Privacy Policy — as8com

This Privacy Policy ("Policy") describes how as8com ("Company", "we", "us", "our") collects, processes, stores and protects the personal data of individuals ("Users", "you", "your") who access or use the as8com platform, including the website at https://as8com.cam, its mobile interface and associated services (collectively, the "Platform").

as8com is an English-language online betting and gaming information platform serving users across Pakistan — from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We take data privacy seriously and are committed to processing personal information lawfully, fairly and transparently.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both of which form part of the overall contractual framework between you and as8com. By using the Platform, you acknowledge that you have read and understood this Privacy Policy.

If you have questions about how your data is handled, please contact us at [email protected] before providing any personal information.

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, including name, email address, device identifiers, payment details and location data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure and deletion.
• "Data Controller" means as8com, which determines the purposes and means of Processing Personal Data.
• "Data Processor" means a third party engaged by as8com to Process Personal Data on its behalf under a contractual data-processing agreement.
• "Consent" means a freely given, specific, informed and unambiguous indication of the User's agreement to the Processing of their Personal Data for a stated purpose.
• "KYC Data" means identity verification documents and associated information collected for Know Your Customer purposes, including CNIC images, passport copies, selfies and proof of address.
• "Cookies" means small text files placed on a User's device by the Platform for functional, analytical or marketing purposes.
• "Platform" has the same meaning as defined in the Terms & Conditions — the as8com website, mobile interface and associated services.

as8com collects Personal Data through several distinct channels. The categories of data we collect are described in the table below:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data or biometric data beyond liveness checks required for KYC verification. We do not collect full payment card numbers — these are processed directly by our third-party payment service providers and are not stored on as8com systems.

as8com processes Personal Data on one or more of the following legal bases, depending on the purpose for which the data is processed:

• Contractual Necessity: Processing that is required to perform our contract with you — including account registration, payment processing, bet settlement and customer support.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC verification, anti-money laundering (AML) obligations and fraud prevention.
• Legitimate Interests: Processing that serves as8com's legitimate business interests, provided these interests are not overridden by your fundamental data-protection rights. This includes platform security monitoring, fraud detection, service improvement analytics and responsible gambling monitoring.
• Consent: Where we rely on consent as the legal basis — principally for optional marketing communications — you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

as8com uses Personal Data collected from Users for the following purposes:

• Account Management: Creating, maintaining, verifying and administering your Account, including password recovery and two-factor authentication.
• KYC & Compliance: Verifying your identity and age, preventing fraud, conducting AML screening and complying with applicable regulatory requirements.
• Transaction Processing: Processing deposits, withdrawals and bonus credits in PKR through confirmed payment methods including, where available, local references such as Easypaisa, JazzCash and Raast bank transfers.
• Service Delivery: Presenting odds, game content, live dealer feeds and account history accurately and in real time.
• Responsible Gambling Monitoring: Identifying unusual betting patterns, enforcing user-set limits, responding to self-exclusion requests and fulfilling our duty-of-care obligations.
• Customer Support: Responding to enquiries, resolving disputes and processing complaints. Support is provided in English; Urdu assistance is available on request.
• Security & Fraud Prevention: Detecting and preventing unauthorised access, multi-accounting, collusion, money laundering and other prohibited activities.
• Platform Improvement: Analysing anonymised usage data to improve Platform performance, usability and content quality for Pakistani users.
• Marketing Communications: Sending promotional offers, bonus notifications and platform updates to Users who have opted in. You may unsubscribe at any time through your Account settings.
• Legal Compliance: Retaining records required by applicable law, including transaction logs and KYC documentation, for the periods specified in Section 8.

as8com does not sell, rent or otherwise commercialise your Personal Data to third parties. Data is shared only in the following circumstances and only to the extent necessary:

• Service Providers (Data Processors): We engage third-party vendors to assist with identity verification, payment processing, fraud detection, customer support tooling and platform analytics. All service providers are bound by contractual data-processing agreements that restrict their use of your data to the specific services they provide.
• Payment Processors: Financial transaction data is shared with payment processors to facilitate deposits and withdrawals. Payment references — such as Easypaisa, JazzCash and bank identifiers — are transmitted only to the extent required to process the specific transaction.
• Regulatory & Law Enforcement Authorities: We may be required to disclose Personal Data to competent authorities — including financial intelligence units, law enforcement agencies or courts — in response to a lawful order, court direction or statutory obligation. We will notify you of such disclosure where we are legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of as8com's business assets, Personal Data held by as8com may be transferred to the acquiring entity. Users will be notified in advance of any such transfer that materially affects how their data is processed.
• Professional Advisors: Personal Data may be disclosed to legal counsel, auditors or insurers where necessary for the conduct of legal proceedings, regulatory audits or risk assessments, subject to professional confidentiality obligations.

as8com will not share your Personal Data with any third party for that party's independent marketing or commercial purposes without your prior explicit consent.

as8com operates internationally and may transfer Personal Data to servers or service providers located outside Pakistan. Where such transfers occur, as8com takes steps to ensure that appropriate safeguards are in place to protect your data, including:

• Entering into data transfer agreements that incorporate standard contractual clauses recognised as providing adequate protection;
• Engaging service providers located in jurisdictions that are recognised as providing an adequate level of data protection;
• Applying equivalent technical and organisational security measures to data regardless of where it is processed.

