Privacy Policy — How 92pakr Handles Your Data

Introduction

92pakr ("Platform", "we", "us", "our") is committed to protecting the personal data of all individuals who access, register on, or otherwise interact with the 92pakr website located at 92pakr.cam. This Privacy Policy ("Policy") describes our data processing practices in connection with the operation of the Platform.

This Policy applies to all personal data collected through the Platform, whether provided directly by you during registration or KYC verification, generated through your use of our Services, or collected automatically through cookies and similar tracking technologies.

By accessing or using 92pakr, you acknowledge that you have read, understood and accepted the practices described in this Policy. Where consent is the legal basis for any specific processing activity, we will request your explicit consent at the appropriate point. If you do not agree with this Policy, please discontinue use of the Platform immediately and contact us to request Account closure and data deletion where applicable.

This Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the Platform. In the event of any inconsistency between this Policy and the Terms & Conditions on a privacy matter, this Policy shall prevail.

Definitions

In this Policy, the following terms shall carry the meanings assigned below:

Personal Data We Collect

We collect Personal Data from you in several ways — directly when you voluntarily provide it, automatically through your interaction with the Platform, and, in limited circumstances, from third parties in connection with KYC and fraud prevention obligations.

3.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, residential address (including city, e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar), email address, mobile number and chosen username and password.
• Identity Verification (KYC) Data: Copies or scans of government-issued identification documents (e.g., Pakistani CNIC — Computerised National Identity Card — passport, or driving licence), proof of address documents (e.g., utility bills, bank statements), and, where required, proof of payment method.
• Financial Data: Payment method details as submitted through the cashier, including mobile wallet identifiers (e.g., Easypaisa or JazzCash account references, referenced for context only) or bank account details for withdrawal processing. Full card numbers are not stored directly by the Platform.
• Communications Data: Records of your correspondence with our support team, including email content, live chat transcripts and any attachments submitted in connection with support requests or complaints.
• Preference Data: Account settings, responsible gambling limit selections, notification preferences and any other choices you make in your Account dashboard.

3.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution and device identifiers.
• Usage Data: Pages visited, time spent on each page, links clicked, search queries entered, game categories browsed, bets placed and their outcomes, session duration and frequency of access.
• Location Data: General geographic location inferred from your IP address. We do not collect precise GPS location data unless you explicitly grant such permission through a mobile application.
• Cookie and Tracking Data: Data collected through cookies, web beacons and similar technologies, as described in Section 9 below.

3.3 Data from Third Parties

• Identity verification and age-check providers who assist in confirming the accuracy of KYC documentation.
• Fraud prevention and AML (Anti-Money Laundering) screening services that cross-reference submitted data against relevant sanctions, watchlists and risk databases.
• Payment service providers who communicate transaction status, refusal codes and settlement confirmations to the Platform.

Legal Basis for Processing

Where applicable data protection law requires that we identify a legal basis for each category of processing, we rely on the following bases:

• Contractual Necessity: Processing required to register your Account, execute bets and gaming transactions, process deposits and withdrawals, and deliver customer support — all necessary to fulfil our contractual obligations to you under the Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable regulatory requirements, including KYC verification, AML obligations, record-keeping requirements and responses to lawful authority requests.
• Legitimate Interests: Processing carried out to detect and prevent fraud, maintain Platform security, improve our Services, conduct analytics, and enforce our Terms — where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for marketing communications, non-essential cookies and any other activity for which we seek your explicit agreement. You may withdraw consent at any time without prejudice to the lawfulness of processing carried out before withdrawal.

How We Use Your Personal Data

92pakr uses the Personal Data we collect for the following purposes, each of which is tied to one or more of the legal bases described in Section 4:

• Account Management: Creating, maintaining, verifying and administering your Account, including identity verification, age confirmation and Account security.
• Service Delivery: Processing bets and casino game sessions, calculating and crediting winnings, applying bonuses in accordance with offer terms, and enabling deposits and withdrawals through supported payment channels.
• Regulatory Compliance: Fulfilling KYC and AML obligations, maintaining transaction records for the legally required retention periods, and responding to lawful requests from regulatory or law enforcement authorities.
• Fraud Prevention and Security: Detecting and investigating suspicious activity, preventing multiple Account registrations, identifying abuse of promotional offers, and protecting the Platform and its users from fraudulent or illegal conduct.
• Responsible Gambling: Monitoring gambling patterns to identify indicators of problem gambling, applying account limits and self-exclusion requests, and communicating responsible gambling information to Users where appropriate.
• Customer Support: Responding to enquiries, complaints and escalations, maintaining records of support interactions and improving support quality.
• Platform Improvement: Analysing usage patterns, testing new features, diagnosing technical issues and optimising the user experience — using aggregated or anonymised data where possible.
• Marketing Communications: Sending promotional emails, bonus notifications and relevant Platform updates to Users who have opted in to receive marketing communications. You may unsubscribe at any time.

Data Sharing & Disclosure

We do not sell, rent or trade your Personal Data. We may share it only in the following circumstances, each subject to appropriate contractual and security safeguards:

• Service Providers and Data Processors: Third-party vendors who process data on our behalf, including payment processors, identity verification services, cloud hosting providers, analytics platforms, fraud prevention tools and customer support software. All processors are bound by data processing agreements that prohibit use of your data for their own purposes.
• Regulatory and Legal Authorities: Where required by law, court order, regulatory direction or as otherwise necessary to protect the legal rights of 92pakr or comply with applicable regulatory obligations. We will inform you of any such disclosure to the extent permitted by law.
• Fraud Prevention and AML Networks: Where there is a reasonable suspicion of fraud, money laundering or other financial crime, we may share relevant information with fraud prevention agencies, AML screening services or relevant financial intelligence bodies.
• Corporate Transactions: In the event of a merger, acquisition, restructuring or sale of assets, your Personal Data may be transferred to the acquiring or successor entity, subject to the same privacy protections as described in this Policy. We will notify you of any such transfer in advance where legally required.
• With Your Consent: We may share your data for any other purpose where you have given your explicit prior consent.

International Data Transfers

92pakr is operated internationally and your Personal Data may be transferred to, stored in, and processed in countries other than Pakistan. These countries may have data protection laws that differ from those in your home jurisdiction.

Where Personal Data is transferred to countries that do not provide a level of data protection equivalent to that required under applicable privacy law, we take appropriate safeguards to ensure the protection of your data. These safeguards may include standard contractual clauses approved by the relevant regulatory authority, data processing agreements with enhanced security obligations, or other legally recognised transfer mechanisms.

By registering on the Platform and providing your Personal Data, you acknowledge that your data may be transferred internationally as described in this section. If you have concerns about international data transfers, please contact us using the details in Section 15.

Data Retention

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce our agreements. The following general retention principles apply:

• Account Data: Retained for the duration of your Account's active status and for a minimum of five years following Account closure or the last transaction, in compliance with AML and regulatory record-keeping requirements applicable to the Platform's licence jurisdiction.
• KYC Documentation: Retained for the period required by applicable AML regulations in the Platform's licence jurisdiction, typically a minimum of five years from the date of the last transaction or Account closure, whichever is later.
• Financial Records: Transaction records, deposit and withdrawal histories are retained for a minimum of five years for regulatory compliance purposes.
• Communications Data: Support correspondence is retained for three years from the date of the last communication, unless a longer period is required due to an ongoing dispute or legal proceeding.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications or request deletion, subject to any legal hold requirements.
• Technical and Usage Data: Log data and analytical data is retained for up to 24 months for security monitoring, fraud detection and Platform optimisation purposes.

When data is no longer required and no legal hold applies, it is securely deleted or irreversibly anonymised. Anonymised and aggregated data may be retained indefinitely for statistical and business intelligence purposes.

Cookies & Tracking Technologies

92pakr uses cookies and similar tracking technologies to operate the Platform, maintain session security, remember your preferences and analyse how users interact with our content. The following categories of cookies are in use:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication tokens, security cookies and load-balancing cookies. They cannot be disabled without disrupting core Platform functionality.
• Functional Cookies: Store your preferences such as language settings, display options and responsible gambling tool configurations. Disabling these may affect your personalised experience.
• Analytical Cookies: Collect anonymised information about how users navigate the Platform — which pages are visited most, where users exit and how long they stay. This data is used to improve Platform design and content.
• Marketing Cookies: Used to track interactions with promotional content and, where you have opted in, to deliver relevant offers. These require your explicit consent and may be withdrawn at any time.

