section 15.

Subject to applicable law, you have the following rights with respect to your personal data. We will respond to valid requests within a reasonable timeframe, typically within 30 days of receipt:

To exercise any of the above rights, please contact us using the details in Section 15. We may request that you verify your identity before processing your request to ensure we are responding to the correct individual. There is no fee for making a rights request in normal circumstances.

The Platform is strictly intended for adults aged 18 or older, or the higher minimum age required by the applicable operator's license jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age.

If we become aware that personal data has been collected from a minor without appropriate consent or in contravention of age eligibility requirements, we will take immediate steps to delete that data and to close the relevant account. Parents or guardians who believe that their child may have provided personal data to 998com are encouraged to contact us immediately using the details in Section 15.

Age verification is carried out as part of the KYC process. Users who cannot demonstrate that they meet the minimum age requirement will not be permitted to access age-restricted features of the Platform.

The Platform may contain references to or contextual information about third-party services, including licensed Operators, payment providers and sports organisations. 998com is not responsible for the privacy practices or data handling of any third-party organisations.

If you follow a link to a third-party platform or service — including but not limited to a licensed gambling Operator — you will be subject to that third party's own privacy policy and terms of service. We encourage you to review those policies carefully before providing any personal data to a third party.

The mention of payment methods familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — does not constitute a relationship, partnership or data-sharing arrangement between 998com and those organisations unless explicitly verified and disclosed.

998com reserves the right to update or modify this Privacy Policy at any time. Where changes are material, we will endeavour to notify you by publishing the updated Policy on the Platform with a revised "Last Updated" date and, where appropriate, by notifying registered users directly.

Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to remain informed about how we handle your personal data.

If you do not agree with any changes to this Policy, you should discontinue your use of the Platform and, if applicable, request deletion of your account and associated personal data by contacting us as described in Section 15.

If you have any questions, concerns or requests relating to this Privacy Policy, or if you wish to exercise your data rights, please contact our Data Privacy team using the details below:

For responsible gambling enquiries and self-exclusion requests, please visit our Responsible Gambling page. For general platform terms, please refer to our Terms & Conditions.