pak97 Privacy Policy

1. Data Controller

1.1 For the purposes of this Privacy Policy, pak97 is the data controller responsible for your personal information. When this policy refers to "pak97", "we", "us", or "our", it means the pak97 platform operating at pak97.app.

1.2 If you have any questions or concerns about how pak97 processes your personal data, or wish to exercise any of your data rights set out in Section 8, you may contact our Data Protection team at: [email protected]

2. Categories of Personal Data We Collect

2.1 pak97 collects the following categories of personal data from players and platform visitors:

2.2 pak97 does not intentionally collect sensitive personal data (such as health information, political opinions, or biometric data) except where specifically required by law or regulation in the context of responsible gaming assessments.

3. How We Collect Personal Data

3.1 pak97 collects personal data through the following means:

• Direct submission — Information you provide when registering your pak97 account, completing KYC verification, submitting a deposit or withdrawal request, or contacting customer support
• Automated collection — Technical and usage data collected automatically when you access and use the pak97 platform, including via cookies and server logs (see Section 9)
• Third-party sources — Identity verification data from CNIC verification services; payment data from JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah in connection with your transactions; and fraud prevention data from licensed screening providers
• Game providers — Game session data and technical logs from pak97's licensed game providers including Evolution Gaming, Ezugi, JILI, PG Soft, Pragmatic Play, Fa Chai, and CQ9

4. Purposes and Legal Bases for Processing

4.1 pak97 processes your personal data for the following purposes, each supported by a lawful basis:

• Account registration and management — Necessary for the performance of our contract with you as a pak97 player
• Identity and age verification (KYC) — Legal obligation under applicable anti-money laundering and responsible gaming requirements; necessary to comply with our 18+ age restriction
• Processing deposits and withdrawals — Necessary for the performance of our contract; required to process PKR transactions via JazzCash, Easypaisa, and bank channels
• Fraud detection and prevention — Legitimate interest of pak97 in protecting the platform, other players, and its business from fraudulent, abusive, or criminal conduct
• Responsible gaming monitoring — Legal obligation and legitimate interest in identifying and supporting players who may be experiencing gambling-related harm
• Customer support — Necessary for the performance of our contract and our legitimate interest in providing quality service
• Platform security and integrity — Legitimate interest in maintaining a secure and fair gaming environment
• Legal and regulatory compliance — Legal obligation to comply with applicable laws, including AML regulations, data retention requirements, and court or regulatory orders
• Marketing communications — Based on your consent, which you may withdraw at any time
• Platform improvement and analytics — Legitimate interest in understanding how players use pak97 to improve the Service

5. Data Sharing and Third-Party Disclosure

5.1 pak97 does not sell your personal data to third parties. We share personal data only in the following limited circumstances:

• Game providers — Licensed game and technology providers (Evolution Gaming, Ezugi, JILI, PG Soft, Pragmatic Play, Fa Chai, CQ9) receive limited session and account data necessary to operate the games you play on pak97
• Payment processors — JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah receive financial data necessary to process your PKR deposits and withdrawals
• Identity verification providers — KYC and age verification service providers may process your identity documents to verify your eligibility as a pak97 player
• Fraud prevention services — Licensed fraud screening and AML compliance providers process certain account and transaction data to detect and prevent financial crime
• Legal and regulatory authorities — pak97 will disclose personal data to law enforcement, regulatory bodies, or courts when required to do so by applicable law, regulation, or binding court order
• Business successors — In the event of a merger, acquisition, or sale of pak97's assets, personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy

5.2 All third parties with whom pak97 shares personal data are required to maintain appropriate security measures and to use the data only for the specified purpose. pak97 does not permit third parties to use your personal data for their own marketing purposes.

6. Data Retention

6.1 pak97 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements.

6.2 As a general guide:

• Account and identity data — Retained for the duration of your account plus a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations
• Transaction data — Retained for a minimum of five (5) years following each transaction
• Communications data — Support correspondence retained for a minimum of two (2) years
• Technical and usage data — Typically retained for twelve (12) to twenty-four (24) months for security and analytical purposes

6.3 Where personal data is no longer required for any retention purpose, pak97 will securely delete or anonymise it.

7. Data Security

7.1 pak97 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and pak97's servers
• Encrypted storage of sensitive personal data and financial information at rest
• Role-based access controls limiting staff access to personal data to those with a legitimate need
• Regular security audits and vulnerability assessments of the pak97 platform
• Two-factor authentication (OTP) for player account access on new or unrecognised devices
• Automatic session timeouts on inactive pak97 sessions

7.2 While pak97 takes all reasonable precautions to protect your data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your pak97 login credentials. If you suspect unauthorised access to your account, contact pak97 support immediately at [email protected].

8. Your Data Rights

8.1 As a pak97 player, you have the following rights in relation to your personal data:

8.2 To exercise any of the above rights, please contact pak97 at [email protected]. pak97 will respond to verifiable requests within 30 days. We may need to verify your identity before processing a data rights request.

8.3 Please note that certain rights may be limited where pak97 is required to retain data to comply with legal obligations — for example, AML record-keeping requirements that mandate retention of transaction data for a minimum period regardless of a deletion request.

9. Cookies and Tracking Technologies

9.1 pak97 uses cookies and similar tracking technologies to operate the platform, remember your session, and improve your experience. The following types of cookies may be set when you use pak97:

• Strictly necessary cookies — Required for the pak97 platform to function. These include session cookies that maintain your login state, CSRF protection tokens, and security identifiers. These cookies cannot be disabled.
• Functional cookies — Enable personalisation features such as remembering your game preferences, language settings, and whether you have previously dismissed certain notifications.
• Analytics cookies — Collect anonymised or pseudonymised data about how players use pak97 — which pages are visited, how long sessions last, and which features are most used. This data is used to improve the platform experience.
• Security cookies — Support fraud detection and security functions, including device fingerprinting to identify suspicious login behaviour.

9.2 You can manage or delete cookies via your browser settings. Disabling strictly necessary cookies will impair the functionality of the pak97 platform, including the ability to log in and maintain your session.

10. Payment Data and Financial Privacy

10.1 pak97 takes the privacy of your financial data particularly seriously. When you make a PKR deposit or request a withdrawal via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, or Bank Alfalah, the relevant transaction data is processed by pak97 and shared with the relevant payment provider solely to complete the transaction.

10.2 pak97 does not store full bank account passwords or payment provider PINs. Payment credentials are handled by the respective payment providers through their own secure systems. pak97 records transaction metadata — amounts, timestamps, payment method type, and masked account identifiers — for cashier management and AML compliance purposes.

10.3 All financial transactions on pak97 are conducted in Pakistani Rupees (PKR). No foreign currency conversion data involving your identity is shared with currency exchanges or brokers.

11. Minors and Age-Restricted Services

11.1 18+ pak97 is strictly an adults-only platform. We do not knowingly collect personal data from persons under 18 years of age. If pak97 discovers or has reason to believe that a minor has registered an account or provided personal data, we will take immediate steps to close the account, delete the associated data, and return any funds deposited.

11.2 If you are a parent or guardian and believe your child has accessed or registered on pak97, please contact us immediately at [email protected] so we can take appropriate action.

12. International Data Transfers

12.1 pak97 and some of its third-party service providers (including game providers and technical infrastructure providers) may process personal data in countries outside Pakistan. Where personal data is transferred internationally, pak97 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under applicable data protection law.

12.2 These safeguards may include: standard contractual clauses, data processing agreements with binding data protection obligations, or transfers to jurisdictions recognised as providing adequate data protection standards.

13. Changes to This Privacy Policy

13.1 pak97 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. The date of the most recent revision is always displayed at the top of this page.

13.2 Where changes are material, pak97 will notify players via the email address or mobile number registered to their account prior to the changes taking effect. Continued use of pak97 following notification of a material policy change constitutes acceptance of the updated Privacy Policy.

14. Contact and Data Rights Requests

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to report a privacy concern, please contact pak97: