pak111 Privacy Policy — How We Handle Your Data

pak111 is the operator of the online gaming platform accessible at pak111.biz (the "Platform"). For the purposes of this Privacy Policy, pak111 acts as the data controller in respect of the personal information collected from users of the Platform.

pak111 is committed to protecting the privacy and personal data of all users, with particular attention to the security expectations of Pakistani players who trust us with their personal and financial information. This policy governs all data processing activities conducted by pak111 in connection with the operation of the Platform.

If you have any questions about how pak111 handles your data, you may contact our Data Protection team at any time using the contact details provided in Section 14 of this policy.

pak111 collects the following categories of personal data from users of the Platform:

pak111 collects personal data through the following channels:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Technical Collection: Data collected automatically when you access the Platform, including IP address, device identifiers, browser fingerprint, and session activity logs collected via server logs and cookies.
• Payment Processors: Transaction confirmations and payment reference data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency network providers in connection with your deposits and withdrawals.
• Identity Verification Partners: Confirmation data received from third-party KYC service providers who verify the authenticity of identity documents submitted by users.
• Third-Party Analytics: Aggregated, anonymised usage statistics collected via analytics tools used to improve Platform performance and user experience.
• Fraud Prevention Services: Risk signals and device reputation data from fraud detection partners used to identify and prevent account abuse.

pak111 uses your personal data for the following specific purposes:

• Account Creation & Management: To register your pak111 account, verify your identity, and manage your account settings, wallet, and preferences.
• Service Delivery: To process bets, credit winnings, manage bonus allocations, and deliver the full range of gaming products available on the Platform — including cricket betting, PSL odds, live casino, and slots.
• Payment Processing: To facilitate PKR deposits and withdrawals via your chosen payment method (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or crypto) and maintain accurate transaction records.
• KYC & Age Verification: To verify that all users are aged 21 or above and meet eligibility requirements, in compliance with responsible gaming obligations and our gaming licence conditions.
• Fraud Detection & Security: To identify and prevent fraudulent activity, money laundering, bonus abuse, and unauthorised account access.
• Legal & Regulatory Compliance: To fulfil obligations under applicable anti-money-laundering (AML) regulations, gaming licence requirements, and tax reporting where required.
• Customer Support: To respond to your queries, process complaints, and resolve disputes raised via live chat or email.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling behaviour and to enforce self-exclusion and limit-setting tools selected by users.
• Platform Improvement: To analyse aggregated usage data and improve the performance, features, and user experience of the pak111 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent to receive such communications, which you may withdraw at any time.

pak111 processes your personal data on the following legal bases, depending on the specific processing activity:

pak111 does not sell, rent, or trade your personal data to any third party for commercial purposes. However, pak111 may share your data with the following categories of recipient where strictly necessary:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency processors — only the data necessary to process your transaction is shared with the relevant provider.
• KYC & Identity Verification Providers: Third-party services that assist pak111 in verifying the identity and age of registered users, operating under strict data processing agreements.
• Fraud Prevention Partners: Risk intelligence services that help pak111 identify fraudulent accounts and betting patterns.
• Regulatory & Law Enforcement Authorities: Where required by law, applicable regulation, court order, or licensing authority mandate, pak111 may disclose personal data to relevant governmental or regulatory bodies.
• Legal & Professional Advisers: Lawyers, auditors, and compliance consultants engaged by pak111 who are bound by professional confidentiality obligations.
• IT Infrastructure & Hosting Providers: Cloud hosting and technical infrastructure partners who process data on pak111's behalf under data processing agreements that restrict their use of your data solely to providing the contracted service.

pak111 uses cookies and similar tracking technologies on the Platform to enhance user experience, maintain session security, and gather anonymised analytics data. The following cookie categories are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies, CSRF protection tokens, and login persistence cookies. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and game history for continuity of experience across sessions.
• Analytics Cookies: Collect anonymised data about how users interact with the Platform — pages visited, session duration, and feature usage — to help pak111 improve the Platform. Data collected is aggregated and not linked to individual identities.
• Security Cookies: Used by fraud prevention systems to detect unusual device behaviour, identify automated bots, and prevent account takeover attacks.

You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will impair your ability to use the Platform. pak111 does not use third-party advertising or retargeting cookies.

pak111 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to any individual.

As a user of the pak111 Platform, you hold the following rights in respect of your personal data. pak111 will respond to all valid rights requests within 30 calendar days of receipt.

To exercise any of the above rights, contact pak111's Data Protection team via live chat or by emailing [email protected] with the subject line "Data Rights Request". pak111 may require identity verification before processing your request.

pak111 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• Encryption at Rest: All stored personal and financial data is encrypted using AES-256 encryption. Database backups are also encrypted before storage.
• Encryption in Transit: All data transmitted between your device and the pak111 Platform is protected using TLS 1.3 (Transport Layer Security). Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Access Controls: Access to personal data within pak111's systems is restricted on a strict need-to-know basis. Staff access is governed by role-based access controls, multi-factor authentication, and comprehensive access logging.
• Penetration Testing: The pak111 Platform undergoes regular independent security testing to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: pak111 maintains a documented data breach response procedure. In the event of a breach that poses a risk to user rights, affected users will be notified promptly and in accordance with applicable obligations.
• Password Security: User passwords are stored exclusively as salted cryptographic hashes — plain-text passwords are never stored anywhere in pak111's systems.

pak111 operates a strict 21+ age policy. The Platform is not intended for, and must not be used by, any person under the age of 21. pak111 does not knowingly collect personal data from individuals under 21 years of age.

pak111 employs age verification technology and manual KYC review processes to prevent underage registration. Where it is discovered that a user has registered while under 21, pak111 will:

• Immediately close the account;
• Void all bets placed while the account was active;
• Return any deposits made, net of any winnings already withdrawn;
• Permanently delete or anonymise all personal data collected from the underage user, except where retention is required for regulatory reporting purposes.

If you are aware of a minor who has accessed or registered on the pak111 Platform, please contact our Support team immediately via live chat or email.

pak111 is an internationally operated platform and your personal data may be transferred to, stored in, or processed in countries other than Pakistan. This may occur in connection with the use of cloud hosting infrastructure, KYC verification providers, or fraud prevention services located outside Pakistan.

Where personal data is transferred internationally, pak111 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Privacy Policy. Such safeguards may include:

• Standard contractual clauses or data processing agreements with receiving parties;
• Transfer to jurisdictions that maintain internationally recognised data protection standards;
• Binding corporate rules applicable to pak111's group companies.

By using the pak111 Platform, you acknowledge and consent to the international transfer of your personal data where such transfer is necessary for the delivery of services described in this Privacy Policy.

pak111 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. The updated policy will be published on this page with a revised effective date.

Where changes are material — for example, where we introduce a new category of data processing or a new third-party data sharing arrangement — pak111 will provide advance notice to registered users via the email address associated with their account or via a prominent notice on the Platform.

Continued use of the pak111 Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with an updated policy, you may request account closure by contacting pak111 Support.

For any questions, concerns, or requests relating to this Privacy Policy or pak111's handling of your personal data, please contact our Data Protection team using the details below: