pak395 Privacy Policy — How We Handle Your Personal Data

1 Who We Are

1.1  pak395 is an online gaming platform operated under an international gaming license, offering sports betting, live casino games, slot titles, and instant-win products to registered adult players. The pak395 Platform is accessible at pak395.com and any associated mobile interfaces.

1.2  For the purposes of this Privacy Policy, pak395 (referred to as "we", "us", "the Company", or "pak395") acts as the data controller in respect of personal data collected from users ("you", "the User") of the Platform. As data controller, pak395 determines the purposes and means by which your personal data is processed.

1.3  If you have any questions about how pak395 processes your personal data or wish to exercise any of the rights described in this Policy, you may contact our dedicated support team via live chat on the Platform or by email at [email protected].

2 Data We Collect

2.1  pak395 collects personal data across several categories depending on your level of engagement with the Platform. The table below summarises the main categories of data we collect and their purpose:

2.2  pak395 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data (other than where voluntarily disclosed in a responsible gaming context), or biometric data beyond what is strictly necessary for CNIC-based identity verification.

3 How We Collect Your Data

3.1  Directly From You. The majority of personal data pak395 holds is provided directly by you during the account registration process, KYC verification, deposit and withdrawal requests, support interactions, and through your voluntary use of Platform features. This includes all identity and contact data you enter when creating your pak395 account.

3.2  Automatically Through Platform Use. When you access pak395, certain technical and usage data is automatically collected through server logs, session tracking mechanisms, and analytics tools. This includes your IP address, device identifiers, browser type, pages visited, and the duration and frequency of your sessions on the Platform.

3.3  From Third Parties. pak395 may receive data about you from third-party identity verification providers, fraud detection databases, and payment processors where such data is necessary to fulfil our KYC and anti-money laundering obligations under our gaming license. We may also receive updated contact or identity information from our payment partners, including JazzCash and EasyPaisa, where relevant to transaction processing.

3.4  Through Cookies and Tracking Technologies. pak395 uses cookies and similar tracking technologies to collect technical and preference data. Full details of our cookie use are set out in Section 7 of this Privacy Policy.

4 How We Use Your Personal Data

4.1  pak395 uses personal data collected from users for the following purposes:

• Account Management: To create, maintain, and administer your pak395 account, including processing your registration, verifying your identity, and managing your account balance denominated in PKR.
• Transaction Processing: To process deposits and withdrawals via your chosen Payment Method, including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and bank transfer, and to maintain accurate financial records of your account activity.
• KYC and AML Compliance: To conduct identity verification checks, screen against sanctions and PEP (Politically Exposed Person) lists, and fulfil anti-money laundering monitoring obligations required under pak395's international gaming license.
• Customer Support: To respond to your support queries via live chat and email, resolve disputes, and maintain records of correspondence for quality assurance purposes.
• Responsible Gaming: To monitor betting patterns and session data for signs of problem gambling behaviour, administer self-exclusion and cooling-off requests, and enforce deposit limits set by you.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, collusion, and other prohibited conduct on the Platform.
• Platform Improvement: To analyse aggregated usage data in order to improve Platform features, fix technical issues, and optimise the player experience across devices commonly used in Pakistan.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have given your express consent to receive such communications. You may withdraw consent at any time (see Section 12).
• Legal and Regulatory Compliance: To comply with legal obligations, respond to lawful requests from regulatory authorities, and defend or prosecute legal claims.

