Privacy Policy

1. Introduction

pak97 (hereinafter "the Platform", "we", "us", or "our") is committed to protecting the privacy and security of all personal data it processes. This Privacy Policy (hereinafter "the Policy") sets out in detail the categories of personal data we collect from users of the website at pak97.cam, the purposes for which that data is processed, the legal bases we rely upon, and the rights available to you as a data subject.

This Policy applies to all users who visit, register with, or otherwise interact with pak97, including players accessing the platform from Pakistan and any other jurisdiction where access is permitted. It should be read together with our Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

By accessing pak97 or registering an account, you acknowledge that you have read, understood and consented to the data practices described in this Policy. If you do not agree with any aspect of this Policy, you must not use the platform.

2. Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person ("data subject").
• "Processing" — any operation performed on personal data, whether by automated means or otherwise, including collection, storage, use, disclosure and erasure.
• "Controller" — the entity that determines the purposes and means of processing personal data. For this Policy, the Controller is the Operator of the pak97 platform.
• "Processor" — any third party that processes personal data on behalf of the Controller under a data processing agreement.
• "User" / "Data Subject" — any natural person who accesses, registers with, or uses the pak97 platform.
• "KYC Data" — identity and address verification documents provided for Know Your Customer compliance purposes.
• "Cookie" — a small text file placed on a user's device by a website to store session and preference information.
• "AML" — Anti-Money Laundering; regulatory obligations requiring verification of the source and legitimacy of funds.

3. Data We Collect

pak97 collects the following categories of personal data, depending on the nature of your interaction with the platform:

3.1 Registration Data

• Full legal name
• Date of birth
• Email address
• Mobile telephone number
• Residential address (city, country — for example, Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Username and account credentials (passwords are stored in hashed, non-reversible form)

3.2 Identity Verification (KYC) Data

• Copy of government-issued identity document (CNIC — both sides — or valid passport)
• Proof of residential address (utility bill, bank statement)
• Selfie or liveness verification photograph
• Payment method verification documentation

3.3 Transaction and Financial Data

• Deposit and withdrawal transaction records
• Payment method identifiers (e.g., masked card numbers, wallet reference IDs)
• Account balance history and currency denomination (PKR)
• Bonus uptake and wagering records

3.4 Behavioural and Technical Data

• IP address and approximate geolocation derived from IP
• Device type, operating system and browser information
• Session duration, pages visited and game history
• Betting patterns and game preference data
• Log data and error reports

3.5 Communications Data

• Support ticket content and live chat transcripts
• Email correspondence with pak97 support
• Survey responses and feedback submissions (where provided voluntarily)

4. How Data Is Collected

Personal data is collected through the following channels:

• Direct submission: Information you provide when registering, completing KYC, making deposits, contacting support, or completing forms on the platform.
• Automated technical collection: Data collected automatically as you interact with the website, including cookies, server logs, and analytics tools.
• Third-party verification providers: Identity and fraud-check data received from KYC service providers and AML screening databases.
• Payment processors: Transaction confirmation data returned by payment gateways following deposit or withdrawal processing.
• Responsible gambling tools: Data generated through use of deposit limits, session timers and self-exclusion features, which is processed to enforce those controls.

5. Legal Basis for Processing

pak97 processes personal data on the following legal grounds, consistent with the data protection framework applicable in its operating jurisdiction:

6. Purposes of Processing

Personal data collected by pak97 is used for the following purposes:

6.1 Platform Operation

To create and manage your account, process deposits and withdrawals, provide access to betting markets and casino games, settle bets, and deliver the full range of services described in the Terms & Conditions.

6.2 Regulatory and Legal Compliance

To comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations, age verification requirements, responsible gambling obligations, and any reporting duties imposed by the applicable licensing authority. Records of KYC data and transaction history are maintained for defined periods as required by applicable law and licensing conditions.

6.3 Fraud Prevention and Security

To detect, investigate and prevent fraudulent activity, account compromise, bonus abuse, identity fraud, and any form of conduct that threatens platform integrity or other users. IP address data, device fingerprints and behavioural patterns may be analysed for these purposes.

6.4 Responsible Gambling

To enforce deposit limits, loss limits, session time controls, reality checks and self-exclusion arrangements you have activated. Behavioural data may be reviewed to identify patterns consistent with problem gambling, in order to prompt intervention tools in accordance with responsible gambling obligations under the applicable licence.

6.5 Customer Support

To respond to support enquiries, resolve disputes, process complaints and maintain records of communications for quality assurance and audit purposes. Support is available in English; Urdu-speaking agents may also be available upon request.

6.6 Marketing Communications

Where you have provided explicit consent, to send you promotional offers, bonus notifications, product updates and personalised recommendations by email or platform notification. You may withdraw your consent to marketing communications at any time by adjusting your account notification settings.

7. Data Retention

pak97 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, or for as long as is required by applicable law, regulatory obligations and licensing conditions. The following indicative retention periods apply:

Retention periods may be extended where required by ongoing legal proceedings, regulatory investigations, or licensing authority instructions. Once the applicable retention period has elapsed, data is securely deleted or anonymised.

8. Data Sharing & Disclosure

pak97 does not sell personal data to third parties under any circumstances. Data may be shared with the following categories of recipients, strictly for the purposes described in this Policy and subject to appropriate contractual safeguards:

8.1 Service Providers and Processors

• KYC and identity verification providers — to conduct document and liveness checks.
• Payment processors — to facilitate deposit and withdrawal transactions. Payment providers referenced for Pakistani user context (such as the services underlying Easypaisa, JazzCash, Raast, or bank transfers via institutions such as HBL, UBL, Meezan Bank, and Bank Alfalah) are independent third parties. Their data practices are governed by their own privacy policies. pak97 does not share more data with payment processors than is necessary to complete the relevant transaction.
• Fraud and AML screening providers — to screen transactions against sanctions lists and risk databases.
• Platform analytics and infrastructure providers — to support hosting, performance monitoring and security.

8.2 Legal and Regulatory Disclosure

pak97 may disclose personal data to competent authorities, regulators, or law enforcement agencies where required to do so by applicable law, court order, or the terms of its operating licence. Such disclosure will be limited to the data strictly required to satisfy the relevant legal obligation.

8.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of the platform or its operating entity, personal data held by pak97 may be transferred to the successor entity as part of that transaction. Users will be notified of any such transfer where required by applicable law.

9. International Data Transfers

pak97 operates under an international licensing framework. Your personal data may be processed or stored by servers and service providers located outside of Pakistan. Where data is transferred to jurisdictions that may not have data protection standards equivalent to your home country, pak97 takes steps to ensure that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by the relevant data protection authority in the licensing jurisdiction;
• Data processing agreements with processors that include binding obligations regarding data security, purpose limitation and subject rights;
• Technical and organisational security measures described in Section 11 of this Policy.

10. Cookies & Tracking Technologies

pak97 uses cookies and similar tracking technologies to operate the platform, maintain your session, personalise your experience and analyse usage patterns. The following categories of cookies may be present on pak97:

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent the platform from functioning correctly. Disabling functional cookies may affect your saved preferences and responsible gambling tool enforcement.

11. Data Security

pak97 implements industry-standard technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/HTTPS) encryption for all data in transit between your browser and pak97 servers.
• Encryption of sensitive data at rest, including identity documents and payment references.
• One-way hashing of user passwords — pak97 staff cannot retrieve your password in plain text.
• Access controls limiting staff data access to the minimum necessary for their role (principle of least privilege).
• Regular security assessments and penetration testing of platform infrastructure.
• Incident response procedures for detecting, reporting and addressing data security breaches.

Notwithstanding these measures, no internet-based system is entirely immune from security threats. You are responsible for maintaining the security of your own account credentials and for notifying pak97 immediately if you suspect any unauthorised access to your account.

12. Minors

pak97 is strictly intended for adults aged 18 years or older, or the higher minimum age required by the applicable operator licence jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete such data and close the associated account.

If you are a parent or guardian and believe that a minor has registered an account on pak97, please contact us at [email protected] immediately so that we can investigate and take appropriate action.

13. Your Rights

Subject to the data protection laws applicable in the Operator's licensing jurisdiction, you may have the following rights with respect to your personal data held by pak97. The availability of specific rights may vary depending on the legal framework applicable to your circumstances.

To exercise any of the above rights, contact us at [email protected]. We will acknowledge your request within 5 business days and respond substantively within 30 calendar days. We may ask you to verify your identity before processing a rights request. Requests that are manifestly unfounded or excessive may be declined or subject to a reasonable fee.

14. Pakistan-Specific Notice

Pakistan does not currently have a comprehensive data protection law of general application equivalent to the EU General Data Protection Regulation (GDPR) or the UK Data Protection Act 2018. The Personal Data Protection Bill has been under consideration but, as of the date of this Policy, has not been enacted as law. pak97 applies the data protection standards of its international operating jurisdiction to all user data.

Users in Pakistan should be aware that:

• By registering an account, you consent to the collection and international transfer of your personal data as described in this Policy.
• Your data may be processed and stored on servers located outside Pakistan.
• The Prevention of Electronic Crimes Act, 2016 (PECA) and the Pakistan Telecommunication (Re-organisation) Act, 1996 may have implications for digital platform operations in Pakistan, but pak97 does not claim compliance with or supervision by any Pakistani authority.
• Any rights-related requests will be handled in accordance with the data protection framework of the Operator's licensing jurisdiction.

15. Policy Amendments

pak97 reserves the right to update or amend this Privacy Policy at any time. Material changes — such as changes to the categories of data collected, the legal bases relied upon, or the rights available to users — will be communicated via a prominent notice on the platform and, where a valid email address is registered, by email notification.

Continued use of the platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the changes, you should cease using the platform and request account closure in accordance with the Terms & Conditions. The "Last Reviewed" date at the top of this Policy will be updated with each revision.

16. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the pak97 data team through the following channel. All communications should be submitted in English.

The email address above is displayed as plain text for informational purposes only and is not a clickable hyperlink. Please copy the address manually into your email client. pak97 will never request your password, full CNIC number or payment card details via email.