Privacy Policy — sq98

1. Introduction

sq98 ("the Platform", "we", "us", "our") operates the online gaming information and entertainment service accessible at sq98.cam. This Privacy Policy ("Policy") sets out how sq98 collects, processes, stores, shares and protects personal data provided by users ("Players", "you", "your") when accessing the Platform's services.

sq98 is committed to handling all personal data responsibly, transparently and in accordance with applicable data protection principles. This Policy applies to all Players, including those accessing the Platform from cities across Pakistan — Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — as well as international users where the Platform is accessible.

By registering an account, depositing funds or otherwise accessing the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform.

2. Definitions

In this Policy, the following terms carry the meanings set out below:

• "Controller" — the entity that determines the purposes and means of processing personal data; in this context, sq98 and/or its operating affiliate as identified in the Platform's licensing documentation.
• "Data Subject" — any identified or identifiable natural person whose personal data is processed; in this context, registered Players and Platform visitors.
• "Personal Data" — any information relating to an identified or identifiable individual, including name, contact details, financial information, device identifiers and behavioural data.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "KYC" — Know Your Customer verification procedures requiring identity document submission prior to account activation or withdrawal processing.
• "Cookies" — small data files stored on a user's device by a web browser for purposes including session management, analytics and personalisation.
• "Third-Party Processor" — an external service provider engaged by sq98 to process Personal Data on the Platform's behalf, subject to contractual data protection obligations.
• "Sensitive Data" — a subset of Personal Data requiring heightened protection, including government-issued identity document numbers, financial account details and, where applicable, health-related information relevant to responsible gambling assessments.

3. Personal Data We Collect

3.1 Registration Data

When you create an account on sq98, we collect: full legal name, date of birth, email address, mobile number, preferred currency (PKR / Rs where applicable), country and city of residence, and any username or display name you select.

3.2 Identity Verification Data (KYC)

To comply with applicable anti-money laundering and responsible gambling obligations, we collect: copies of government-issued identity documents (CNIC, passport or equivalent), proof of address documentation, and — where required — source-of-funds declarations.

3.3 Financial Transaction Data

We collect data relating to deposits, withdrawals and payment method details as entered in the cashier. Where familiar Pakistani payment rails such as Easypaisa, JazzCash, Raast or bank accounts at institutions including HBL, UBL, Meezan Bank or Bank Alfalah are used, transaction metadata necessary for processing and reconciliation is retained. These references are contextual; no data-sharing arrangement with those providers is implied beyond what is strictly necessary to process a transaction.

3.4 Gameplay & Behavioural Data

We record game activity including bet amounts, outcomes, session duration, game categories accessed (e.g., cricket betting, live casino, slots, crash games), platform navigation patterns and responsible gambling tool usage (deposit limits set, self-exclusion requests, etc.).

3.5 Device & Technical Data

We automatically collect IP address, browser type and version, operating system, device type, screen resolution, referring URL, pages visited, time spent on pages and approximate geographic location derived from IP data.

3.6 Communications Data

If you contact our support team, we retain records of correspondence including email content, live chat transcripts, the nature of your query and the resolution provided.

4. How Personal Data Is Collected

We collect Personal Data through the following mechanisms:

• Directly from you — via registration forms, KYC submission portals, cashier inputs and support communications.
• Automatically — through cookies, pixel tags, server logs and analytics tools when you visit and interact with the Platform.
• From third parties — identity verification service providers, fraud prevention databases, payment processors and, where applicable, publicly available sources used to validate submitted information.

5. Data Processing & Purpose

The table below summarises the primary purposes for which we process your Personal Data:

6. Legal Basis for Processing

sq98 processes Personal Data on the following legal grounds, consistent with applicable data protection frameworks:

• Contractual necessity — processing required to fulfil the Terms & Conditions agreement with you, including account management, payment processing and game service delivery.
• Legal obligation — processing required to comply with anti-money laundering regulations, responsible gambling obligations and applicable licensing conditions.
• Legitimate interests — processing for fraud prevention, platform security, analytics and service improvement where such interests are not overridden by your fundamental rights and freedoms.
• Consent — processing for optional marketing communications, certain cookie categories and any processing activity where we have expressly requested and obtained your consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Cookies & Tracking Technologies

7.1 What We Use

sq98 uses cookies and similar tracking technologies including pixel tags, web beacons and local storage objects. These are used to maintain login sessions, remember user preferences, measure page performance, prevent fraud and — where you have consented — deliver relevant content.

7.2 Cookie Categories

• Strictly Necessary: Essential for the Platform to function. These cannot be disabled. Examples include session authentication cookies and security tokens.
• Functional: Remember your preferences such as language settings and responsible gambling limit configurations. Disabled cookies in this category may affect Platform functionality.
• Analytics: Help us understand how players navigate the Platform — which game categories are accessed most, how long sessions last, and where navigation issues occur. Data is aggregated and anonymised where possible.
• Marketing: Used to present relevant promotional information about sq98 features. These are only activated with your explicit consent.

7.3 Managing Cookies

You may manage cookie preferences through your browser settings or the Platform's cookie consent tool. Disabling certain cookies may affect your ability to use parts of the Platform — for example, disabling strictly necessary cookies will prevent login session maintenance.

