Privacy Policy

ef98 ("ef98", "we", "us", "our") operates the website ef98.cam (the "Platform"), an English-language online gaming information and entertainment service targeting users in Pakistan. We take the privacy of our users seriously and are committed to protecting any personal data you provide when using the Platform.

This Privacy Policy ("Policy") sets out in full detail what personal data we collect, why we collect it, how we process and store it, how long we retain it, with whom we may share it, and what rights you hold in relation to your data. Please read this Policy carefully before using the Platform.

By accessing or using ef98.cam, you acknowledge that you have read and understood this Policy. Use of the Platform constitutes your consent to the data practices described herein to the extent required by applicable law. If you do not agree to this Policy, you must not use the Platform.

In this Policy, unless the context requires otherwise, the following terms carry the meanings set out below:

ef98, operating through the domain ef98.cam, acts as the Data Controller in respect of Personal Data collected through the Platform. As Data Controller, ef98 determines the purposes for which and the means by which Personal Data is processed.

ef98 is an informational platform targeting the Pakistan market. All content is produced in English. The Platform does not hold a Pakistani gambling license, does not process financial transactions and does not operate as a gambling or betting service in any jurisdiction.

For all data protection enquiries, requests or complaints, please contact us using the details provided in Section 16 (Contact Us) of this Policy.

ef98 collects only the minimum data necessary for the operation and improvement of the Platform. The categories of Personal Data we may collect are set out in the table below:

ef98 does not intentionally collect special categories of sensitive Personal Data (such as health data, racial or ethnic origin, religious beliefs or biometric data). If you voluntarily include such information in a message to us, we will handle it with heightened care and delete it once the relevant enquiry is resolved.

We collect Personal Data through the following methods:

• Automatic Collection: When you visit ef98.cam, our web servers and analytics infrastructure automatically record Technical Data and Usage Data as part of normal platform operation. This happens regardless of whether you actively interact with any content.
• Cookies and Tracking Technologies: The Platform uses cookies and similar technologies to enable core functionality, remember settings and collect anonymised usage statistics. See Section 10 for full details.
• Direct Submission: When you voluntarily contact ef98 via the support email ([email protected]) or any contact form on the Platform, you provide Communication Data directly. We collect only what you choose to share.
• Third-Party Analytics: We may use privacy-respecting analytics services that process anonymised or pseudonymised usage data. These services are engaged as Data Processors under appropriate contractual arrangements.

We do not purchase, rent or receive Personal Data about you from third-party data brokers, social media platforms or marketing databases.

ef98 processes Personal Data for the following specific purposes:

ef98 does not process Personal Data for the purpose of serving targeted behavioural advertising, building individual marketing profiles or selling data to third parties for any commercial purpose.

Where applicable data protection law requires a legal basis for processing Personal Data, ef98 relies on the following:

• Legitimate Interests: Processing of Technical Data and Usage Data for Platform operation, security and improvement is carried out on the basis of ef98's legitimate interests in maintaining a functional, secure and high-quality informational platform. We have assessed that these interests are not overridden by your fundamental privacy rights.
• Consent: Where cookies that are not strictly necessary for Platform functionality are placed on your device, we rely on your consent. You may withdraw consent at any time by adjusting your browser settings to refuse cookies.
• Contract Performance: Where you contact ef98 with a support request, processing of your Communication Data is necessary to respond to your enquiry and fulfil our obligation to engage with users.
• Legal Obligation: Where processing is required to comply with a legal requirement or respond to a lawful order from a competent authority, we process data on this basis.

ef98 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by Applicable Law. The following general retention principles apply:

• Technical and Usage Data: Retained in aggregated or anonymised form for up to 24 months for analytics purposes. Individual-level technical data logs are typically purged within 90 days.
• Communication Data: Retained for as long as necessary to resolve the relevant support enquiry and for a reasonable period thereafter in case of follow-up queries — typically no longer than 12 months from the date of resolution.
• Cookie Data: Session cookies expire at the end of your browser session. Persistent analytics cookies expire in accordance with the applicable cookie policy of the analytics provider, typically between 30 days and 13 months.
• Legal Hold: Where data must be retained to comply with a legal obligation, regulatory requirement or pending legal proceeding, retention periods may be extended accordingly.

Once the applicable retention period expires, Personal Data is securely deleted or anonymised so that it can no longer be linked to an individual.

ef98 does not sell, rent, trade or otherwise transfer your Personal Data to third parties for their own commercial use. We may share Personal Data in the following limited circumstances:

• Service Providers (Data Processors): We engage trusted third-party service providers — such as hosting providers, analytics platforms and content delivery networks — to support Platform operations. These providers act as Data Processors under contractual arrangements requiring them to process data only on ef98's instructions and to implement appropriate security measures.
• Legal and Regulatory Requirements: We may disclose Personal Data where required to do so by law, court order, regulatory authority or other legal process. We will, where permitted by law, notify you of such a request.
• Protection of Rights: We may disclose data where necessary to protect the rights, property or safety of ef98, its users or others, including for fraud prevention and security purposes.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of ef98's assets, Personal Data may be transferred to the relevant successor entity. We will provide notice of any such transfer where required by Applicable Law.

ef98 uses cookies and similar technologies on the Platform. Cookies are small text files stored on your device when you visit a website. They enable the Platform to function correctly, remember your preferences and collect anonymised usage data.

You can manage cookie preferences through your browser settings. Most modern browsers allow you to block, delete or restrict cookies. Note that disabling strictly necessary cookies may affect Platform functionality. For detailed guidance on browser cookie settings, refer to your browser's support documentation.

ef98 does not use advertising or targeting cookies, and does not share cookie data with advertising networks.

ef98 implements appropriate technical and organisational security measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. These measures include:

• Transmission of data over HTTPS (TLS encryption) between your device and our servers;
• Access controls limiting Personal Data access to authorised personnel who require it for their specific operational functions;
• Regular security reviews of platform infrastructure and third-party service providers;
• Data minimisation practices — we collect only what is necessary and retain it only as long as required;
• Pseudonymisation and aggregation of analytics data where technically feasible.

While ef98 takes data security seriously, no system connected to the internet can be guaranteed to be completely secure. We cannot warrant the absolute security of data transmitted to or from the Platform. In the event of a Personal Data breach that poses a risk to your rights, we will take steps required by Applicable Law, which may include notifying affected users.

Subject to Applicable Law and the specific circumstances of your request, you may have the following rights with respect to your Personal Data held by ef98:

• Right of Access: You have the right to request confirmation of whether ef98 holds Personal Data about you and, if so, to receive a copy of that data along with information about how it is processed.
• Right to Rectification: If Personal Data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of Personal Data we hold about you where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where processing is otherwise unlawful.
• Right to Restriction of Processing: In certain circumstances, you may request that we restrict processing of your Personal Data — for example, while the accuracy of data is contested or while an objection to processing is under consideration.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format.
• Right to Object: You may object to processing of your Personal Data where that processing is based on ef98's legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, or where processing is necessary for the establishment, exercise or defence of legal claims.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, please contact us at [email protected] with a clear description of your request. We will respond within a reasonable timeframe as required by Applicable Law — typically within 30 days. We may need to verify your identity before processing certain requests.

If you are dissatisfied with our handling of your data or our response to a rights request, you may have the right to lodge a complaint with a competent supervisory authority under Applicable Law.

The Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator or license jurisdiction. ef98 does not knowingly collect, process or retain Personal Data from individuals under the age of 18.

If we become aware that Personal Data has been submitted by or about a person under 18, we will take prompt steps to delete that data from our systems. If you are a parent or guardian and believe your child has provided Personal Data to ef98, please contact us immediately at [email protected].

The Platform may contain references to or descriptions of third-party operators, payment providers and services. ef98 does not include outbound hyperlinks to third-party websites on its standard content pages. Where any such references appear, they are for contextual and educational purposes only.

Payment method names referenced on the Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are mentioned as familiar Pakistani payment context. These references do not constitute links to, partnerships with or endorsements by those providers. Each provider operates under its own privacy policy and terms of service.

ef98 has no control over and accepts no responsibility for the content, privacy practices or data handling of any third-party service. Users who choose to access any third-party platform based on information found on ef98 do so at their own risk and should review the relevant privacy policy of that third party before providing any Personal Data.

ef98 reserves the right to update, amend or replace this Privacy Policy at any time. Revised versions will be published on this page with an updated effective date. Where changes are material — for example, changes to the categories of data collected, the purposes of processing or your rights — we will endeavour to provide prominent notice on the Platform.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes and your agreement to the revised terms, to the extent permitted by Applicable Law.

We recommend that you review this Policy periodically. The effective date at the top of this page indicates when the current version was last published.

For any questions, concerns, rights requests or complaints relating to this Privacy Policy or our data processing practices, please contact the ef98 team using the details below. All privacy-related correspondence should be submitted in English for the most accurate and timely response.

For further information about your rights and the legal framework governing data processing in Pakistan, you may wish to consult the relevant data protection authority or seek independent legal advice. Nothing in this Policy constitutes legal advice.