pak92 Privacy Policy

1. Data Controller

pak92, operated at pak92.bio under an international gaming licence, is the data controller responsible for the personal data of Players who use the pak92 platform. As data controller, pak92 determines the purposes and means by which your personal data is processed. References in this Privacy Policy to "pak92," "we," "us," or "our" refer to the pak92 platform and its operating entity.

Questions, data access requests, and complaints regarding data protection at pak92 may be directed to our support team at [email protected]. We aim to acknowledge all data-related correspondence within 48 hours of receipt.

2. Scope of This Privacy Policy

This Privacy Policy applies to all personal data collected and processed by pak92 in connection with your use of the pak92 website (pak92.bio), any sub-domains or mobile-optimised versions of the site, and any communications channels through which you interact with pak92, including email, live chat support, and any messaging platforms used for customer service.

This policy applies to all registered Players, prospective registrants who have initiated but not completed registration, former Players whose accounts have been closed, and any individual who contacts pak92's support team regardless of whether they hold an active account.

This policy does not apply to third-party websites, payment processors, or services that may be linked from pak92. Those third parties operate under their own independent privacy policies, and pak92 is not responsible for their data handling practices. We encourage you to review the privacy policy of any third-party service before sharing your personal information with them.

3. Personal Data We Collect

3.1 Registration Data

When you create a pak92 account, we collect the following personal information:

• Full legal name — as it appears on your Pakistani CNIC
• Date of birth — used to verify you are 21 years of age or older
• Pakistani mobile number — used for account authentication, OTP delivery, and communication
• Email address — used for account correspondence, promotional communications (if opted in), and account recovery
• CNIC number — collected as part of the KYC verification process required before withdrawals
• Residential address — collected at KYC stage for identity verification and regulatory compliance
• Username and encrypted password — for account access; passwords are stored in irreversibly hashed form and are never accessible to pak92 staff

3.2 KYC Verification Documents

Before processing withdrawal requests, pak92 requires identity verification. The following documents are collected and stored as part of the KYC process:

• Photograph of both sides of your Pakistani CNIC
• Selfie photograph of you holding your CNIC, taken at the time of verification
• Proof of address (utility bill, bank statement, or equivalent), where requested
• Proof of source of funds documentation, where requested for enhanced due diligence

3.3 Payment and Financial Data

pak92 collects transaction records associated with your account. We do not store complete JazzCash or EasyPaisa account details on our own servers — payment authentication is handled through our licensed payment processor partners. We do retain:

• Transaction amounts, dates, and types (deposit, withdrawal, wager, win)
• Payment method identifiers (e.g., masked JazzCash number, bank name)
• Account balance history for regulatory and audit purposes

3.4 Gameplay and Behavioural Data

pak92 records gameplay activity for purposes including game integrity, responsible gaming monitoring, and product improvement:

• Game sessions, game types, wager amounts, outcomes, and win/loss records
• Session start and end times, duration, and in-session betting patterns
• Sports markets accessed, selections placed, and live betting activity
• Promotional offers viewed, accepted, and wagering completion status

3.5 Technical and Device Data

When you access pak92, we automatically collect certain technical data through standard server logging and analytics:

• IP address — used for fraud detection, geographic access controls, and security logging
• Device type, operating system version, and browser type
• Pages visited, time on page, and navigation path through the platform
• Connection type (Wi-Fi or mobile data) and network carrier information
• Referral source — how you arrived at pak92 (search engine, direct, referral link)

3.6 Communications Data

If you contact pak92 via email, live chat, or any other support channel, we collect and retain records of those communications — including the content of your messages, the date and time of contact, and the outcome of any support interaction. These records are used for quality assurance, dispute resolution, and compliance purposes.

