Privacy Policy

Section 1

Introduction

SZ88 ("SZ88", "we", "us", or "our") operates the online betting and casino information platform accessible at sz88.cam ("the Platform"). This Privacy Policy ("Policy") describes how SZ88 collects, processes, stores, shares, and protects personal data relating to individuals who access or use the Platform ("Users", "you", or "your").

By registering an account, accessing the Platform, or using any SZ88 service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you should cease using the Platform immediately.

This Policy should be read in conjunction with SZ88's Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

Section 2

Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, national identity number, financial details, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transfer, or deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, SZ88.
• "Data Processor" means a third party that processes Personal Data on behalf of and under the instruction of SZ88.
• "Consent" means a freely given, specific, informed, and unambiguous indication by the User, by a statement or clear affirmative action, signifying agreement to the processing of their Personal Data.
• "KYC" means Know Your Customer — the identity and age verification process required to comply with anti-money laundering and responsible gambling obligations.
• "Cookie" means a small data file placed on a User's device by the Platform to facilitate session management, analytics, and personalised content.
• "Sensitive Personal Data" means Personal Data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or financial account details, which is afforded enhanced protection under applicable data protection law.

Section 3

Data Controller

SZ88 acts as the Data Controller in respect of Personal Data collected through the Platform. The Platform is operated and administered from the jurisdiction in which SZ88 holds its operating licence. For any privacy-related enquiries, including requests to exercise your data rights, please contact us using the details provided in Section 15 of this Policy.

Section 4

Data We Collect

SZ88 collects Personal Data through several channels during the course of the User's interaction with the Platform. The categories of data collected are described below:

4.1 Registration Data

When you create an Account, we collect:

• Full legal name (as appearing on your CNIC or equivalent identity document);
• Date of birth (for age verification purposes);
• Email address;
• Username and password (stored in hashed, non-reversible form);
• Country of residence and, where provided, city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar);
• Mobile phone number (where provided for two-factor authentication).

4.2 KYC and Identity Verification Data

To fulfil KYC obligations and responsible gambling requirements, we may collect:

• Government-issued identity documents (e.g., CNIC, passport);
• Proof of address documentation;
• Source of funds documentation where required by anti-money laundering procedures.

4.3 Financial and Transaction Data

We collect transaction data relating to deposits and withdrawals, including:

• Deposit and withdrawal amounts in PKR or other supported currencies;
• Payment method identifiers (e.g., partial account numbers — full financial credentials are handled by payment processors and are not stored on SZ88 servers);
• Transaction history, timestamps, and processing status.

4.4 Platform Usage and Activity Data

We automatically collect usage data when you interact with the Platform, including:

• IP address and device type;
• Browser type, version, and operating system;
• Pages visited, time spent, and clickstream data;
• Betting and gaming activity, including markets accessed, wagers placed, and game sessions;
• Session timestamps and login history.

4.5 Communication Data

When you contact our support team via live chat or email, we retain a record of your communication, including the content of your query, your account reference, and the support agent's responses.

4.6 Data You Choose to Provide

You may voluntarily provide additional information when setting account preferences, completing responsible gambling self-assessments, or interacting with Platform features. Such data is collected only to the extent you choose to provide it.

Section 5

Data Processing & Purpose

SZ88 processes Personal Data only for specified, explicit, and legitimate purposes. The table below sets out the primary purposes for which your data is processed and the corresponding legal basis for each activity:

SZ88 does not use Personal Data to make purely automated decisions that produce significant legal effects on Users, except where this is expressly required by applicable law or regulatory obligation.

Section 6

Legal Basis for Processing

SZ88 processes Personal Data under one or more of the following legal bases, depending on the nature and purpose of the specific processing activity:

• Contract Performance: Processing is necessary to perform the contract between SZ88 and the User — including account management, wager processing, and withdrawal fulfilment.
• Legal Obligation: Processing is required to comply with applicable legal and regulatory requirements, including KYC, AML, responsible gambling obligations, and mandatory reporting to licensing authorities.
• Legitimate Interests: Processing is necessary for the legitimate interests of SZ88, including Platform security, fraud detection, abuse prevention, and analytics — provided such interests are not overridden by the User's rights and freedoms.
• Consent: Where SZ88 relies on your consent (for example, for marketing communications or non-essential cookies), you have the right to withdraw that consent at any time without detriment to your account. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Section 7

Data Sharing

SZ88 does not sell, rent, or commercially exploit your Personal Data to third parties. We may, however, share your Personal Data with the following categories of recipients where necessary for legitimate purposes:

7.1 Service Providers and Data Processors

SZ88 engages trusted third-party service providers who process Personal Data on our behalf under data processing agreements, including:

• KYC and identity verification technology providers;
• Payment processing and fraud detection providers — note that SZ88 does not store full payment credentials; these are managed by the respective payment processors;
• Cloud hosting and infrastructure providers;
• Customer support platform providers;
• Analytics and platform-performance monitoring tools.

7.2 Regulatory and Legal Authorities

SZ88 may disclose Personal Data to regulatory authorities, law enforcement agencies, courts, or other public bodies where required to do so by applicable law, court order, or regulatory obligation. This includes disclosures required under anti-money laundering legislation in the jurisdiction where SZ88 is licensed.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of SZ88's assets, Personal Data held by SZ88 may be transferred to the acquiring entity. Users will be notified of any such transfer that materially affects the processing of their Personal Data.

Section 8

International Transfers of Personal Data

The SZ88 Platform operates from a jurisdiction outside Pakistan. Accordingly, Personal Data submitted by Pakistani users is transferred to and processed in jurisdictions that may have different data protection standards from those applicable in Pakistan.

Where Personal Data is transferred internationally, SZ88 implements appropriate safeguards to protect your data, which may include:

• Contractual clauses binding Data Processors to equivalent data protection obligations;
• Technical and organisational security measures appropriate to the sensitivity of the data involved;
• Restriction of access to Personal Data on a need-to-know basis.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data to jurisdictions outside Pakistan as described in this section.

Section 9

Data Retention

SZ88 retains Personal Data for no longer than is necessary for the purposes for which it was collected, subject to applicable legal and regulatory retention obligations. The following general retention periods apply:

Following the expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be attributed to an identifiable individual. Data subject to mandatory legal hold is retained until the relevant legal obligation is discharged.

Section 10

Cookies & Tracking Technologies

SZ88 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by the Platform's server. Cookies do not contain executable code and cannot be used to access files on your device.

10.1 Categories of Cookies

10.2 Managing Cookies

You may control and manage cookies through your browser settings. Most browsers allow you to refuse non-essential cookies, delete existing cookies, or receive an alert when a cookie is set. Please note that disabling strictly necessary cookies will prevent the Platform from functioning correctly.

SZ88 does not respond to browser-based Do Not Track (DNT) signals at this time, but we honour cookie consent preferences captured through our Platform's cookie management interface.

Section 11

User Rights

Subject to applicable law and any overriding regulatory retention obligations, Users have the following rights in relation to their Personal Data held by SZ88:

• Right of Access: You may request a copy of the Personal Data SZ88 holds about you, along with information about how it is processed. We will respond to verified access requests within a reasonable timeframe.
• Right to Rectification: If you believe that any Personal Data held by SZ88 is inaccurate or incomplete, you may request that it be corrected. You may update basic account details directly through your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request that SZ88 delete your Personal Data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent (where consent is the legal basis). Note that erasure requests may be subject to overriding legal retention requirements — for example, AML and KYC records cannot be deleted during mandatory retention periods.
• Right to Restriction of Processing: You may request that SZ88 limit the processing of your Personal Data in certain circumstances — for example, while a rectification request is under review.
• Right to Data Portability: Where processing is based on consent or contract performance and is carried out by automated means, you may request that your Personal Data be provided to you in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including direct marketing. You may opt out of marketing communications at any time through your account preferences or by contacting support.
• 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 prior to withdrawal.

Section 12

Security Measures

SZ88 implements a range of technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between Users' devices and the Platform;
• At-rest encryption for databases containing Personal Data and sensitive account information;
• Password hashing using industry-standard one-way cryptographic functions — SZ88 staff cannot access User passwords in plain text;
• Role-based access controls limiting staff access to Personal Data on a strict need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures to detect, contain, and notify Users of material data breaches within the timeframes required by applicable law.

While SZ88 takes reasonable and appropriate measures to protect Personal Data, no online platform can guarantee absolute security against all possible threats. Users are encouraged to protect their account credentials, enable two-factor authentication, and report any suspected unauthorised access to support immediately.

Section 13

Minors & Age Verification

The SZ88 Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction, whichever applies. SZ88 does not knowingly collect Personal Data from individuals below the minimum age requirement.

Age verification is a mandatory component of the KYC process. Accounts found to belong to underage individuals will be closed immediately, and Personal Data collected in connection with such accounts will be deleted or retained only to the extent required by applicable legal obligations.

If you have reason to believe that a minor has registered an account on the Platform or provided Personal Data without parental consent, please notify SZ88 support immediately.

Section 14

Policy Amendments

SZ88 reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The revised Policy will be published at sz88.cam/privacy-policy with an updated effective date.

Where an amendment materially affects your rights or the way in which your Personal Data is processed, SZ88 will notify registered Users via the email address associated with their Account or through a prominent notice displayed on the Platform at login.

Your continued use of the Platform following publication of a revised Privacy Policy constitutes acceptance of the amended terms. If you do not agree with any amendment, you must cease using the Platform and may request account closure in accordance with the process described in the Terms & Conditions.

Section 15

Contact Us

For all privacy-related enquiries, data rights requests, or complaints regarding SZ88's handling of your Personal Data, please contact us using the details below. We are committed to responding to all privacy-related communications promptly and transparently.