5 Legal Basis for Processing

5.1  pak395 processes your personal data only where a valid legal basis exists for doing so. The primary legal bases on which pak395 relies are as follows:

• Contractual Necessity: Processing required to perform our obligations under the user agreement between you and pak395, including account operation, bet settlement, and payment processing.
• Legal Obligation: Processing required for pak395 to comply with applicable law and the conditions of our international gaming license, including KYC verification, AML monitoring, and regulatory reporting.
• Legitimate Interests: Processing necessary for pak395's legitimate business interests, including fraud prevention, Platform security, responsible gaming enforcement, and service quality improvement, where those interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications and non-essential cookies, which we only carry out where you have given us clear, specific, and freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Third Parties

6.1  pak395 does not sell, rent, or disclose your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances and only to the extent strictly necessary:

• Identity Verification Providers: To conduct KYC checks, pak395 shares identity and document data with vetted third-party verification services. These providers are contractually bound to process your data solely for verification purposes.
• Payment Processors: Transaction data is shared with payment service providers including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank solely to process your deposits and withdrawals. These providers operate under their own regulatory obligations and privacy frameworks.
• Fraud Prevention and AML Services: pak395 shares account and transaction data with fraud detection and anti-money laundering screening services as required by our gaming license compliance obligations.
• Technology and Infrastructure Providers: pak395 uses cloud hosting and Platform infrastructure providers who may process technical data on our behalf as data processors. All such providers are bound by data processing agreements.
• Regulatory and Law Enforcement Authorities: pak395 will disclose personal data to licensing regulators, financial intelligence units, or law enforcement agencies where required to do so by law, court order, or lawful regulatory instruction.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of pak395's business assets, personal data held by pak395 may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

7 Cookies & Tracking Technologies

7.1  pak395 uses cookies — small text files stored on your device — and similar tracking technologies to operate the Platform, remember your session and preferences, analyse usage patterns, and detect security threats. Cookies do not give us access to your device and cannot read other data stored on it.

7.2  The categories of cookies used by pak395 are as follows:

• Strictly Necessary Cookies: Essential to the operation of the Platform. Without these cookies, features such as account login, session persistence, and bet placement cannot function. These cookies do not require your consent.
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations, to provide a more personalised experience.
• Analytical Cookies: Used in aggregate, anonymised form to help us understand how players interact with the Platform, which pages are most visited, and where technical issues occur — allowing us to improve the experience for all users.
• Security Cookies: Used to detect and prevent fraudulent activity, including identifying unusual login patterns, multiple account indicators, and bot activity.

7.3  You may control non-essential cookies through your browser settings. Please be aware that disabling certain cookies may affect the functionality of the pak395 Platform and your ability to access some features.

8 Data Retention

8.1  pak395 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and licensing obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active account relationship with pak395, plus a minimum of five (5) years following account closure, as required by anti-money laundering record-keeping obligations.
• Transaction Records: Financial transaction records, including deposit and withdrawal history in PKR, are retained for a minimum of seven (7) years in accordance with financial record-keeping requirements applicable under our gaming license.
• KYC Documentation: Identity verification documents, including CNIC copies and verification results, are retained for a minimum of five (5) years following account closure.
• Support Communications: Customer support correspondence is retained for three (3) years from the date of the last interaction for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of your consent to or withdrawal from marketing communications are retained indefinitely to provide an auditable consent trail.

8.2  Where personal data is no longer required for any valid retention purpose, pak395 will securely delete or anonymise it in a manner that prevents reconstruction of personally identifiable information.

9 Data Security

9.1  pak395 implements a multi-layered data security framework designed to protect your personal information against unauthorised access, disclosure, alteration, and destruction. The security measures in place include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and pak395 servers.
• Encrypted storage of sensitive data fields, including financial account references and CNIC details, at rest.
• Role-based access controls limiting internal access to personal data to authorised staff on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by qualified third-party security specialists.
• Two-factor authentication options available to all registered pak395 account holders.
• Continuous server-side monitoring for anomalous access patterns and potential intrusion activity.

9.2  Despite the measures described above, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. pak395 therefore cannot warrant the absolute security of your personal data and shall not be liable for breaches arising from circumstances beyond its reasonable control, provided it has taken all reasonable and appropriate precautions.

9.3  You play an important role in keeping your pak395 account secure. You must never share your login credentials with any third party and should use a strong, unique password for your pak395 account. Contact support immediately if you suspect unauthorised access.

