pak99 Privacy Policy

This Privacy Policy ("Policy") describes how pak99 ("pak99", "we", "us", "our") collects, processes, stores, and protects personal data relating to users ("you", "your") of the pak99 website located at https://pak99.org and all associated services, mobile interfaces, and subdomains (collectively, the "Platform"). By registering an account or continuing to use the pak99 Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy applies to all users of pak99, including players from Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, Peshawar, Multan, Quetta, and all other cities and regions of Pakistan. It applies equally to all gaming products available on pak99 — the sportsbook (cricket, PSL, UFC, football), casino games, slots, live dealer tables, fishing games, and crash titles.

1. Data Controller

The data controller responsible for your personal data processed through the pak99 Platform is the licensed operating entity of pak99, operating under an internationally recognised gaming licence. For all privacy-related enquiries, you may contact our designated privacy point of contact at [email protected] (plain text — not a link). We aim to respond to all substantive privacy enquiries within 30 calendar days of receipt.

2. Data We Collect

pak99 collects personal data in the following categories, only to the extent necessary to operate the Platform and comply with applicable legal and regulatory obligations:

• Registration Data: Full legal name, date of birth (to verify 21+ age requirement), Pakistani mobile number, email address, username, and password (stored in hashed form).
• Identity Verification (KYC) Data: Government-issued ID (CNIC, passport), proof of address, and in some cases a selfie photograph. This is collected to satisfy anti-money laundering (AML) and Know Your Customer (KYC) obligations under our licensing requirements.
• Financial Data: Bank account details (HBL, UBL, Meezan Bank), JazzCash wallet number, EasyPaisa wallet number, Raast ID, debit/credit card details (processed via PCI-DSS-compliant payment processors — pak99 does not store full card numbers), and USDT wallet addresses.
• Transaction Data: Records of all deposits, withdrawals, bonus claims, bet placements, game sessions, and account balance movements.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, time zone, session timestamps, and referral source. This data is collected automatically when you access the Platform.
• Behavioural Data: Pages visited, games played, bet history, wagering patterns, session frequency and duration, and feature interactions. This data is used for responsible gaming monitoring and platform improvement.
• Communications Data: Records of your interactions with pak99 customer support, including live chat transcripts, email correspondence, and support ticket content.
• Marketing Preferences: Your opted-in preferences for promotional communications, including SMS alerts for PSL odds and bonus notifications via JazzCash-linked mobile number.

pak99 does not knowingly collect sensitive personal data beyond the categories listed above. We do not collect racial or ethnic origin data, political opinions, religious beliefs, biometric data (other than identity photographs for KYC purposes), or health data as part of ordinary account operations.

3. How We Use Your Data

pak99 uses the personal data it collects for the following purposes:

• Account Management: Creating, maintaining, and securing your pak99 account, including password reset, two-factor authentication, and session management.
• Service Delivery: Processing bets on cricket, PSL, and other sportsbook markets; providing access to casino games and slots; processing deposits and withdrawals via JazzCash, EasyPaisa, and bank transfer.
• Identity Verification & Fraud Prevention: Verifying that you are who you say you are, confirming the 21+ age requirement, preventing fraudulent transactions, and detecting suspicious wagering patterns that may indicate match-fixing or money laundering.
• Legal & Regulatory Compliance: Fulfilling AML obligations, responding to lawful requests from regulatory or law enforcement authorities, and maintaining transaction records as required by our licensing authority.
• Responsible Gaming: Monitoring betting behaviour to identify signs of problem gambling, enforcing deposit and loss limits, processing self-exclusion requests, and communicating responsible gaming information to at-risk players.
• Customer Support: Responding to your queries, resolving disputes, processing complaints, and improving support quality through communication review.
• Marketing & Promotions: Sending you promotional communications about PSL betting offers, casino bonuses, reload promotions, and platform news — only where you have provided explicit consent or where permitted by applicable law. You may opt out at any time.
• Platform Analytics & Improvement: Analysing usage patterns, testing new features, optimising the Platform interface, and improving performance for Pakistani users on mobile networks.

