Privacy Policy – Spribe Pakistan: How We Protect Your Data

This Privacy Policy is published by Spribe, the operator of spribe.click — an online gaming platform serving players in Pakistan. When this Policy refers to "Spribe", "we", "our" or "us", it means the licensed entity that operates spribe.click and all gaming services available through it.

Spribe acts as the data controller for personal data collected through the platform. This means we are responsible for determining how and why your personal data is collected, stored and used. If you have any questions about how Spribe handles your personal data, or if you wish to exercise any of the rights described in this Policy, you can reach us at support@spribe.click at any time.

This Privacy Policy applies to all visitors to spribe.click, all registered players, and all individuals who interact with Spribe's customer support team — regardless of whether those interactions take place in English or Urdu. By using the Spribe platform, you acknowledge that you have read and understood this Policy.

Spribe collects several categories of personal data in connection with your use of the platform. Below is a detailed breakdown of each category:

Identity Data includes your full legal name, date of birth, CNIC number, and any other identity documentation you provide during the KYC (Know Your Customer) verification process. This data is mandatory for account holders who request withdrawals or reach applicable transaction thresholds.

Contact Data includes your Pakistani mobile number, email address, and any alternative contact information you provide. Your mobile number is the primary identifier used for account creation and two-factor security on the Spribe platform.

Financial Data includes records of your deposits, withdrawals, bets placed, game outcomes, and account balance history. This data is maintained for regulatory compliance, dispute resolution and responsible gaming monitoring. Actual payment credentials — such as your full Easypaisa wallet number or card details — are handled exclusively by regulated payment processors and are not stored on Spribe's own servers.

Technical Data includes your IP address, device information, operating system, browser type and version, mobile network details, and session identifiers. This data is collected automatically and is used for platform security, fraud detection and performance monitoring.

Usage and Behavioural Data includes the games you play, the frequency and duration of your sessions, the features you interact with, your cash-out patterns in games like Aviator, and your response to promotions. This data informs responsible gaming monitoring — for example, identifying unusual patterns that may indicate problematic gambling behaviour.

Spribe collects personal data through the following channels:

• Direct registration: When you create a Spribe account, you provide your name, mobile number, date of birth and other registration details directly through the sign-up form.
• KYC documentation: When you submit identity verification documents — such as a photo of your CNIC — in response to a Spribe verification request, that information is added to your account record.
• Deposits and withdrawals: Each financial transaction generates a record that includes amount, method, timestamp and reference number. This record is linked to your account automatically.
• Platform activity: Your interactions with the platform — games launched, bets placed, sessions started and ended — are logged automatically as part of the platform's operating infrastructure.
• Customer support interactions: When you contact Spribe's support team by email or live chat, the content of that interaction is recorded and associated with your account for quality, training and dispute-resolution purposes.
• Cookies and similar technologies: When you visit spribe.click, cookies and similar tracking technologies collect technical and usage data. See Section 8 for full details of Spribe's cookie practices.

Spribe uses personal data only for specific, documented purposes. We do not use your data for purposes beyond those listed here, and we do not sell your data to third parties for their own marketing or profiling use. The purposes for which Spribe processes personal data are:

• Account management: Creating and maintaining your player account, verifying your identity and age, and administering your settings and preferences.
• Payment processing: Facilitating PKR deposits via Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT and Visa/Mastercard; processing withdrawals back to the same methods; maintaining financial records for each transaction.
• Regulatory compliance: Meeting anti-money-laundering (AML) requirements, KYC obligations, and the reporting and record-keeping requirements of Spribe's operating licence.
• Fraud and security: Detecting and preventing fraudulent accounts, duplicate registrations, bot activity, and any other conduct that breaches Spribe's Terms and Conditions.
• Responsible gaming: Monitoring player activity to identify patterns consistent with problematic gambling behaviour; applying self-exclusion, deposit limits and other responsible gaming tools when requested; proactively intervening when usage patterns suggest a player may need support.
• Customer support: Responding to your queries, resolving disputes, handling complaints, and providing assistance in both English and Urdu.
• Platform improvement: Analysing usage patterns to improve game performance, interface design, payment flows and the overall player experience — using aggregated, anonymised data wherever possible.
• Communications: Sending account-related notifications such as deposit confirmations, withdrawal updates and security alerts. Marketing communications are sent only to players who have opted in and may be opted out of at any time.

