92pakr Privacy Policy – Your Data, Explained Clearly

1. Introduction

This Privacy Policy ("Policy") is issued by 92pakr ("the Platform", "we", "us", "our") and applies to all personal data collected from individuals ("you", "Player", "User") who access or use the 92pakr website and associated services (collectively, the "Service").

92pakr takes the privacy of its players seriously. This Policy is intended to give you a clear, honest account of what personal data we collect, the purposes for which we use it, with whom we share it, and the rights available to you. We encourage you to read it carefully. By registering an account or using the Service, you acknowledge that you have read and understood this Policy.

This Policy should be read in conjunction with the 92pakr Terms & Conditions. Terms defined in the Terms & Conditions and not otherwise defined here carry the same meaning in this Policy.

2. Data We Collect

92pakr collects personal data in the following categories:

• Identity Data: Full name, date of birth, gender, and national identity information (e.g. CNIC number) collected during registration and KYC verification.
• Contact Data: Mobile number, email address, and residential address provided at registration or updated by you subsequently.
• Financial Data: Payment method details (JazzCash mobile number, Easypaisa account, bank account details for HBL, UBL, Meezan Bank, or Bank Alfalah), transaction history, deposit amounts, withdrawal requests, and account balance history. Full payment card numbers — where applicable — are not stored by 92pakr; they are handled directly by the payment provider.
• Technical Data: IP address, device type, operating system, browser type, session duration, and platform interaction logs collected automatically when you access the Service.
• Gaming Data: Betting history, game session logs, wagering patterns, and responsible gaming tool usage (deposit limits set, cool-off periods activated, etc.).
• Communications Data: Records of any correspondence you initiate with 92pakr support, including email content, chat transcripts, and support ticket history.
• KYC Documentation: Copies of identity documents, address verification documents, and source-of-funds declarations submitted during the verification process.

We do not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs, or political opinions) unless specifically required by a responsible gaming obligation or legal mandate.

3. How We Use Your Data

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

• To create, verify, and manage your 92pakr player account.
• To conduct identity and age verification (KYC) as required by anti-money laundering and responsible gaming standards.
• To process deposits, withdrawals, and all financial transactions in PKR.
• To detect and prevent fraud, money laundering, collusion, and other prohibited conduct.
• To comply with our legal and regulatory obligations, including reporting obligations to relevant authorities where required.
• To administer bonuses, promotions, and loyalty rewards in accordance with applicable terms.
• To provide customer support and respond to your enquiries.
• To operate and improve the 92pakr platform, including technical performance monitoring and security.
• To send you service-related communications — account confirmations, security alerts, withdrawal notifications. These are not optional; they are necessary for the operation of your account.
• To monitor gaming behaviour for responsible gaming purposes, including identifying patterns that may indicate problem gambling, and contacting you where appropriate.

4. Legal Basis for Processing

92pakr processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions — including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering requirements, age verification mandates, and regulatory reporting obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improvement of the Service, where such interests are not overridden by your rights.
• Consent: For any processing not covered by the above — such as optional marketing communications — we will seek your explicit consent separately. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Third-Party Disclosure

92pakr does not sell your personal data. We share your data only in the following limited circumstances:

• Payment Processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and cryptocurrency processing partners receive the minimum data necessary to execute your transaction. Each provider operates under their own privacy policy and applicable financial regulations.
• KYC & Identity Verification Providers: Third-party identity verification services may process your CNIC data and documentary evidence on our behalf for compliance purposes. These providers are contractually bound to data protection standards equivalent to our own.
• Technology Service Providers: Cloud infrastructure, platform hosting, and customer support tool providers may process data as data processors acting on 92pakr's documented instructions only.
• Legal Authorities: Where required by applicable law, court order, or regulatory directive, 92pakr will disclose personal data to the relevant authority. We will notify you of such disclosure where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of assets involving 92pakr, your data may be transferred as part of that transaction. You will be notified of any such change and the applicable privacy terms of the acquiring entity.

