s89 Privacy Policy

1. Who We Are

s89 ("s89", "we", "us", "our") is a licensed online casino and sports betting platform operating under an international gaming license. s89 serves players in Pakistan and other permitted territories, offering cricket betting, live dealer casino games, slots, baccarat, and related entertainment services.

For the purposes of this Privacy Policy, s89 is the data controller responsible for the personal data you provide when registering, using, or interacting with the s89 platform. Any queries relating to data protection and privacy should be directed to the s89 support team, whose contact details are provided in Section 15 of this policy.

This Privacy Policy applies to the s89 website, mobile platform, all sub-pages, and any communication channels operated by s89, including live chat, email support, and promotional communications.

2. Personal Data We Collect

s89 collects personal data from players at various stages of the registration, verification, and gameplay process. The categories of personal data we collect are as follows:

s89 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond what is strictly required for identity verification purposes under KYC obligations imposed by our gaming license.

3. How We Collect Your Data

3.1 Directly From You

The majority of personal data s89 holds is provided directly by you during the following interactions:

• Completing the s89 account registration form;
• Submitting KYC identity verification documents;
• Making a deposit or requesting a withdrawal via JazzCash, EasyPaisa, or Pakistani bank transfer;
• Contacting s89 support via live chat or email;
• Opting in to promotional communications or bonus offers;
• Using responsible gaming tools such as deposit limits or self-exclusion requests.

3.2 Automatically Through Platform Use

When you use the s89 platform, certain technical data is collected automatically through cookies, server logs, and analytics tools. This includes your IP address, device fingerprint, session data, and in-platform navigation behaviour. This data is used to maintain platform security, detect fraud, and improve user experience. Full details are provided in Section 9 (Cookies & Tracking).

3.3 From Third Parties

s89 may receive personal data about you from the following third-party sources:

• Identity Verification Providers: Third-party KYC services that cross-reference the identity documents you submit against official databases;
• Payment Processors: Transaction confirmation data from JazzCash, EasyPaisa, and Pakistani banking partners;
• Fraud Prevention Services: Risk scores and fraud signals from licensed anti-fraud and AML screening providers;
• Regulatory Authorities: Where required by law or gaming license obligation, information may be received from regulatory bodies.

4. How We Use Your Personal Data

s89 uses your personal data only for legitimate, specified purposes directly related to the operation of the s89 platform. The primary purposes for which your data is used are:

• Account Management: Creating, maintaining, and securing your s89 player account;
• Identity Verification (KYC): Verifying your identity to comply with our gaming license obligations and prevent underage gambling. All players must be 21 or older;
• Payment Processing: Processing deposits and withdrawals via your chosen Pakistani payment method (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, USDT);
• Fraud & AML Prevention: Monitoring transactions and account activity for signs of money laundering, fraud, or prohibited behaviour as required by our international gaming license;
• Customer Support: Responding to your queries, complaints, and support requests via live chat and email;
• Responsible Gaming: Operating deposit limits, self-exclusion tools, and responsible gaming monitoring systems to protect vulnerable players;
• Platform Improvement: Analysing aggregated usage data to improve platform performance, game selection, and user experience for Pakistani players;
• Legal & Regulatory Compliance: Meeting obligations imposed by our gaming license, applicable law, and regulatory authority directives;
• Marketing Communications: Sending promotional emails and platform notifications about bonuses, PSL betting offers, and new game launches — only where you have given consent or where there is a legitimate interest basis (see Section 5).

5. Legal Basis for Processing

s89 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil the contract between s89 and you as a registered player — including account management, payment processing, and customer support;
• Legal Obligation: Processing required to comply with obligations under our international gaming license, including KYC/AML obligations and responsible gaming requirements;
• Legitimate Interests: Processing for fraud prevention, platform security, and aggregate analytics, where these interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and optional personalisation features, where you have provided clear, informed, freely given consent. Consent may be withdrawn at any time.

6. Data Sharing & Disclosure

s89 does not sell, rent, or trade your personal data. We share your data only with third parties where it is necessary to operate the platform, comply with legal obligations, or protect the integrity of the s89 service. Data sharing occurs with the following categories of recipient:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency payment processors receive transaction data necessary to process your deposits and withdrawals. Each processor operates under its own privacy policy and data protection obligations;
• KYC & Identity Verification Providers: Licensed third-party providers who verify your identity documents and cross-check your details against AML screening databases;
• Fraud Prevention & AML Services: Specialist providers who analyse transaction patterns to detect and prevent money laundering and fraudulent activity on the platform;
• Gaming Software Providers: Game developers and live dealer studios whose platforms are integrated into s89 may receive session data necessary to deliver the game service;
• Regulatory Authorities: s89 may be required to disclose player data to the gaming regulatory authority under whose license s89 operates, or to law enforcement agencies where required by a valid legal order;
• Professional Advisers: Legal, accounting, and auditing firms engaged by s89 who are bound by professional confidentiality obligations.

All third-party service providers engaged by s89 are required to process personal data only in accordance with s89's instructions and under contractual data processing agreements that impose equivalent data protection standards.

7. International Data Transfers

As an internationally licensed gaming platform, s89 may transfer your personal data to servers and service providers located outside Pakistan. Where such transfers occur, s89 takes appropriate measures to ensure that your personal data receives an equivalent level of protection, including:

• Entering into standard contractual clauses with data recipients that impose data protection obligations;
• Transferring data only to service providers in jurisdictions that maintain adequate data protection frameworks;
• Applying additional technical safeguards such as encryption in transit for all cross-border data transfers.

By using s89, you acknowledge that your personal data may be transferred to and processed in countries outside Pakistan. s89 will always take reasonable steps to ensure the security and integrity of your data regardless of where it is processed.

8. Data Retention

s89 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and licensing obligations. The following retention periods apply as a general guide:

When personal data is no longer required for any lawful purpose, s89 will securely delete or anonymise it. Anonymised aggregate data (from which individual players cannot be identified) may be retained indefinitely for statistical and analytical purposes.

9. Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit the s89 platform. They allow the platform to recognise your device across sessions, remember your preferences, and collect analytical data about how the platform is used. Similar technologies such as web beacons, pixel tags, and local storage objects may also be used.

9.2 Types of Cookies Used by s89

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your s89 account and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred deposit method, and interface layout. Disabling these cookies may affect your platform experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and use the s89 platform. This data is used to improve platform performance and user experience. s89 uses only first-party analytics; no third-party advertising networks have access to s89 analytics data.
• Responsible Gaming Cookies: Store your active deposit limits, session reminder settings, and cool-off period status locally to ensure these restrictions are consistently applied across your sessions.

9.3 Managing Cookies

You can manage non-essential cookies through the cookie preference centre available on the s89 platform. You may also configure your browser to refuse or delete cookies, though this may affect the functionality of your s89 account. Strictly necessary cookies cannot be disabled without preventing the platform from operating correctly.

10. Children & Minors

The s89 platform is strictly for users aged 21 years and above. s89 does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the s89 KYC process, and accounts where the registered player is found to be under 21 will be immediately suspended.

If s89 becomes aware that personal data has been collected from a person under the age of 21 without verified parental or guardian consent, that data will be deleted as soon as reasonably practicable and the account will be permanently closed. If you believe that a minor has registered on s89, please contact the support team immediately via live chat.

11. Marketing Communications

s89 may send you marketing communications about bonuses, PSL betting promotions, new slot releases, live casino events, and other s89 offers. Marketing communications are sent only where:

• You have opted in to receive promotional emails or platform notifications during registration or account settings; or
• s89 has a legitimate interest in communicating with you as an active player about directly relevant platform updates.

You may opt out of marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email from s89;
• Updating your communication preferences in your s89 account settings;
• Contacting s89 support via live chat and requesting removal from all marketing communications.

Opting out of marketing communications will not affect the delivery of transactional messages such as deposit confirmations, withdrawal notifications, KYC requests, or account security alerts, which s89 must send to fulfil its contractual obligations to you.

12. Security Measures

s89 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS Encryption: All data transmitted between your device and the s89 platform is encrypted using Transport Layer Security (TLS 1.2 or higher);
• AES-256 Encryption at Rest: Personal data stored in s89 databases is encrypted at rest using AES-256 industry-standard encryption;
• Two-Factor Authentication (2FA): Players are strongly encouraged to enable 2FA on their s89 accounts as an additional layer of account security;
• Access Controls: Internal access to player personal data is restricted to authorised s89 personnel on a strict need-to-know basis. All access is logged and audited;
• Security Monitoring: s89 infrastructure is monitored 24/7 for security threats, intrusion attempts, and anomalous access patterns;
• Third-Party Security Audits: s89's platform and data handling practices are subject to periodic independent security review as part of our gaming license obligations.

Despite these measures, no method of electronic transmission or storage is 100% secure. s89 cannot guarantee absolute security of your data but commits to notifying affected players and relevant authorities promptly in the event of a data breach that poses a risk to your rights, in accordance with applicable law.

13. Exercising Your Data Rights

To exercise any of your data subject rights — including access, rectification, erasure, portability, objection, or restriction — please contact the s89 support team using the details in Section 15. When submitting a data rights request, please:

• Clearly identify the right you wish to exercise;
• Provide sufficient information for s89 to verify your identity (your registered email address and account username are sufficient in most cases);
• Specify the data or processing activity your request relates to.

s89 will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days. Where a request is complex or there are multiple requests, s89 may extend this period by a further 30 days with notice. There is no charge for exercising your data rights, unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

14. Updates to This Privacy Policy

s89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in data protection law, gaming license requirements, or our data processing practices. The updated policy will be published on this page with a revised effective date.

Where changes to this Privacy Policy are material — meaning they significantly affect how your personal data is used or your rights as a data subject — s89 will make reasonable efforts to notify active players via the platform or by email to your registered address prior to the changes taking effect.

Your continued use of the s89 platform after the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with a material change, you may request account closure by contacting s89 support before the change takes effect.

15. Contact & Data Protection Queries

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by s89, please contact the s89 support team through the following channels:

s89 is committed to resolving all privacy-related queries promptly and transparently. If you are not satisfied with how s89 has handled a data protection concern, you may escalate the matter to the relevant gaming regulatory authority or data protection supervisory body under whose jurisdiction s89 operates.