You can manage cookie preferences through your browser settings. Most modern browsers allow you to block, delete or receive alerts about cookies. Note that blocking certain cookie categories may impair your ability to use some Platform features. Our Platform's cookie consent tool (where implemented) allows granular control over non-essential cookies.

Data Security

92pakr implements a range of technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• HTTPS / TLS Encryption: All data transmitted between your browser and the Platform is encrypted using current TLS (Transport Layer Security) protocols. The padlock symbol in your browser's address bar confirms the connection is secure.
• Access Controls: Personal Data is accessible only to authorised personnel who require it to perform their job functions. Access is governed by role-based permissions and regular access reviews.
• Password Security: Passwords are stored in hashed form using industry-standard cryptographic algorithms. We do not store plaintext passwords.
• Two-Factor Authentication (2FA): Where available, 2FA is strongly encouraged for all registered Accounts and mandatory for high-value withdrawal requests above specified thresholds.
• Security Monitoring: The Platform employs continuous security monitoring and logging to detect and respond to potential threats or intrusion attempts.
• Vendor Due Diligence: Third-party data processors are evaluated for security compliance before engagement and are contractually required to maintain appropriate security standards.

Your Rights as a Data Subject

Depending on the data protection law applicable to your situation, you may have some or all of the following rights in relation to your Personal Data held by 92pakr. We will respond to valid rights requests within the timeframe required by applicable law — typically within 30 days of receipt.

To exercise any of the above rights, please contact us using the details provided in Section 15. We may need to verify your identity before processing a rights request. We will not charge a fee for reasonable requests but reserve the right to charge a reasonable administrative fee for manifestly unfounded or excessive requests.

Minors & Age Verification

The 92pakr Platform is strictly for adults. We do not knowingly collect Personal Data from individuals under the age of 18 — or the higher minimum age required by the operator's licence jurisdiction. Age verification is a mandatory component of the registration and KYC process.

If we become aware that we have inadvertently collected Personal Data from a minor, we will take immediate steps to delete that data from our systems and close the associated Account. If you believe that a minor has created an Account on the Platform using false information, please contact us immediately at the address provided in Section 15.

Parents and guardians who are concerned about minors accessing online gambling platforms should consider implementing parental control software and making use of the filtering tools provided by internet service providers. Being 18 years of age does not, by itself, make online gambling lawful in all jurisdictions — Pakistani users must independently verify their local legal obligations.

Third-Party Links & Services

The Platform may reference third-party services, including payment providers and game technology suppliers, in an educational or contextual capacity. Any such references do not constitute endorsement, affiliation or a recommendation to use those services for gambling or any other purpose.

If the Platform contains links to third-party websites (including in the context of responsible gambling resources), those websites operate under their own privacy policies and terms of use, for which 92pakr accepts no responsibility. We encourage you to read the privacy policy of any third-party site you visit.

Payment providers referenced in Platform content — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are mentioned for Pakistani market context only. Their mention does not imply any data-sharing arrangement between 92pakr and these providers beyond what is strictly necessary for payment processing where such processing occurs through our cashier.

Policy Amendments

92pakr reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or the Services we offer. The date of the most recent revision is displayed at the top of this page.

Where material changes are made to this Policy — particularly those that affect your rights or the way we process sensitive categories of data — we will notify you by email or through a prominent notice on the Platform prior to the changes taking effect. We will seek fresh consent where required by applicable law.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the amended terms. If you do not agree with changes to this Policy, please discontinue use of the Platform and contact us to exercise your applicable data rights.

Contact & Data Requests

If you have any questions, concerns or requests in connection with this Privacy Policy or the processing of your Personal Data by 92pakr, please contact our data privacy team. All communications are handled in English. We aim to acknowledge receipt of all privacy requests within 5 business days and to respond substantively within 30 days, or such shorter period as required by applicable law.

Data Privacy Contact — Email (plain text, not a clickable link):

[email protected]

When submitting a data rights request, please include: your full name as registered on the Platform, your registered email address, the nature of your request (e.g., access, deletion, rectification), and any relevant context that will help us locate your records efficiently. We may request additional identity verification before processing the request to prevent unauthorised data disclosure.

If you are unsatisfied with our response to a privacy request or complaint, you have the right to escalate your complaint to the supervisory data protection authority in the jurisdiction governing our data processing operations.

For general platform questions, account support and betting-related enquiries, please also visit our FAQ page which covers the most frequently raised topics.