Privacy Policy — e89

This Privacy Policy ("Policy") is issued by e89 ("we," "us," "our"), the operator of the online casino and sports betting platform accessible at e89.im. It governs the collection, processing, storage, and disclosure of personal data relating to all registered players, prospective users, and visitors to the e89 website ("you," "your").

e89 is committed to handling your personal information with transparency, integrity, and in accordance with the data protection obligations imposed by our international gaming licence. By registering an account with e89 or continuing to use the e89.im platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read alongside the e89 Terms & Conditions and Responsible Gaming Policy, which together form the complete contractual and compliance framework governing your relationship with the platform.

e89 collects personal data through several channels: directly from you during registration and account use, automatically through your interactions with the platform, and from third parties such as payment processors and identity verification services. The categories of data we collect are set out below.

We do not intentionally collect special categories of sensitive personal data (such as racial or ethnic origin, religious beliefs, or health information) unless you voluntarily disclose such information through support interactions, in which case it is handled with heightened confidentiality standards.

e89 uses personal data collected from players exclusively for legitimate, specified purposes directly related to the operation of the platform and our legal obligations. The primary purposes for which your data is processed are as follows:

• Account creation and management: To register your e89 account, authenticate your identity at login, and maintain your account in good standing.
• Transaction processing: To process deposits made via JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT TRC20, and to execute withdrawal requests to your registered payment method.
• Identity and age verification: To verify that you are at least 21 years of age and that your identity matches the information on file, as required under our gaming licence obligations.
• Fraud prevention and AML compliance: To detect, investigate, and prevent fraudulent activity, money laundering, account sharing, and other prohibited conduct described in our Terms & Conditions.
• Responsible gaming: To monitor gaming behaviour for indicators of problem gambling and to enforce player-requested deposit limits, cooling-off periods, and self-exclusion requests.
• Platform improvement: To analyse aggregated, anonymised usage data to improve game offerings, platform performance, and user experience for Pakistani players.
• Promotional communications: To send you bonus offers, promotional updates, and relevant gaming news where you have opted in to marketing communications. You may withdraw this consent at any time.
• Customer support: To respond to your enquiries, process complaints, and maintain records of support interactions for quality assurance.
• Legal compliance: To fulfil obligations imposed by our international gaming licence, applicable anti-money laundering regulations, and any lawful requests from regulatory authorities.

e89 processes your personal data on one or more of the following legal grounds, depending on the nature of the processing activity:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions you accepted at registration — including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with our gaming licence conditions, anti-money laundering obligations, and any applicable regulatory or law-enforcement requests.
• Legitimate interests: Processing carried out in pursuit of e89's legitimate business interests — such as fraud detection, platform security, and responsible gaming monitoring — where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — most commonly applicable to marketing communications. Consent-based processing can be withdrawn at any time without affecting the lawfulness of prior processing.

Where e89 relies on legitimate interests as a legal basis, we carry out a balancing test to ensure that our interests do not override your fundamental rights and freedoms as an individual data subject.

e89 does not sell, rent, or trade personal data. We may share your information with the following categories of recipient only where strictly necessary and on the basis of appropriate data protection safeguards:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, SadaPay, Meezan Bank, and USDT wallet providers — solely to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers who assist in verifying your identity and age in accordance with our licensing requirements.
• Gaming software providers: Game studios and live dealer platform providers who supply the gaming content on e89.im. These providers may receive anonymised session data to support game performance and integrity monitoring.
• Fraud and AML screening services: Specialist providers who assist in detecting suspicious financial activity, duplicate accounts, and prohibited conduct patterns.
• Regulatory and law-enforcement authorities: Where required by law, court order, or regulatory instruction, e89 may disclose personal data to competent authorities. We will notify you of such disclosure where legally permitted to do so.
• Professional advisers: Legal counsel, auditors, and compliance consultants who are bound by confidentiality obligations and who advise e89 on its regulatory and legal obligations.

e89.im uses cookies and similar tracking technologies to ensure the platform functions correctly, to maintain your login session, and to gather anonymised analytics about how users navigate the site. The types of cookies we deploy are as follows:

• Strictly necessary cookies: These are essential for the platform to operate. They manage your authenticated session, maintain your language preferences, and protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Functional cookies: These remember your preferences — such as game view settings and notification preferences — to personalise your experience on return visits.
• Analytics cookies: These collect aggregated, anonymised data about page views, session duration, and navigation paths to help us identify and fix usability issues. No personally identifiable information is captured through analytics cookies.
• Security cookies: These assist in detecting and preventing fraudulent access attempts, bot traffic, and suspicious login behaviour.

e89 does not use third-party advertising cookies, cross-site tracking pixels, or retargeting technologies of any kind. You can control cookie behaviour through your browser settings; however, disabling strictly necessary cookies may impair your ability to log in or use certain platform features.

e89 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required to comply with legal and regulatory obligations. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus a minimum of 5 years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction and financial records: Retained for a minimum of 7 years following each transaction, as required for financial compliance and audit purposes.
• KYC documents (CNIC, passport): Retained for the duration of the account relationship plus 5 years post-closure. Copies are securely deleted beyond this period unless a legal hold applies.
• Customer support communications: Retained for 3 years from the date of the interaction for quality assurance and dispute resolution purposes.
• Gaming and wagering history: Retained for 5 years to support responsible gaming monitoring, dispute resolution, and regulatory reporting obligations.
• Marketing consent records: Retained for as long as your marketing preferences are active, plus 3 years following withdrawal of consent as evidence of the prior consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual. Where anonymisation is applied, the resulting dataset may be retained indefinitely for aggregate statistical analysis.

e89 implements a layered security architecture designed to protect personal data against unauthorised access, alteration, disclosure, and loss. Our key technical and organisational security measures include:

• Encryption: All data transmitted between your browser and e89 servers is protected using TLS 1.3. Sensitive data stored at rest — including financial records and KYC documents — is encrypted using AES-256.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. All internal access is logged and subject to regular review. Privileged access requires multi-factor authentication.
• Penetration testing: e89 commissions periodic independent security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident response: e89 maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify affected individuals and relevant authorities within the timeframes required by our licensing obligations.
• Secure payment processing: Payment data is handled exclusively by certified payment processors. e89 does not store full payment card numbers, CVVs, or mobile money PINs on its own servers.

As a player on e89, you hold meaningful rights over the personal data we hold about you. These rights can be exercised by contacting our support team via live chat or by emailing [email protected] with the subject line "Privacy Rights Request — [your account username]."

• Right of access: You may request a copy of all personal data that e89 holds about you. We will respond within 30 days of a verified request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. Minor updates — such as email address or phone number changes — can be made directly through your account settings.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other legal basis applies. Note that deletion requests may be subject to our legal retention obligations, which take precedence where applicable.
• Right to restriction of processing: You may request that we temporarily restrict processing of your data while a rectification request is pending or where you contest the legal basis for processing.
• Right to data portability: You may request a structured, machine-readable export of the personal data you provided to e89 during registration and account use.
• Right to object: You may object at any time to processing carried out on the basis of legitimate interests, including profiling for responsible gaming monitoring. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent: Where processing is based on consent — most commonly marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

e89 will acknowledge all privacy rights requests within 5 business days and provide a substantive response or request additional verification within 30 calendar days. We will never charge a fee for exercising your privacy rights under normal circumstances.

e89 operates a strict 21+ age policy. The platform is not intended for, marketed to, or accessible by individuals under the age of 21. We do not knowingly collect personal data from minors.

During registration, all players are required to declare that they are at least 21 years of age. e89 further verifies age through its mandatory KYC process, which requires submission of a valid government-issued identity document confirming date of birth. Any account found to have been registered by an individual under the age of 21 will be immediately closed and any deposits made to the account will be returned less any amounts that cannot be recovered due to gaming activity.

The e89 platform integrates with a number of third-party service providers to deliver a complete gaming experience. While e89 maintains strict contractual data protection standards with all third-party partners, each provider operates under their own independent privacy policy for data processed directly by them.

Categories of third-party service integrations on e89 include:

• Game content providers: Software studios supplying slot games, live dealer tables, and instant-win titles. These providers may collect anonymised gameplay telemetry directly from the game interface to support game integrity monitoring.
• Payment gateways: JazzCash, EasyPaisa, SadaPay, HBL, UBL, Meezan Bank, and USDT blockchain networks. Each processes your financial data under its own applicable terms and privacy policies.
• Identity verification (KYC) platforms: Specialist providers who process your identity documents to confirm eligibility. These are contractually bound to use your data only for the verification purpose for which it was shared.
• Live chat support software: The live chat tool embedded on e89.im may retain transcripts of support conversations. These transcripts are accessible to e89's support team and the platform provider under strict access controls.

e89 does not integrate social media sharing widgets, third-party advertising networks, or cross-site tracking pixels on any page of e89.im.

e89 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform services. When material changes are made — particularly changes that affect the way we collect, use, or share your personal data — we will notify you via email to your registered address or through an in-platform notification at least 14 days before the changes take effect.

Non-material amendments, such as typographical corrections or clarifications that do not alter the substance of the Policy, may be published without advance notice. The effective date displayed at the top of this page will be updated each time a revision is made.

The current version of the Privacy Policy published at e89.im/privacy-policy supersedes all previous versions. We recommend reviewing this page periodically to remain informed of how e89 handles your personal information. Your continued use of the platform after any published amendment constitutes acceptance of the revised Policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data e89 holds about you, please contact our team using the details below:

• Live Chat: Available 24/7 directly from the e89.im website. This is the fastest channel for all privacy-related enquiries from players in Karachi, Lahore, Islamabad, Faisalabad, and across Pakistan.
• Email: [email protected] — use the subject line "Privacy Policy Enquiry" for the fastest routing to our compliance team.

We aim to acknowledge all privacy-related correspondence within 2 business days and to provide a full substantive response within 30 calendar days of receipt. For complex data subject access requests, we may request additional identity verification before releasing any personal data.