Spribe processes your personal data under the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing required to create and operate your account, process payments, and deliver the gaming services you have signed up for. Without this processing, Spribe cannot provide the services described on the platform.
• Legal obligation: Processing required to comply with Spribe's regulatory obligations — including AML checks, KYC verification, transaction record-keeping, and responsible gaming requirements mandated by the terms of Spribe's operating licence.
• Legitimate interests: Processing carried out for fraud prevention, platform security, and analytical purposes — where those interests do not override your fundamental privacy rights.
• Consent: Processing for optional communications such as marketing emails and promotional notifications, where you have explicitly opted in. You may withdraw this consent at any time by contacting support@spribe.click or using the unsubscribe option in any marketing message.

Spribe does not sell your personal data. We share data only with carefully selected third parties where sharing is necessary for the operation of the platform or required by law. The categories of recipients are:

• Payment processors: Regulated third-party companies that handle the technical processing of deposits and withdrawals via Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT and card networks. These processors receive only the information necessary to execute the specific transaction.
• Identity verification providers: Services that assist with KYC document verification, age checking and sanctions screening. These providers process identity documents under strict contractual data protection obligations.
• Fraud detection services: Technology providers whose services help Spribe identify and prevent fraudulent account activity, duplicate registrations and automated bot behaviour.
• Customer support platforms: Technology used to manage and deliver support via live chat and email, including the storage of support interaction records.
• Regulatory and law enforcement bodies: Where required by Spribe's operating licence or applicable law, Spribe may be required to disclose data to regulatory bodies, law enforcement agencies or courts. Spribe will always seek to notify the relevant player of such a disclosure unless prohibited from doing so by law.

All third parties with whom Spribe shares personal data are required to handle that data in accordance with applicable data protection law and Spribe's contractual requirements. Spribe does not permit third-party service providers to use your data for their own marketing or commercial purposes.

Spribe takes the security of financial data especially seriously, given that the platform handles real Pakistani Rupee transactions for hundreds of thousands of players. The following specific protections apply to payment data:

• Full payment credentials — including your complete Easypaisa or JazzCash wallet number, full card number, card expiry and CVV — are processed exclusively by regulated third-party payment processors and are never stored on Spribe's own servers.
• What Spribe does retain is a transaction reference, the payment method type, the last four digits of a card number (where applicable), the transaction amount in PKR, timestamp, and outcome. This is the minimum necessary to support dispute resolution and regulatory record-keeping.
• All payment transactions are transmitted over SSL/TLS encrypted connections. This applies to every deposit and withdrawal request made through the platform regardless of the payment method used.
• Spribe's systems are designed so that support staff can see transaction records for the purpose of resolving queries, but cannot access raw payment credentials. This access restriction is enforced at the system level, not merely by policy.

Spribe uses cookies and similar technologies — such as local storage and session identifiers — when you visit spribe.click. These technologies serve specific functional and operational purposes. They are not used to build advertising profiles for sale to third parties.

The categories of cookies used by Spribe are:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in between pages, security tokens, and cookies that store your game settings. Without these, the platform cannot operate. These cookies cannot be disabled.
• Functional cookies: Remember your preferences — such as your preferred language, the last game you played, and your device settings. Disabling these will not prevent you from using the platform, but may mean your preferences are not remembered between sessions.
• Analytics cookies: Collect anonymised or pseudonymised data about how players use the platform — which pages are visited, how long sessions last, and how players navigate between sections. This data helps Spribe improve the platform. No personally identifying data is included in analytics reports.
• Security cookies: Used to detect and prevent fraudulent or automated behaviour, such as bot accounts. These are part of the platform's fraud prevention infrastructure.

You can manage cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will prevent you from logging into your Spribe account. For more information on managing cookies on Pakistani mobile browsers, refer to your browser's help documentation.

Spribe implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures include:

• SSL/TLS encryption: All data transmitted between your device and spribe.click is encrypted in transit using industry-standard TLS protocols. The padlock icon in your browser address bar confirms this when you visit the platform.
• Access controls: Personal data is accessible to Spribe staff only on a need-to-know basis. Access is controlled by role-based permissions and authenticated login. No staff member has access to raw payment credentials.
• Server security: Spribe's servers are maintained in secure data centre environments with physical and network security controls aligned with industry standards.
• Fraud monitoring: Automated systems continuously monitor platform activity for patterns consistent with account compromise, unauthorised access, or fraudulent use. Alerts trigger manual review and, where appropriate, account security measures.
• Incident response: Spribe maintains a data breach response procedure. In the event of a confirmed breach affecting personal data, affected players will be notified as required by applicable law and Spribe's regulatory obligations.

No online system is completely immune to security risks. Spribe takes its security obligations seriously and invests in keeping its infrastructure current with evolving best practices. You also have a role to play: use a strong, unique password for your Spribe account and never share your login credentials with anyone else.

Spribe retains personal data for as long as necessary to fulfil the purposes described in this Policy and to meet its regulatory obligations. Specific retention periods are governed by the following principles:

• Active accounts: Personal data is retained for the full duration of your relationship with Spribe and for a period after account closure as required by Spribe's licensing authority and applicable financial regulations. This period is typically five years from the date of account closure for transaction records and KYC documentation.
• Self-excluded accounts: Where an account has been closed due to self-exclusion, core identity data is retained to prevent the player from opening a new account during the exclusion period. This data is held securely and access is restricted to the minimum staff required to enforce the exclusion.
• Support interactions: Customer support records are retained for a period sufficient to handle any related dispute or complaint — typically two years from the date of the interaction, unless the record is relevant to an ongoing investigation or claim.
• Technical and usage data: Aggregated and anonymised usage data that cannot be linked back to an individual player may be retained indefinitely for platform improvement purposes. This data contains no personally identifying information.

When personal data is no longer required, it is securely deleted or anonymised. Spribe does not retain data "just in case" — retention periods are set based on documented regulatory requirements and operational necessity.

You have the following rights in relation to the personal data Spribe holds about you. These rights apply to all players, regardless of how long they have been using the platform or the size of their account:

To exercise any of these rights, send your request to support@spribe.click with the subject line "Data Rights Request". Include your registered mobile number and a brief description of your request. Spribe will acknowledge your request within 3 working days and respond fully within 30 days. Requests are processed free of charge for standard submissions.

Spribe's platform is strictly intended for adults aged 18 years and over. Spribe does not knowingly collect personal data from individuals under the age of 18. Age verification is carried out as part of the account registration process and, where appropriate, through formal KYC documentation requests.

If Spribe becomes aware that personal data has been collected from a minor — whether through an age misrepresentation at registration, a report from a parent or guardian, or detection through verification processes — the following steps will be taken immediately: the account will be suspended pending investigation; if confirmed, the account will be permanently closed; any remaining balance will be handled in accordance with applicable regulatory guidance; and all personal data associated with the minor will be deleted except where retention is required by law.

If you are a parent or guardian and you believe your child has created an account on spribe.click, contact Spribe immediately at support@spribe.click. All such reports are treated as high priority and handled with full confidentiality.

Spribe may update this Privacy Policy from time to time to reflect changes in the platform, its data practices, or applicable legal requirements. When changes are made, the updated Policy will be published on this page with a revised effective date at the top. Significant changes that materially affect how Spribe processes personal data — particularly changes that expand the categories of data collected or introduce new purposes for processing — will be communicated to active players via email or in-platform notification before they take effect.

For minor or technical updates, the change will simply be reflected in the updated Policy on this page without a separate notification. We encourage all players to review this page periodically to stay informed about how Spribe handles personal data. Continued use of the platform after a Policy update constitutes acceptance of the revised terms.

If you have any questions about this Privacy Policy, want to exercise your data rights, have a concern about how Spribe has handled your personal data, or want to report a privacy issue, Spribe's support team is available 24 hours a day, seven days a week. Support is available in both English and Urdu — please use whichever is more comfortable for you.

• Email: support@spribe.click — include "Privacy" in your subject line for fastest routing
• Live Chat: Available within your Spribe account once logged in

Spribe is committed to resolving privacy concerns directly with players wherever possible. If after contacting Spribe you remain unsatisfied with the response, you may have the right to escalate your complaint to the relevant data protection authority under the laws applicable in your jurisdiction. Details of the applicable escalation path can be provided by the Spribe support team on request.

Spribe treats all privacy-related enquiries confidentially. Your complaint or query will be handled by a senior support team member with data protection responsibility and will not be shared with parties beyond those necessary to investigate and resolve your concern.