By using the Platform, you acknowledge that your Personal Data may be transferred, stored and processed outside Pakistan. Where you wish to understand the specific safeguards applicable to a particular transfer, please contact us at [email protected].

as8com retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal obligations. The following indicative retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or, where deletion is not technically feasible, anonymised so that it can no longer be linked to an identifiable individual.

as8com uses cookies and similar tracking technologies (collectively, "Cookies") to operate the Platform, analyse usage patterns and, where you have consented, deliver personalised marketing content. The main categories of Cookies used are:

• Strictly Necessary Cookies: Essential for the Platform to function. These Cookies enable session management, login persistence, security token handling and fraud prevention. They cannot be disabled without breaking core Platform functionality.
• Performance & Analytics Cookies: Collect anonymised data about how Users interact with the Platform — such as pages visited, session duration and device type — to help us improve the user experience for players across Pakistan.
• Functional Cookies: Remember your preferences — including language setting (English), currency display (PKR) and Pakistan Standard Time zone selection — to personalise your experience on return visits.
• Marketing & Targeting Cookies: Used to deliver promotional content relevant to your interests, based on browsing behaviour on the Platform. These Cookies are only deployed where you have given explicit consent.

You may manage Cookie preferences through your browser settings. Disabling non-essential Cookies will not affect your ability to use the core betting and gaming features of the Platform. Note that some browser-level Cookie restrictions may affect the functionality of certain Platform features.

as8com implements a layered set of technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, destruction, disclosure or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between the User's device and as8com's servers;
• Encryption at rest for sensitive Personal Data, including KYC documents and payment identifiers;
• Role-based access controls ensuring that only authorised personnel with a defined business need may access Personal Data;
• Two-factor authentication options for User Accounts and mandatory multi-factor authentication for internal administrative access;
• Regular security assessments, including vulnerability scanning and penetration testing;
• Incident response procedures to detect, contain, investigate and notify affected parties in the event of a data breach, within applicable notification timeframes.

Despite these measures, no transmission over the internet or method of electronic storage can be guaranteed to be 100% secure. You use the Platform at your own risk and are encouraged to maintain strong, unique passwords and to enable two-factor authentication on your Account.

The Platform is strictly for adults. as8com does not knowingly collect Personal Data from individuals under the age of 18 — or the higher minimum age required by the applicable operator/license jurisdiction. If you are under the applicable minimum age, you must not register an Account or provide any Personal Data to as8com.

Where as8com identifies or suspects that Personal Data has been provided by a minor, the associated Account will be closed immediately, all data will be deleted in accordance with applicable obligations, and the matter may be reported to the appropriate authority.

Parents and guardians who believe that their child may have provided Personal Data to as8com should contact our support team at [email protected] immediately.

Subject to applicable law and the limitations described below, you hold the following rights in relation to your Personal Data processed by as8com:

To exercise any of these rights, please submit a written request to [email protected]. We will acknowledge your request within 5 business days and aim to respond substantively within 30 days. Where a request is complex or high in volume, this period may be extended by a further 30 days with prior notification to you.

Certain rights are subject to limitations where data is required for the performance of a contract, fulfilment of legal obligations or legitimate security purposes. We will explain any applicable limitations clearly when responding to your request.

With your prior consent, as8com may send you marketing communications about promotions, bonuses, new game releases, PSL season specials, ICC tournament offers and other platform news. These communications may be sent by email, push notification or, where you have provided a mobile number, by SMS.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in the Account settings;
• Clicking the unsubscribe link included in any marketing email;
• Contacting our support team at [email protected].

Withdrawal of marketing consent will not affect the lawfulness of communications sent prior to withdrawal, nor will it affect your receipt of transactional or service communications — such as deposit confirmations, withdrawal notifications and KYC status updates — which are necessary for the operation of your Account.

If you have activated self-exclusion under the Responsible Gambling Policy, all marketing communications will be suspended for the duration of the exclusion period regardless of your general marketing consent status.

The Platform may reference third-party payment services — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — as familiar local payment context. These references are provided for user convenience only. as8com does not control the privacy practices of these third-party organisations and is not responsible for their data-processing activities.

Where the Platform integrates third-party services — including game technology providers, live streaming partners and sports data feeds — the data shared with such providers is limited to what is strictly necessary for the delivery of the relevant service, and all third-party integrations are governed by contractual data-processing agreements.

This Privacy Policy does not cover the data practices of any third-party website, application or service that may be referenced or integrated into the Platform. We encourage you to review the privacy policies of any third-party services you use in connection with your as8com Account.

as8com reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, our data-processing practices or the services offered on the Platform. Where changes are material, we will provide advance notice by posting a prominent notice on the Platform or by sending a notification to the email address registered to your Account.

The "Effective Date" displayed at the top of this Policy reflects the date on which the most recent version came into effect. Your continued use of the Platform following the effective date of any update constitutes your acknowledgement of the revised Policy.

We recommend reviewing this Privacy Policy periodically to stay informed of how we handle your Personal Data.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the as8com Data Privacy team using the details below. We take all data privacy enquiries seriously and will respond promptly.

• Email: [email protected]
• Subject Line: Please include "Privacy Policy Enquiry" or "Data Rights Request" in the subject line for faster routing.
• Support Hours: 24 hours a day, 7 days a week
• Response Language: English. Urdu assistance available on request.
• Response Time: Acknowledgement within 5 business days; substantive response within 30 days.

Please do not include your password, full payment card number or any other highly sensitive information in written support communications.