Privacy Policy

This Privacy Policy ("Policy") describes how 92pkrk ("the Platform", "we", "us", "our") collects, uses, stores, discloses and otherwise processes personal data relating to users ("you", "User") of the website available at https://92pkrk.cam and all associated services (collectively, the "Services").

92pkrk is an English-language online betting information and gaming platform serving Pakistani users. We take the privacy and security of your personal data seriously. This Policy is drafted to give you a clear, plain-English account of our data practices so you can make informed decisions about how you interact with our platform.

By registering an account or using the Services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Services.

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, identification document numbers, IP address and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 92pkrk.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a documented instruction.
• "Consent" means a freely given, specific, informed and unambiguous indication by which you agree to the processing of your Personal Data for a stated purpose.
• "KYC Data" means identity and verification documents submitted in connection with Know Your Customer procedures, including government-issued identification, proof of address and source-of-funds documentation.
• "Cookies" means small text files placed on your device by the platform to enable certain functionality and analytics.

92pkrk acts as the Data Controller in respect of Personal Data collected through the platform. As Data Controller, we are responsible for determining why and how your Personal Data is processed, and for ensuring that processing is carried out lawfully, fairly and transparently.

92pkrk does not hold a Pakistani gambling license and is not regulated by any Pakistani governmental authority, including the Pakistan Telecommunication Authority (PTA) or the State Bank of Pakistan. Our data processing obligations are governed by the laws of the jurisdiction in which the platform is licensed and operated.

For all privacy-related enquiries, including the exercise of data subject rights, please contact us using the details set out in Section 16 of this Policy.

We collect Personal Data from you directly, automatically through your use of the platform, and in certain cases from third-party sources. The categories of data we collect are set out below.

We process your Personal Data only where we have a valid lawful basis for doing so. The lawful bases we rely upon are as follows:

• Contractual Necessity: Processing required to fulfil our obligations to you under the Terms and Conditions, including operating your account, processing deposits and withdrawals, and settling bets.
• Legal Obligation: Processing required to comply with applicable legal requirements, including anti-money laundering (AML) obligations, KYC verification, fraud prevention and regulatory reporting.
• Legitimate Interests: Processing carried out for our legitimate business interests, including platform security, fraud detection, responsible gambling monitoring, and service improvement — provided such interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Where we rely on legitimate interests as our lawful basis, we conduct and document a balancing assessment to confirm that our interests do not override your fundamental rights.

92pkrk uses your Personal Data for the following purposes:

• Account Management: Creating, maintaining and administering your user account, including login authentication and account preference settings.
• Identity Verification: Conducting KYC checks to verify your identity, age and eligibility to use the platform in accordance with our Terms and applicable regulatory requirements.
• Transaction Processing: Processing deposits, withdrawals and bet settlements denominated in PKR, and maintaining accurate financial records.
• Customer Support: Responding to your enquiries, resolving complaints, and maintaining records of communications for quality and compliance purposes.
• Fraud and Security: Detecting, investigating and preventing fraudulent activity, money laundering, account takeovers and other security threats.
• Responsible Gambling: Monitoring betting patterns to identify potential problem gambling behaviour, implementing limits and exclusions, and fulfilling our duty of care obligations.
• Platform Improvement: Analysing usage data to improve the functionality, performance and user experience of the platform.
• Legal Compliance: Fulfilling obligations under applicable law, including responding to lawful requests from regulatory or law enforcement authorities.
• Marketing Communications: Sending promotional offers, bonus notifications and platform updates where you have opted in to receive such communications. You may opt out at any time via your account settings or by contacting support.

We do not use your Personal Data for automated decision-making that produces significant legal effects without human oversight, except where required by applicable law or where you have provided explicit consent.

92pkrk uses cookies and similar tracking technologies to operate the platform and improve your experience. When you first visit the platform, you will be presented with a cookie consent banner allowing you to accept or decline non-essential cookies.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies, authentication tokens and security cookies. They cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences, such as language settings, preferred sports categories (e.g., cricket, PSL or football) and layout choices, to provide a more personalised experience.
• Analytics Cookies: Collect anonymised data about how users interact with the platform — pages visited, time spent and navigation paths — to help us improve platform performance. Used only with your consent.
• Marketing Cookies: Track your activity to help us deliver relevant promotional content. Used only with your explicit consent and subject to withdrawal at any time.

You may manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies will impair your ability to use the platform. Disabling other categories will not affect your ability to access your account or place bets.

We do not sell, rent or trade your Personal Data to any third party for their own marketing purposes. We may share your data in the following limited circumstances:

• Service Providers: We engage third-party processors including payment processors, KYC verification providers, cloud hosting providers, analytics platforms and customer support tools. These processors are contractually bound to process data only on our documented instructions and to maintain appropriate security standards.
• Regulatory & Legal Authorities: We may disclose Personal Data to regulatory bodies, law enforcement agencies or courts where required by applicable law, court order or regulatory direction. We will notify you of any such disclosure where permitted to do so.
• Fraud Prevention & AML: We may share data with industry fraud prevention networks and financial intelligence units as required for anti-money laundering compliance.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.
• With Your Consent: We may share data with third parties not listed above where you have provided explicit, informed consent to that specific disclosure.

All third-party recipients of Personal Data are required to handle that data in accordance with applicable data protection law and their contractual obligations to 92pkrk.

As an online platform serving users in Pakistan and operating infrastructure in multiple jurisdictions, Personal Data collected through the platform may be transferred to and processed in countries outside Pakistan. Some of these countries may not have data protection laws equivalent to those in your home jurisdiction.

Where Personal Data is transferred internationally, we take appropriate steps to ensure adequate protection is maintained, including:

• Transferring only to countries recognised as providing adequate data protection under applicable law;
• Using standard contractual clauses or equivalent data transfer mechanisms with recipient processors;
• Applying additional technical and organisational safeguards where the risk profile of a transfer warrants it.

By using the platform, you acknowledge that your Personal Data may be transferred and processed internationally as described in this section. If you have concerns about international data transfers, you may contact us at the address in Section 16.

We retain your Personal Data for as long as is necessary to fulfil the purposes outlined in this Policy, subject to any longer retention period required by applicable law or regulatory obligation.

The following general retention periods apply:

• Account Data: Retained for the duration of your account's active status, plus a period of up to five (5) years following account closure, in accordance with standard AML and audit retention requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of account closure or the last transaction, as required by applicable AML legislation.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction for accounting, audit and legal compliance purposes.
• Customer Support Communications: Retained for up to three (3) years from the date of resolution, unless the subject matter requires longer retention for legal reasons.
• Marketing Consent Records: Retained for the duration of your subscription to marketing communications, plus a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be attributed to an identifiable individual.

92pkrk implements appropriate technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction or disclosure. Our security programme includes:

• TLS/SSL encryption for all data transmitted between your device and our platform;
• Encryption at rest for stored personal and financial data;
• Role-based access controls limiting employee access to Personal Data on a strict need-to-know basis;
• Regular security assessments and vulnerability testing of platform infrastructure;
• Incident response procedures for the detection, investigation and notification of data security breaches;
• Staff training on data protection and information security practices.

In the event of a personal data breach that is likely to result in a risk to your rights, we will notify affected users without undue delay and in accordance with our obligations under applicable law.

Subject to applicable law and certain exceptions, you have the following rights in relation to your Personal Data held by 92pkrk:

To exercise any of these rights, please contact our privacy team using the details in Section 16. We will respond to all valid requests within a reasonable period and without undue delay, subject to identity verification and applicable legal exceptions.

Please note that certain rights may be limited or overridden where processing is required for compliance with legal obligations, including AML and KYC retention requirements. We will explain any such limitation clearly when responding to your request.

The 92pkrk platform is strictly intended for adults aged 18 and above, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect, process or retain Personal Data from individuals below the minimum eligible age.

If we become aware that Personal Data has been collected from an underage individual, we will take immediate steps to delete that data, close the associated account and, where applicable, return any funds deposited through the most recently used verified payment method.

If you are a parent or guardian and believe that a minor in your care has registered an account or provided Personal Data to 92pkrk, please contact us immediately at [email protected] so that we can investigate and act promptly.

The 92pkrk platform may contain references to third-party services, payment providers or content for contextual purposes. Where any such references include navigable links, those destinations operate under their own independent privacy policies and data practices, which 92pkrk does not control.

We are not responsible for the privacy practices, content or security of any third-party website or service. We recommend that you review the privacy policy of any third-party platform before providing Personal Data to it.

The mention of payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah is for contextual familiarity only and does not constitute an endorsement by those providers of gambling activity, nor does it imply any data-sharing relationship between those providers and 92pkrk beyond what is strictly necessary for payment processing.

92pkrk reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform functionality. When material changes are made, we will publish the updated Policy on this page with a revised effective date.

Where changes are significant, we will provide advance notice to registered users via email or on-platform notification prior to the changes taking effect. Your continued use of the platform following publication of an updated Policy constitutes your acceptance of the revised terms.

We encourage you to review this Policy periodically. The date at the top of this page indicates when it was last updated.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how 92pkrk handles your Personal Data, please contact our privacy team using the details below.

All privacy-related communications should be directed to:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the in-platform support widget

When submitting a data rights request, please include your registered username, a clear description of your request, and any relevant account reference numbers. We may need to verify your identity before processing the request to protect against unauthorised access to Personal Data.

We aim to acknowledge all privacy enquiries within two business days and to resolve them fully within a reasonable period. For complaints that cannot be resolved informally, escalation routes through the applicable regulatory framework will be communicated in our response.