10 Your Privacy Rights

10.1  As a pak395 user, you have the following rights in respect of your personal data. To exercise any of these rights, please contact our support team via live chat or email:

• Right of Access: You may request a copy of the personal data pak395 holds about you, along with information about how it is used and with whom it is shared.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held in your pak395 account. Some data corrections may require additional documentary verification.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. This right is subject to our legal and regulatory retention obligations — for example, pak395 is required to retain transaction records for a defined period regardless of an erasure request.
• Right to Restriction: You may request that pak395 restricts the processing of your personal data in specific circumstances, such as while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where processing is based on your consent or a contract, and is carried out by automated means, you may request that pak395 provide your personal data in a structured, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of pak395's legitimate interests, including profiling for responsible gaming monitoring. pak395 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g. marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

10.2  pak395 will respond to all verifiable data rights requests within thirty (30) days of receipt. Where a request is complex or involves multiple data sets, we may extend this period by a further thirty (30) days, with prior notice to you.

11 Children & Minors

11.1  The pak395 Platform is strictly intended for adults aged 21 years and above. pak395 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process, and accounts found to belong to under-age individuals will be immediately closed.

11.2  If pak395 becomes aware that personal data has been collected from a person under the age of 21, that data will be deleted promptly and the account will be closed. Any funds associated with an under-age account will be handled in accordance with our licensing obligations and applicable law.

11.3  If you are a parent or guardian and believe that a minor in your care has registered an account on pak395, please contact our support team immediately so that we can take appropriate action.

12 Marketing Communications

12.1  pak395 may send you promotional communications about bonuses, new game launches, PSL betting markets, and platform features where you have provided express consent to receive such communications at the time of registration or through your account preference settings.

12.2  You may opt out of marketing communications at any time by updating your preferences within your pak395 account settings, by clicking the "unsubscribe" link included in any marketing email, or by contacting the support team directly.

12.3  Opting out of marketing communications will not affect the delivery of transactional and account-related messages, which pak395 is required to send as part of its service delivery and regulatory obligations — such as deposit confirmations, withdrawal status updates, KYC requests, and responsible gaming notifications.

12.4  pak395 does not send unsolicited SMS or WhatsApp marketing messages to users who have not explicitly opted in to such communications via their account settings.

13 Third-Party Links

13.1  The pak395 Platform does not contain outbound links to third-party websites as a matter of policy. Where references to third-party service providers such as payment processors are made within account interfaces or support documentation, those references are informational only. pak395 is not responsible for the privacy practices or content of any third-party services you independently choose to access.

13.2  This Privacy Policy applies exclusively to personal data collected and processed through the pak395 Platform at pak395.com and its associated interfaces. It does not apply to the data practices of JazzCash, EasyPaisa, or any banking provider you use independently to fund your pak395 transactions — those entities operate under their own separate privacy policies.

14 Changes to This Privacy Policy

14.1  pak395 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or licensing requirements. When a material change is made, we will notify registered users via the email address on their account and update the "Last Updated" date at the top of this page.

14.2  Your continued use of the pak395 Platform following notification of a revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed about how your personal data is being protected.

14.3  Where a proposed change materially reduces your privacy rights, pak395 will provide at least fourteen (14) days' advance notice before the change takes effect, giving you the opportunity to contact us with any concerns or to close your account if you do not wish to continue under the revised Policy.

15 Contact & Complaints

15.1  If you have any questions, concerns, or complaints regarding the way pak395 handles your personal data, or if you wish to exercise any of the data rights described in Section 10, please contact us through the following channels:

• Live Chat: Available 24/7 through the chat widget on the pak395 Platform — the fastest route for urgent privacy concerns.
• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" for faster routing. We aim to respond within 4 hours during business hours.

15.2  pak395 takes all privacy complaints seriously. Upon receipt of a complaint, we will acknowledge it within two (2) business days and aim to provide a substantive response within fourteen (14) business days. Complex matters may require additional time, and we will keep you informed of progress.

15.3  If you are not satisfied with pak395's response to a privacy complaint, you may escalate the matter to the relevant supervisory authority or the dispute resolution mechanism available under pak395's gaming license framework.