spribe Privacy Policy

01 Who We Are — The Data Controller

For the purposes of this Privacy Policy, the data controller responsible for your personal data is spribe — the internationally licensed online gaming and sports betting platform operating at spribe.cam and serving players in Pakistan and other permitted territories.

spribe holds an active international gaming licence. A condition of that licence is that spribe maintains documented, auditable data protection and privacy practices in line with international standards. The licensing authority has the right to inspect spribe's data handling practices as part of its regulatory oversight function.

For all privacy-related queries, data subject requests, or complaints, you may contact spribe's data protection team by emailing [email protected] with the subject line "Privacy / Data Request." Our team will acknowledge all privacy requests within 5 business days and provide a substantive response within the timeframes specified in Section 10 of this Policy.

02 Personal Data We Collect

spribe collects the following categories of personal data from players and prospective players:

2.1 Registration Data

When you create a spribe account, we collect the information you provide in the registration form, including:

• Full legal name as it appears on your government-issued identity document.
• Date of birth (used for mandatory age verification — you must be 21 or older).
• Pakistani mobile number, which serves as your primary account identifier and login credential.
• City of residence (e.g. Karachi, Lahore, Islamabad, Faisalabad, or other).
• Email address, where provided during registration or subsequently added to your account.

2.2 KYC Verification Data

As required by spribe's international gaming licence, players must complete Know Your Customer (KYC) identity and age verification before their first withdrawal is processed. KYC data collected includes:

• Copies of government-issued identity documents — such as CNIC (Computerised National Identity Card), passport, or driving licence.
• Proof of address documents where required for enhanced verification.
• Selfie or live identity check images used to verify that the identity document belongs to the account holder.
• Proof of payment method ownership (e.g. screenshot of JazzCash or EasyPaisa wallet showing the registered name) where required for withdrawal processing.

2.3 Transaction Data

spribe records all financial transactions associated with your account, including:

• Deposit amounts, dates, times, and payment method references (note: full payment credentials are not stored by spribe — see Section 9).
• Withdrawal requests, amounts, approved or rejected status, and processing timestamps.
• Bonus credits and wagering activity against bonus balances.

2.4 Gaming & Betting Activity Data

spribe maintains a full record of gaming and betting activity conducted through your account. This includes game titles played, stake amounts, outcomes, session durations, and sports betting selections. This data is retained as required by spribe's licensing authority for audit and responsible gaming compliance purposes.

2.5 Device & Technical Data

When you access spribe, our platform automatically collects certain technical information, including your IP address, device type and operating system, browser type and version, and the pages of the spribe platform you visit and the duration of those visits. This data is used for security monitoring, fraud prevention, and platform performance optimisation.

2.6 Communications Data

Records of all communications between you and spribe — including live chat transcripts, support emails, and complaint correspondence — are retained by spribe for quality assurance, dispute resolution, and regulatory compliance purposes.

03 How We Collect Your Data

spribe collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact support, or participate in a promotion.
• Automatically: Through cookies and similar tracking technologies when you visit spribe.cam — as described in Section 7 of this Policy.
• From payment processors: Transaction confirmation data from JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank payment gateways, confirming that a transaction was completed and its reference details.
• From identity verification providers: Results of automated document and identity checks performed by third-party KYC verification service providers engaged by spribe.
• From fraud prevention systems: Risk signals and device fingerprinting data from fraud detection tools used by spribe to identify and prevent unauthorised account access, payment fraud, and bonus abuse.

04 Why We Use Your Personal Data

spribe uses the personal data we collect for the following specific purposes:

05 Legal Basis for Processing

spribe processes your personal data on the following legal bases:

• Contract performance: Processing necessary to create and manage your spribe account, execute your deposits and withdrawals, and deliver the gaming services you have requested.
• Legal obligation: Processing required by spribe's international gaming licence — including mandatory KYC age verification, responsible gaming monitoring, transaction records, and regulatory reporting to the licensing authority.
• Legitimate interests: Processing for fraud prevention, platform security, abuse detection, and anonymised analytics used to improve the platform — where these interests do not override your privacy rights.
• Consent: Processing for marketing communications, which requires your explicit opt-in. You may withdraw consent at any time.

06 Who We Share Your Data With

spribe does not sell, rent, or trade your personal data. We share your data only in the following strictly defined circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank payment gateway providers receive only the transaction details required to complete your deposit or withdrawal. They do not receive your gaming activity data or full KYC documentation.
• Identity verification providers: Third-party KYC service providers process your identity documents and selfie data solely for the purpose of completing age and identity verification as required by spribe's licence. These providers are contractually bound by data protection obligations.
• Gaming software providers: Game providers whose titles are featured on spribe may receive anonymised session identifiers necessary to deliver game content. They do not receive your name, mobile number, or payment details.
• Fraud prevention services: Fraud detection and risk management service providers may process device and behavioural data for the purpose of identifying and preventing account fraud and payment fraud. All such providers operate under data processing agreements with spribe.
• spribe's licensing authority: spribe is required by its international gaming licence to provide transaction records, KYC data, and gaming activity reports to the licensing authority as part of regulatory compliance. This is a legal obligation that cannot be waived.
• Law enforcement agencies: spribe will disclose personal data to law enforcement or judicial authorities where required by a valid legal process — such as a court order or regulatory investigation. spribe does not voluntarily share data with law enforcement beyond what is legally required.
• Professional advisers: Lawyers, auditors, and compliance consultants engaged by spribe may access personal data as necessary in the course of providing professional services, subject to strict confidentiality obligations.

07 Cookies & Tracking Technologies

spribe uses cookies and similar tracking technologies on spribe.cam. Cookies are small text files stored on your device when you visit the platform. spribe uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function correctly — including session management, login state, and security token validation. These cookies cannot be disabled without preventing the platform from operating.
• Functional cookies: Store your preferences — such as language settings and game display preferences — to personalise your spribe experience across sessions.
• Analytics cookies: Collect anonymised data about how players navigate the spribe platform — page visit durations, navigation paths, and feature usage. This data is used to improve platform performance and user experience. No personally identifiable information is included in analytics data.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorised access attempts, and automated bot activity on the spribe platform.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair the functionality of the spribe platform and may prevent you from logging in or completing transactions. Disabling functional or analytics cookies will not affect core platform operation.

08 Data Retention

spribe retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to longer retention periods required by spribe's gaming licence and applicable law.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that makes re-identification impossible. Anonymised aggregate data derived from your gaming activity may be retained indefinitely for platform analytics and improvement purposes.

09 Data Security

spribe implements a multi-layered approach to data security designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• Transport encryption: All data transmitted between your device and spribe.cam is encrypted using TLS 1.2 or higher with 256-bit encryption. The presence of HTTPS and a valid SSL certificate on all spribe pages confirms this protection is active during your session.
• Payment data isolation: Your JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank payment credentials are processed exclusively by the respective certified payment gateways. spribe stores only transaction reference numbers — never full payment account details.
• KYC document security: Identity documents submitted for KYC verification are stored in encrypted form on access-controlled servers. Access is restricted to spribe's compliance team on a need-to-know basis and is audit-logged.
• Access controls: spribe staff access to player personal data is role-based and governed by the principle of least privilege. Administrative access to production systems is logged, monitored, and subject to periodic security review.
• Penetration testing: spribe's platform undergoes regular security testing by independent security professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident response: In the event of a personal data breach that poses a risk to players, spribe will notify affected players and the relevant licensing authority within the timeframes required by applicable regulations.

10 Your Data Rights

As a spribe player, you have the following rights with respect to your personal data. These rights can be exercised by contacting spribe's support team:

11 Children & Minors

spribe's platform is strictly restricted to individuals aged 21 years and above. spribe does not knowingly collect, process, or retain personal data from persons under the age of 21. Registration by persons under 21 constitutes a breach of spribe's Terms and Conditions and is a violation of the conditions of spribe's international gaming licence.

If spribe becomes aware — through KYC verification, parental notification, or any other means — that personal data belonging to a person under the age of 21 has been collected, spribe will take immediate steps to close the relevant account, void any associated gaming activity, and securely delete the personal data of the underage individual, subject only to any mandatory retention obligations imposed by the licensing authority in relation to the incident.

12 Changes to This Privacy Policy

spribe reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, updates to our gaming licence conditions, or changes in applicable law. The "Last Updated" date at the top of this Policy indicates when the most recent revision was made.

Where changes to this Policy are material — meaning they affect how spribe uses your personal data in a way that is significantly different from what was previously described — spribe will notify you by SMS to your registered mobile number or by a prominent notice displayed on the spribe platform upon your next login, with a minimum of 14 days' advance notice before the changes take effect.

Continued use of the spribe platform after the effective date of a revised Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any change to this Policy, you have the right to close your spribe account before the revised Policy takes effect, by contacting spribe support.

13 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how spribe has handled your personal data, please contact us through any of the following channels:

If you are not satisfied with spribe's handling of a privacy complaint after following the process above, you have the right to escalate the matter to spribe's licensing authority for independent review. Details of the relevant licensing authority are available from spribe's compliance team on request.

spribe is committed to resolving all privacy concerns fairly and transparently, in keeping with both the letter and the spirit of our licensing obligations. Players in Karachi, Lahore, Islamabad, Faisalabad, and across Pakistan are entitled to the same standard of data protection, and our support team is trained to handle data queries in a clear and responsive manner.