4. Legal Basis for Processing

pak99 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil the contract between you and pak99 — account creation, bet settlement, payment processing, and support.
• Legal Obligation: Processing required to comply with applicable laws and licensing conditions, including AML/KYC obligations and regulatory reporting.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and certain cookie categories, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing & Third Parties

pak99 does not sell or rent your personal data to third parties for their own commercial purposes. We may share your data with carefully selected third parties only in the following circumstances:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, 1LINK/IBFT, Raast, and card network processors. These parties receive only the financial data necessary to process your transaction and are bound by their own data protection commitments.
• Game Content Providers: Third-party game studios and RNG providers whose games are hosted on the pak99 Platform. Game providers may receive anonymised session data necessary to operate the game but do not receive your identity or financial information.
• KYC & AML Verification Partners: Third-party identity verification services used to confirm CNIC authenticity and conduct AML screening. These partners operate under strict contractual data protection obligations.
• Technology & Hosting Providers: Cloud infrastructure, CDN, cybersecurity, and analytics vendors who process data on our behalf as data processors. All such vendors are contractually bound to process data only as instructed by pak99 and to maintain appropriate security standards.
• Regulatory & Law Enforcement Authorities: Where pak99 is required by law, court order, or licensing authority instruction to disclose personal data.
• Corporate Transactions: In the event of a merger, acquisition, or business transfer, user data may be transferred to a successor entity subject to equivalent privacy protections.

6. Data Retention

pak99 retains personal data for as long as your account remains active and for a period thereafter as required by our licensing obligations and applicable law. Specifically:

• Account and transaction records are retained for a minimum of five (5) years from the date of the last transaction or account closure, whichever is later, in line with standard AML regulatory requirements.
• KYC identity documents are retained for a minimum of five (5) years from the closure of your account.
• Support communications are retained for two (2) years from the date of the interaction.
• Marketing preference data is retained until you withdraw consent or close your account.
• Technical and log data is typically retained for twelve (12) months from collection for security and fraud analysis purposes.

After the applicable retention period expires, data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

7. Security Measures

pak99 implements a layered approach to data security designed to protect your personal information against unauthorised access, disclosure, alteration, and destruction. Our technical and organisational security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and pak99 servers.
• AES-256 encryption for sensitive data at rest, including financial information and KYC documents.
• Bcrypt or equivalent one-way hashing for all stored account passwords.
• Multi-factor authentication (MFA) available for all pak99 accounts — strongly recommended for all users.
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis.
• Regular penetration testing and security audits conducted by independent third-party security specialists.
• Real-time fraud detection and anomaly monitoring systems operating on all transaction and login activity.
• Incident response procedures with defined timelines for breach notification to affected users and relevant authorities where required by law.

Notwithstanding these measures, no system is entirely impenetrable. pak99 strongly recommends that users employ a strong, unique password for their pak99 account, enable MFA, and not share their login credentials with any third party.

8. Cookies & Tracking Technologies

pak99 uses cookies and similar tracking technologies (web beacons, local storage) to operate and improve the Platform. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the Platform to function. These enable login session management, security tokens, and bet slip functionality. They cannot be disabled without disrupting core Platform features.
• Performance & Analytics Cookies: Used to understand how users navigate the Platform — which pages are visited most, how long sessions last, and where users encounter errors. Data is aggregated and anonymised where possible.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method display, and game lobby filters.
• Marketing Cookies: Used only where you have provided explicit consent, to measure the effectiveness of promotional campaigns — for example, tracking whether a PSL betting bonus notification led to a qualifying deposit.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using core pak99 features, though some preference-based functionality may be limited.

9. Your Rights

As a user of pak99, you have the following rights in relation to your personal data:

• Right of Access: You may request a copy of all personal data pak99 holds about you in a structured, commonly used format.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes at any time.
• Right to Portability: You may request that data you have provided to pak99 be transmitted to you or to another controller in a machine-readable format, where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time. Withdrawal does not affect the lawfulness of prior processing.

To exercise any of the above rights, contact pak99 at [email protected]. We will respond to verified requests within 30 calendar days. In some cases we may need to verify your identity before processing a request to protect against fraudulent access attempts.

10. Minors — Strict 21+ Age Policy

pak99 does not knowingly collect personal data from persons under the age of 21. If we discover that data has been collected from a minor, it will be promptly and permanently deleted from our systems. Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms.

11. International Data Transfers

pak99 operates under an international gaming licence and may use service providers located outside Pakistan. Where personal data is transferred to countries that may not provide the same level of data protection as local law, pak99 ensures that appropriate safeguards are in place — such as standard contractual clauses, data processing agreements, or other recognised transfer mechanisms — to ensure your data remains protected to a consistent standard regardless of where it is processed.

12. Changes to This Policy

pak99 reserves the right to update this Privacy Policy at any time. When we make material changes, we will notify registered users via the email address associated with their pak99 account and will update the "Last Updated" date at the top of this page. The updated Policy will be effective from the date it is posted on the Platform. Continued use of the pak99 Platform after the effective date constitutes acceptance of the revised Policy. We encourage you to review this page periodically to stay informed of how pak99 protects your data.

13. Contact Us

For any questions, concerns, or requests related to this Privacy Policy or the personal data pak99 holds about you, please contact our privacy team using the details below. All communications are handled in English and Urdu.