4. Legal Basis for Processing

pak92 processes your personal data under the following legal bases:

5. Purposes of Data Processing

pak92 processes your personal data for the following specific purposes. We do not process your data for any purpose not listed here without first providing notice and, where required, obtaining consent:

• Account Registration and Management: Creating and maintaining your pak92 account, authenticating your identity on login, and managing your account settings and preferences.
• KYC and Identity Verification: Verifying that you are who you say you are, that you meet the 21+ age requirement, and that your account complies with our licensing obligations before withdrawals are released.
• Payment Processing: Facilitating PKR deposits via JazzCash, EasyPaisa, bank transfers, and other accepted payment methods, and processing withdrawal requests to your nominated account.
• Fraud and AML Prevention: Monitoring transactions, login activity, and gameplay patterns for indicators of fraud, money laundering, structuring, or other prohibited conduct, and acting on those indicators in accordance with our regulatory obligations.
• Responsible Gaming: Monitoring your gameplay patterns for indicators of problem gambling, enforcing self-imposed deposit and loss limits, facilitating cool-off and self-exclusion requests, and contacting you if our systems identify concerning patterns in your gaming activity.
• Customer Support: Responding to your queries, complaints, and requests, and maintaining records of those interactions for quality assurance and dispute resolution.
• Platform Improvement: Analysing aggregated, anonymised usage data to understand how Players use pak92 and to prioritise development improvements that enhance the player experience.
• Marketing: Sending you promotional offers, bonus notifications, and product updates via email or SMS, subject to your marketing consent preferences. You may unsubscribe at any time.
• Legal and Regulatory Compliance: Meeting our obligations under our international gaming licence, responding to lawful requests from regulatory authorities, and maintaining records required by applicable law.

6. Data Sharing with Third Parties

pak92 does not sell, rent, or trade your personal data with third parties. We share personal data only in the following defined circumstances and only with recipients who are bound by appropriate data protection obligations:

6.1 Payment Processors

To facilitate PKR deposits and withdrawals, pak92 shares necessary financial and identity data with our licensed payment processor partners, including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and Raast. Each payment partner operates under its own regulated financial infrastructure with applicable data protection obligations. Data shared is limited to what is required to complete the specific transaction.

6.2 KYC and Identity Verification Providers

pak92 uses specialist third-party KYC verification service providers to authenticate CNIC documents and conduct biometric selfie matching. These providers process your identity documents solely for the purpose of verification and are contractually prohibited from using your data for any other purpose.

6.3 Fraud Detection and Security Services

pak92 employs third-party fraud detection and cybersecurity services that may process technical data — including IP addresses, device fingerprints, and behavioural patterns — for the purpose of identifying fraudulent or suspicious activity. These services do not receive your personal identification data beyond what is technically necessary for risk scoring.

6.4 Regulatory Authorities and Law Enforcement

pak92 may disclose your personal data to our gaming licence regulator, financial intelligence units, or law enforcement agencies where we are legally required to do so or where disclosure is necessary to prevent, detect, or investigate suspected criminal activity. We will notify you of any such disclosure where we are legally permitted to do so.

6.5 Professional Advisors

pak92 may share personal data with legal counsel, auditors, and financial advisors where necessary for the conduct of legal proceedings, regulatory audits, or professional advisory engagements. Such parties are bound by professional confidentiality obligations.

7. International Data Transfers

pak92 operates as an internationally licensed platform. Some of the data processing activities described in this policy may involve the transfer of your personal data to servers or service providers located outside Pakistan. Where such transfers occur, pak92 takes the following measures to ensure your data remains protected to a standard equivalent to that described in this policy:

• Transfers are made only to countries or entities that provide adequate data protection standards, or where adequate contractual protections have been put in place between pak92 and the recipient entity.
• All third-party service providers who receive personal data from pak92 are required to sign data processing agreements that bind them to use the data only for the specified purpose and to maintain appropriate security standards.
• pak92's primary data infrastructure uses encrypted cloud hosting services with data centres in jurisdictions that implement industry-standard data protection frameworks.

If you would like further information about the specific safeguards applied to any international transfer of your data, please contact us at [email protected].

8. Data Retention Periods

pak92 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to longer retention periods required by applicable law. The following retention schedule applies:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with pak92's data destruction procedures. Where anonymisation is applied, the resulting data may be retained indefinitely as it no longer constitutes personal data.

9. Security Measures

pak92 implements technical and organisational security measures appropriate to the sensitivity of the personal data it processes. Key measures include:

• Transport Layer Security: All data transmitted between your browser or mobile device and pak92's servers is encrypted using TLS 1.2 or higher (256-bit SSL). The padlock icon in your browser confirms this encrypted connection is active.
• Data Encryption at Rest: Personal data stored on pak92's servers is encrypted using AES-256 encryption. Encryption keys are managed using a dedicated key management service with role-based access controls.
• Access Controls: Access to personal data within pak92's operational team is strictly role-based. No member of pak92 staff can access personal data outside the scope of their specific operational function. All data access is logged with a full audit trail.
• Password Security: Player passwords are stored using irreversible cryptographic hashing. pak92 cannot recover your password — only reset it. If you receive any communication claiming to be from pak92 and requesting your password, treat it as a phishing attempt.
• Two-Factor Authentication: pak92 supports optional two-factor authentication via SMS OTP, which we encourage all Players to activate. For accounts with large balances, 2FA is strongly recommended as a critical second layer of protection against unauthorised access.
• Penetration Testing: pak92's platform undergoes regular third-party security testing. Identified vulnerabilities are remediated within defined timelines based on severity classification.
• Incident Response: pak92 maintains a documented security incident response procedure. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay and take immediate remedial action.

10. Cookies & Tracking Technologies

pak92 uses cookies and similar tracking technologies to operate the platform, improve performance, and — where you have consented — personalise your experience. A cookie is a small text file stored on your device by your browser when you visit a website.

10.1 Types of Cookies Used

10.2 Managing Cookies

You may control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, and delete cookies from individual sites. Note that disabling certain cookies may impact your ability to use some features of pak92, particularly functional cookies that remember your preferences.

11. Marketing Communications

pak92 may send you promotional communications — including bonus offers, new game announcements, PSL betting promotions, and VIP programme updates — via email and/or SMS. We will only send you marketing communications if you have actively opted in to receive them at the time of registration or subsequently through your account settings.

You may withdraw your marketing consent at any time by:

• Clicking the "unsubscribe" link included in any marketing email from pak92
• Updating your communication preferences in the Notifications section of your pak92 account settings
• Contacting pak92 support at [email protected] and requesting removal from marketing lists

Withdrawal of marketing consent does not affect transactional communications — pak92 will still send you messages necessary for the operation of your account, such as deposit confirmations, withdrawal processing updates, security alerts, and regulatory notices. These communications are not marketing and cannot be opted out of while your account is active.

pak92 does not share your contact details with third-party marketing partners. Any promotional communications you receive will be from pak92 directly.

12. Your Data Subject Rights

pak92 respects your rights in relation to your personal data. The following rights are available to all pak92 Players. To exercise any of these rights, contact us at [email protected]. We will acknowledge your request within 48 hours and fulfil it within 30 days, subject to legal limitations.

13. Minors & Age Verification

pak92 strictly prohibits the use of its platform by any person under the age of 21 years. pak92 does not knowingly collect, store, or process personal data of minors. The collection of date of birth and CNIC data during registration and KYC verification is conducted specifically to confirm that all Players meet the 21+ requirement before they are permitted to wager or withdraw.

If pak92 discovers or is notified that it has collected personal data from an individual who was under 21 at the time of collection, the following steps will be taken immediately: the account will be suspended, no further data will be processed, all deposited funds will be returned to the source, the account will be permanently closed, and all associated personal data will be securely deleted to the extent permitted by applicable law.

If you are a parent or guardian and you believe your child may have created an account on pak92, please contact us immediately at [email protected]. We treat all such reports as urgent and respond within 2 hours during operating hours.

14. Changes to This Privacy Policy

pak92 may update this Privacy Policy from time to time to reflect changes in our data processing practices, new legal requirements, or improvements to the Platform. The date of the most recent revision is displayed at the top of this page.

Where changes to this policy are material — meaning they affect your rights or the way we use your personal data in a significant way — pak92 will notify registered Players by email to the address on their account and/or by a prominent notice on the Platform at least 14 days before the changes take effect.

We encourage you to review this policy periodically. Continued use of pak92 after the effective date of any revision constitutes your acknowledgement of the updated policy. If you do not agree with material changes to this policy, you may request closure of your account in accordance with Section 13 of the Terms and Conditions before the effective date of the change.

15. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a complaint about how pak92 has handled your personal data, please contact us using the details below.

Complaints

If you are not satisfied with pak92's response to a data protection complaint, you have the right to escalate your complaint to the relevant supervisory authority under the laws applicable to pak92's international gaming licence. Details of the applicable supervisory authority are available upon request from our support team.

pak92 takes all data protection complaints seriously. We will investigate your complaint fully, communicate our findings to you, and take any remedial action that is appropriate and proportionate to the circumstances. We will not treat you less favourably as a result of having raised a data protection concern.