Privacy Policy — pakr92

This Privacy Policy (hereinafter referred to as the "Policy") is issued by pakr92 (hereinafter "the Platform", "we", "us" or "our") and applies to all personal data collected from individuals (hereinafter "you", "the User" or "the Data Subject") who access, register on, or otherwise interact with the website available at pakr92.cam and all associated services (collectively, the "Services").

We are committed to protecting your privacy and processing your personal data responsibly, lawfully and transparently. This Policy describes what personal data we collect, why we collect it, how we use and protect it, how long we retain it and what rights you have with respect to your personal data.

This Policy may be updated from time to time. The effective date and version number displayed in the page header indicate the currently operative version. We will notify registered Users of material changes via the registered email address and/or a prominent notice within the Platform prior to changes taking effect.

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

pakr92 collects personal data across several categories, depending on how you interact with the Platform. The following table provides an overview of the categories of data we may collect:

We collect personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, respond to a survey or interact with any feature of the Platform.
• Automatically: Through cookies, web beacons, server logs and similar tracking technologies when you access or browse the Platform, as described in Section 10.
• From third-party verification providers: Identity and document verification services used to support KYC processes may provide verified data back to the Platform.
• From payment processors: Transaction confirmation and fraud-screening data returned by payment processing partners. Note that payment method names referenced on the Platform (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are provided for contextual familiarity only and do not indicate that those providers share data with or endorse the Platform.
• From analytics and fraud-detection services: Aggregated and pseudonymised data provided by platform analytics and anti-fraud technology partners to support security and performance operations.

pakr92 processes your personal data only for the purposes set out in this Policy and for no other purpose without your prior consent or another lawful basis. The primary purposes for which we process your personal data are as follows:

• Account Operation: Creating and managing your account, authenticating your identity on login, processing transactions and providing access to the Services.
• KYC & Compliance: Verifying your identity and age, meeting anti-money-laundering (AML) obligations, maintaining required regulatory records and reporting to licensing authorities where obligated.
• Payment Processing: Facilitating deposits and withdrawals, maintaining transaction records, detecting and preventing fraudulent transactions.
• Responsible Gambling: Monitoring player activity to identify patterns consistent with problem gambling, implementing responsible gambling tools (deposit limits, self-exclusion), and proactively supporting player wellbeing.
• Customer Support: Responding to queries, resolving disputes, and maintaining records of communications for quality assurance.
• Security & Fraud Prevention: Detecting and preventing unauthorised access, fraudulent accounts, collusion, money laundering and other prohibited activity.
• Platform Improvement: Analysing aggregated usage data to improve performance, user experience and content relevance.
• Marketing Communications: Sending promotional communications to Users who have opted in to receive them. You may withdraw consent at any time by updating your communication preferences in account settings.

Where applicable data protection law requires us to identify a legal basis for each processing activity, we rely on the following:

• Contractual Necessity: Processing required to perform our contractual obligations to you under the Terms & Conditions — including account operation, payment processing and provision of Services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC, AML obligations and record-keeping requirements imposed by the Platform's license jurisdiction.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, security, platform improvement and responsible gambling monitoring, where such interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given consent. You have the right to withdraw consent at any time without detriment.

pakr92 does not sell your personal data to third parties. We do not share personal data with third parties for their own independent marketing purposes without your explicit consent. We may share personal data in the following circumstances:

• Service Providers (Data Processors): We engage carefully vetted third-party service providers who process personal data on our behalf under binding contractual agreements. These include payment processors, KYC/identity verification providers, cloud hosting services, analytics providers and fraud-detection services.
• Licensing Authorities: Where required by the Platform's license terms, we may be obligated to share specific data with the relevant licensing authority for regulatory audit and compliance purposes.
• Law Enforcement and Regulatory Bodies: Where we are legally compelled to do so by a court order, subpoena, regulatory direction or equivalent legal process, or where disclosure is necessary to prevent serious harm, detect or prosecute crime, or comply with AML reporting obligations.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of the Platform's assets, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• With Your Consent: For any other purpose not listed above, only with your explicit, informed and revocable consent.

We retain your personal data for no longer than is necessary for the purposes for which it was collected, subject to the following considerations:

• Active Account Data: Retained for the duration of your account relationship with the Platform plus a reasonable administrative period following closure.
• KYC and Financial Records: Retained for a minimum period as required by the Platform's licensing obligations and applicable AML regulations — typically a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Support and Communications Records: Retained for a period sufficient to resolve any disputes and meet quality assurance needs, typically up to three (3) years from the date of the communication.
• Technical and Log Data: Typically retained for up to twelve (12) months for security and fraud-detection purposes, unless retention for a longer period is required for an ongoing investigation.
• Marketing Consent Records: Retained for the duration of the consent period and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

pakr92 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. Our security measures include:

• Encryption in Transit: All data transmitted between your browser and the Platform is encrypted using TLS/SSL protocols.
• Encryption at Rest: Sensitive personal data stored on our systems is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Personal data is accessible only to authorised personnel with a legitimate operational need. Access is controlled via role-based permissions and multi-factor authentication.
• Two-Factor Authentication: Users are encouraged and able to enable 2FA on their accounts to provide an additional layer of protection against unauthorised access.
• Regular Security Testing: Our systems and infrastructure are subject to regular security assessments and penetration testing.
• Incident Response: We maintain a documented data breach response procedure. In the event of a breach affecting your personal data in a manner that creates a risk to your rights, we will notify you without undue delay in accordance with applicable obligations.

The Platform uses cookies and similar tracking technologies to operate and improve the Services. Cookies are small files placed on your device when you visit the Platform. They serve the following functions:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during a session. These cookies cannot be disabled without preventing core functionality.
• Functional Cookies: Enable personalisation features such as language preference, currency display and responsible gambling tool settings. These can be disabled, but doing so may impair certain features.
• Analytics Cookies: Collect aggregated and pseudonymised data about how Users interact with the Platform — page views, session duration, navigation paths — to help us improve performance. Placement of analytics cookies is subject to your consent where required.
• Security Cookies: Used for fraud detection, bot mitigation and session integrity verification.

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling strictly necessary cookies will prevent you from using the Platform effectively. For Users accessing the Platform from Karachi, Lahore, Islamabad or elsewhere in Pakistan, the same cookie policy applies regardless of geographic location.

Depending on the data protection laws applicable in your jurisdiction and the Platform's license jurisdiction, you may have some or all of the following rights in respect of your personal data:

To exercise any of these rights, please contact our support team via live chat or at the email address listed in Section 16. We will respond to verified requests within the timeframe required by applicable law (typically 30 days). We may require proof of identity before actioning a data rights request.

pakr92 serves users across Pakistan, including those based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. This section provides specific information relevant to Pakistani residents.

Pakistan's primary data protection legislation is the Personal Data Protection Bill (currently in legislative process as of the effective date of this Policy). We acknowledge Pakistan's evolving data protection landscape and are committed to applying data handling standards consistent with internationally recognised data protection principles regardless of local legislative status.

References on this Platform to local payment methods — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are provided for contextual familiarity. These references do not indicate data-sharing arrangements with those payment providers, nor do they imply that those providers endorse, affiliate with or support gambling transactions on this Platform.

Where data is transferred outside of Pakistan for processing or storage (for example, to servers in the license jurisdiction or to global service providers), we ensure that appropriate safeguards are in place, including contractual protections with receiving parties.

The Platform is strictly restricted to adults 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.

If we become aware that personal data has been submitted by or on behalf of a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor may have submitted personal data through the Platform, please contact us immediately via the channels described in Section 16.

Age verification is a mandatory step in our KYC process. Access to certain features, including all deposit and withdrawal functionality, is restricted until age and identity have been satisfactorily verified.

The Platform may reference third-party services, technologies or content providers in an informational capacity. This Privacy Policy applies solely to data processed by pakr92 as Data Controller. We are not responsible for the privacy practices of any third-party service, technology provider or external resource.

Game content and functionality may be delivered by third-party game studios or live dealer providers, who may collect certain technical data (such as device type and session activity) in connection with their game delivery services. Such processing is governed by the respective provider's own privacy practices, over which pakr92 has no control beyond contractual obligations.

We review and update this Privacy Policy periodically to reflect changes in our data processing activities, applicable law, regulatory guidance or best practice. When we make material changes to this Policy, we will:

• Update the version number and effective date displayed in the page header;
• Notify registered Users via their registered email address where the changes are material and affect rights or processing activities in a significant way;
• Display a notice within the Platform for a period following the update.

We encourage you to review this Policy periodically. Your continued use of the Platform after the effective date of an updated version of this Policy constitutes your acknowledgement of the revised terms. Where changes require fresh consent under applicable law, we will seek that consent before proceeding with the affected processing.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact us through any of the following channels:

• Live Chat: Available 24/7 via the support chat widget within the Platform. This is the fastest channel for data-related queries and rights requests.
• Support Email: [email protected] — displayed as plain text only in compliance with platform policy; this address is not a clickable link.
• Data Rights Requests: When submitting a data rights request (access, erasure, rectification, portability or objection), please include "Data Rights Request" in the subject line of your email and provide sufficient information for us to verify your identity.

We aim to acknowledge all privacy-related enquiries within two (2) business days and to provide a substantive response within thirty (30) days of receipt of a verified request, in accordance with applicable law.