6. Cookies & Tracking Technologies

92pakr uses cookies and similar session technologies to operate the platform. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the platform to function — session management, security tokens, login state, and anti-fraud checks. These cannot be disabled without breaking core platform functionality.
• Performance Cookies: Anonymised data about how players interact with the platform — page load times, error logs, feature usage — used to improve platform performance. No personally identifiable data is included.
• Functional Cookies: Preferences such as language settings and display preferences that improve your experience across sessions.

92pakr does not use third-party advertising cookies, cross-site tracking pixels, or social media tracking tags. Your browsing activity on 92pakr is not shared with advertising networks.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use the platform.

7. Data Security

92pakr implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and 92pakr servers.
• Encryption at rest for sensitive data fields including identity documents and payment method references.
• Access controls ensuring that personal data is accessible only to 92pakr personnel and contractors with a documented business need.
• Regular security assessments and vulnerability testing of platform infrastructure.
• Two-factor authentication (2FA) available to all players for account login security.

No system is completely immune to security risks. In the event of a data breach that is likely to result in significant risk to your rights, 92pakr will notify you and the relevant regulatory authority within the timeframe required by applicable law.

8. Data Retention

92pakr retains personal data for the period necessary to fulfil the purposes described in this Policy, subject to the following considerations:

• Active account data is retained for the duration of your account's active status plus a minimum of five (5) years following account closure, to satisfy anti-money laundering and financial record-keeping obligations.
• KYC documentation is retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction records are retained for a minimum of five (5) years for financial regulatory compliance.
• Customer support communications are retained for two (2) years from the date of resolution.
• Technical and session logs are retained for up to twelve (12) months for security and fraud prevention purposes, then anonymised or deleted.

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

9. Your Rights

Subject to applicable law and certain exemptions, you have the following rights in relation to your personal data held by 92pakr:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure: Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: Request that we restrict processing of your data in certain circumstances, for example while a complaint is under investigation.
• Right to Data Portability: Receive a machine-readable copy of personal data you have provided to us, for transfer to another service provider where technically feasible.
• Right to Object: Object to processing based on legitimate interests where your individual circumstances warrant it.
• Right to Withdraw Consent: Where processing is based on consent, withdraw that consent at any time without penalty. Withdrawal does not affect the lawfulness of prior processing.

To exercise any of the above rights, contact 92pakr at: [email protected]. We will respond to verified requests within thirty (30) calendar days. We may require identity verification before processing a rights request to protect against unauthorised access.

10. Children's Privacy

92pakr is strictly an adult platform. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been provided by or on behalf of a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor may have registered an account, please contact us at [email protected] immediately.

11. International Data Transfers

92pakr's primary operations are focused on Pakistani players, and we endeavour to process data within appropriate jurisdictions. Where data is transferred to or processed by service providers located outside Pakistan — for example, cloud infrastructure providers — we implement contractual safeguards to ensure that such transfers maintain data protection standards consistent with this Policy and applicable law.

By using the Service, you acknowledge that your data may be processed in jurisdictions outside Pakistan as described in this section.

12. Amendments to This Policy

92pakr reserves the right to amend this Privacy Policy at any time. Material changes will be communicated to registered players via email or in-platform notification at least 7 days before taking effect, where practicable. The "Last Updated" date at the top of this page will be revised accordingly. Continued use of the Service after an amendment takes effect constitutes acceptance of the revised Policy. You are encouraged to review this page periodically.

13. Contact & Data Enquiries

For any questions, requests, or complaints relating to this Privacy Policy or 92pakr's handling of your personal data, please contact us in writing. Our support team handles data protection enquiries and aims to respond within 30 calendar days.

Contact: [email protected]

Support is available in English and Urdu, Monday to Friday during Pakistan Standard Time business hours. For urgent security concerns, please mark your email subject line "DATA SECURITY – URGENT".