8. Data Sharing & Third-Party Disclosure

sq98 does not sell your Personal Data to third parties. We may share your data in the following circumstances:

• Service Providers: Third-party processors engaged to deliver platform services — including payment processing, identity verification, cloud hosting, analytics and customer support infrastructure — operate under strict data processing agreements requiring them to handle your data only as instructed by sq98.
• Regulatory & Legal Obligations: We may disclose Personal Data to regulatory bodies, law enforcement agencies or courts where required by applicable law or in response to valid legal process, including obligations arising under anti-money laundering frameworks.
• Fraud & Security: We may share data with fraud prevention services and gaming industry shared databases to detect and prevent fraudulent activity, including the operation of multiple accounts or abuse of bonus structures.
• Corporate Transactions: In the event of a merger, acquisition or asset sale affecting the Platform, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

Payment provider names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced throughout this Policy for contextual familiarity. Any data-sharing with payment processors is limited strictly to transaction data required to process your specific payment instruction and does not imply broader data partnerships with those institutions.

9. Data Retention

sq98 retains Personal Data for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal, regulatory and compliance obligations. Indicative retention principles are as follows:

• Account data: Retained for the duration of the account's active status plus a post-closure period as required by licensing or AML obligations (typically five to seven years).
• KYC documents: Retained for the period required by applicable anti-money laundering regulations from the date of the last transaction or account closure.
• Financial transaction records: Retained for a minimum of five years from transaction date in accordance with standard financial record-keeping requirements.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, whichever is earlier.
• Support communications: Retained for up to three years from the date of resolution unless a longer period is required for dispute or regulatory purposes.
• Analytics data: Aggregated or anonymised data may be retained indefinitely for platform improvement purposes.

Upon expiry of applicable retention periods, Personal Data is securely deleted or anonymised in accordance with the Platform's data disposal procedures.

10. Data Security

sq98 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, loss, alteration or disclosure. These include:

• SSL/TLS encryption for all data transmitted between your device and Platform servers
• Encryption at rest for sensitive stored data including KYC documents and financial information
• Access controls limiting staff access to Personal Data on a strict need-to-know basis
• Regular security assessments and penetration testing of Platform infrastructure
• Two-factor authentication options for player account access
• Incident response procedures for prompt identification, containment and notification of data security breaches

Whilst sq98 employs industry-standard security practices, no digital system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately at [email protected] if you suspect unauthorised access to your account.

11. Your Data Rights

Subject to applicable data protection law and the Platform's licensing jurisdiction, you hold the following rights in respect of your Personal Data. To exercise any of these rights, contact us at [email protected] with your account identifier and a clear description of your request.

We will respond to all verified data rights requests within a reasonable timeframe consistent with applicable law. We may need to verify your identity before processing a request. Certain rights may be subject to limitations where legal retention or compliance obligations apply.

12. International Data Transfers

sq98 may transfer Personal Data to servers, processors or affiliated entities located outside Pakistan and outside the jurisdiction in which you are located. Such transfers are necessary for the operation of a globally distributed gaming platform and its supporting infrastructure.

Where data is transferred internationally, sq98 takes reasonable steps to ensure that appropriate safeguards are in place to protect Personal Data to a standard consistent with the principles set out in this Policy. This may include contractual data transfer mechanisms, standard contractual clauses or transfer to jurisdictions that maintain equivalent data protection standards.

Pakistani privacy law and data protection frameworks continue to evolve. sq98 monitors regulatory developments and will update this Policy accordingly where material changes to transfer obligations arise.

13. Minors & Age Verification

sq98 is strictly an adults-only platform. Access to, and registration on, the Platform is limited to individuals aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect Personal Data from individuals under the applicable minimum age.

Age verification is conducted during the KYC process. Where evidence emerges that a registered account belongs to a minor, sq98 will immediately suspend the account, void any outstanding activity and delete or securely retain the associated Personal Data only to the extent required by applicable compliance obligations.

If you are a parent or guardian and believe a minor has accessed the Platform, please contact us immediately at [email protected]. The 18+ requirement does not imply that gambling is lawful for all adult individuals under Pakistani law. Players must satisfy themselves as to their own legal position.

14. Third-Party Links & External Services

The sq98 Platform may reference third-party services, payment providers or other external resources in an informational context. This Policy does not extend to the privacy practices of any third party. When you access services provided by third parties — including payment processors — their own privacy policies govern the handling of your data by those parties.

sq98 is not responsible for the content, privacy standards or data practices of any third-party service, and the inclusion of a payment provider name or service reference on the Platform does not constitute endorsement of that provider's privacy or security practices.

15. Policy Amendments

sq98 reserves the right to amend this Privacy Policy at any time. Material changes will be communicated by posting an updated Policy on the Platform with a revised "Last Updated" date. Where changes significantly affect how we process your Personal Data, we will seek to provide reasonable advance notice through your registered contact details.

Continued use of the Platform following publication of an updated Policy constitutes acceptance of the revised terms. Players who do not accept material amendments should discontinue use of the Platform and may request account closure in accordance with the Terms & Conditions.

16. Contact Us

For all data protection queries, Personal Data access requests, consent withdrawal notifications or privacy-related complaints, please contact the sq98 data team using the details below. Please include your registered account identifier and a clear description of your request to ensure prompt handling.

You may also review related policies and resources: Terms & Conditions · Responsible Gambling · FAQ. Our About Us page provides additional background on sq98's values and operating principles.