92pak Privacy Policy

1. Personal Data We Collect

When you register, use, or interact with the 92pak platform, we may collect the following categories of personal data:

1.1 Registration & Identity Data

• Pakistani mobile number used as the primary account identifier.
• Full legal name, date of birth, and nationality (collected during KYC verification).
• Copy of Pakistani CNIC (Computerised National Identity Card), passport, or other government-issued identity document (collected when KYC is required).
• Residential address (city and province within Pakistan, or full address where required for enhanced KYC).

1.2 Financial & Transaction Data

• JazzCash or Easypaisa mobile wallet number used for deposits and withdrawals.
• Bank account details (bank name, account number) where bank transfer is the chosen payment method — HBL, UBL, Meezan Bank, Bank Alfalah, or others.
• Deposit and withdrawal transaction records, including amounts in PKR, timestamps, and payment channel used.
• Account balance history and bonus credit/debit records.

1.3 Gaming & Betting Activity Data

• Betting history across all product lines: cricket sportsbook, live casino, slots, and other games.
• Session data: login timestamps, session duration, games accessed, and bet sizes.
• Responsible gaming tool settings: deposit limits, session time limits, self-exclusion status.

1.4 Technical & Device Data

• IP address at the time of login and during active sessions.
• Device type, operating system, and browser version.
• Approximate geolocation derived from IP address (city-level, not GPS-precise).
• Session cookies and local storage tokens used for authentication and session continuity.

1.5 Communications Data

• Records of live chat conversations with 92pak support staff.
• Email correspondence where email is used as a contact channel.
• SMS logs for OTP delivery and account notifications.

2. How 92pak Uses Your Personal Data

92pak uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, verifying, and securing your 92pak player account.
• Identity verification (KYC/AML): Fulfilling our obligations under applicable anti-money laundering and know-your-customer requirements, including verifying that you are of legal gambling age (18+) and that your identity matches your payment methods.
• Payment processing: Facilitating deposits and withdrawals via JazzCash, Easypaisa, and local bank channels in PKR.
• Platform operation: Delivering the gaming and betting services you access, including personalising the platform experience based on game preferences and betting history.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviour and applying the responsible gaming tools and limits you have set on your account.
• Customer support: Responding to queries, resolving disputes, and maintaining records of support interactions.
• Security and fraud prevention: Detecting and preventing unauthorised access, fraud, cheating, collusion, and other prohibited activities on the platform.
• Legal compliance: Meeting our obligations under applicable law, including responding to lawful requests from regulatory or law enforcement authorities.
• Platform analytics: Understanding how players use 92pak to improve product quality, fix bugs, and develop new features. Analytics data is aggregated and de-identified where possible.

3. Legal Basis for Processing

92pak processes your personal data on the following legal grounds:

• Contract performance: Processing necessary to provide you with the 92pak services you have registered for and to manage your player account.
• Legal obligation: Processing required to comply with applicable AML, KYC, and regulatory requirements, including age verification and transaction monitoring.
• Legitimate interests: Processing for fraud prevention, platform security, and product improvement, where these interests are not overridden by your rights and interests.
• Consent: Where we rely on consent (for example, for optional marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

4. Data Sharing & Third Parties

92pak does not sell your personal data. We share personal data only in the following circumstances and only to the minimum extent necessary:

• Payment processors: JazzCash, Easypaisa, and bank partners receive only the transaction data required to process your deposit or withdrawal. 92pak does not transmit your gaming history or account details to payment processors.
• Game providers: Live casino and slot providers (e.g. Evolution, Pragmatic Play, PG Soft) receive a session token to authenticate your game session. They do not receive your full account details, identity documents, or payment information.
• KYC/identity verification services: Where third-party identity verification tools are used, your identity document data is shared under strict data processing agreements that prohibit secondary use.
• Legal and regulatory authorities: 92pak will disclose personal data to law enforcement, regulatory bodies, or other public authorities where required to do so by applicable law or a valid legal process.
• Platform infrastructure providers: Hosting, security, and analytics service providers who process data on 92pak's behalf under contractual obligations that limit data use to the provision of the contracted service only.

5. Data Retention

92pak retains personal data for as long as your account is active and for a period thereafter as required by applicable law and our legitimate business interests:

• Active accounts: Personal data is retained for the duration of the account relationship.
• Closed accounts: Following account closure, 92pak retains identity, transaction, and gaming records for a minimum period of five (5) years in line with standard AML record-keeping obligations.
• KYC documents: Identity verification documents are retained for the statutory period required under applicable anti-money laundering regulations, after which they are securely deleted.
• Support records: Live chat and email support records are retained for a period of two (2) years from the date of the last interaction.

When data is no longer required, 92pak applies secure deletion or anonymisation processes to ensure it cannot be recovered or attributed to an identifiable individual.

6. Data Security

92pak implements technical and organisational security measures proportionate to the sensitivity of the personal data we process. These measures include:

• TLS 1.2 or higher encryption for all data in transit between your device and 92pak servers.
• Encryption at rest for sensitive data including identity documents and financial records stored on 92pak infrastructure.
• Access controls limiting personal data access to authorised 92pak staff with a legitimate operational need.
• Regular security reviews, penetration testing, and vulnerability assessments of the 92pak platform.
• Two-factor authentication (SMS OTP) available for all player accounts to prevent unauthorised access.

Despite these measures, no internet transmission or electronic storage system is 100% secure. In the event of a data breach that poses a risk to your rights and freedoms, 92pak will notify affected players without undue delay in accordance with our legal obligations.

7. Cookies & Tracking Technologies

92pak uses cookies and similar technologies on the Platform for the following purposes:

• Session cookies: Required to maintain your login state during an active session. These are deleted when you close your browser.
• Authentication tokens: Persistent tokens stored in local storage on trusted devices to enable "remember me" login functionality.
• Security cookies: Used to detect fraudulent login attempts and bot activity.
• Analytics cookies: First-party analytics cookies used to understand how players navigate the Platform, which features are used most, and where technical issues occur. This data is aggregated and does not identify individual players.

92pak does not use third-party advertising cookies, retargeting pixels, or social media tracking tags. You may disable cookies in your browser settings; however, doing so may prevent the Platform from functioning correctly, including preventing login.

8. Your Data Rights

Subject to applicable law, you have the following rights in relation to the personal data 92pak holds about you:

• Right of access: You may request a copy of the personal data 92pak holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where 92pak no longer has a lawful basis for retaining it. Note that statutory retention obligations (e.g. AML record-keeping) may prevent full deletion in certain cases.
• Right to restriction: You may request that 92pak restricts processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
• Right to data portability: Where processing is based on consent or contract performance and is carried out by automated means, you may request a machine-readable export of your personal data.
• Right to object: You may object to processing based on legitimate interests, including profiling for marketing purposes.

To exercise any of the above rights, contact 92pak via the live chat on the Platform or by emailing [email protected]. 92pak will respond to all valid data rights requests within thirty (30) calendar days. Identity verification may be required before processing a data rights request.

9. Children and Minors

The 92pak Platform is strictly intended for adults aged 18 and above. 92pak does not knowingly collect personal data from individuals under the age of 18. As part of the KYC process, 92pak verifies the age of all players before processing any withdrawal, and may verify age at registration or at any point during an account's lifetime.

If 92pak becomes aware that it holds personal data relating to a minor, that account will be closed immediately, all funds will be handled in accordance with 92pak's Terms & Conditions, and the relevant personal data will be deleted or anonymised promptly.

If you believe that a minor may have registered an account on the 92pak Platform, please contact support immediately via live chat.

10. Changes to This Privacy Policy

92pak may update this Privacy Policy from time to time to reflect changes in applicable law, platform features, or our data practices. Where changes are material, 92pak will notify registered players via SMS to their registered mobile number or via a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this document indicates when the most recent revision was made. Continued use of the 92pak Platform following the effective date of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not accept the revised policy, you should cease using the Platform and contact support to initiate account closure.

11. Contact & Data Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or the personal data 92pak holds about you, please contact us through the following channels:

• Live Chat: 24/7 live chat support is available directly on the 92pak Platform.
• Email (plain text — not a link): [email protected]

Please include "Privacy Request" in the subject line of any email relating to data rights. 92pak aims to acknowledge all privacy-related enquiries within two (2) business days and to resolve them within thirty (30) calendar days.