pak65 Privacy Policy

This Privacy Policy ("Policy") is published by pak65 and applies to all personal data collected, processed, stored, or transmitted in connection with the pak65 platform, accessible at pak65.bio. This Policy governs the personal data of all individuals who interact with pak65, including registered players, prospective players who visit the Platform without registering, and individuals who contact pak65's customer support team.

pak65 takes its data protection obligations seriously. As an operator holding an international gaming license, pak65 is subject to data governance requirements forming part of that regulatory framework. These requirements establish standards for the collection, use, and protection of personal data that go beyond basic website privacy norms — reflecting the sensitivity of financial and identity data handled by a licensed gambling operator.

This Policy is intended to give Pakistani players — whether in Karachi, Lahore, Islamabad, Faisalabad, or any other part of Pakistan — a clear and honest understanding of what happens to their personal data when they use pak65. Privacy documentation written in impenetrable legalese serves nobody well; this Policy is written to be genuinely readable while remaining legally accurate.

For the purposes of this Privacy Policy, pak65 acts as the data controller in respect of personal data collected through the pak65 Platform. As data controller, pak65 determines the purposes and means by which personal data is processed and is responsible for ensuring that processing activities comply with applicable data protection requirements under its international gaming license framework.

Players with questions about data controllership, data processing activities, or the exercise of their data rights should direct enquiries to pak65's data protection contact:

• Platform: pak65, accessible at pak65.bio
• Data Protection Contact: [email protected] — please include "Privacy / Data Request" in the subject line of your email
• Response Timeframe: pak65 aims to acknowledge data-related requests within 3 business days and to respond substantively within 30 calendar days of receipt

pak65 collects personal data across several categories, depending on how you interact with the Platform. The following table summarises the main categories of personal data pak65 collects, the source of that data, and the contexts in which collection occurs.

pak65 does not knowingly collect personal data from individuals under the age of 21. Where pak65 discovers that personal data has been submitted by an individual under 21, the relevant account and associated data will be processed in accordance with Section 12 of this Policy.

pak65 does not collect sensitive personal data categories — including racial or ethnic origin, political opinions, religious beliefs, or health data — beyond what is incidentally visible in CNIC documents submitted for KYC purposes. CNIC data is used solely for identity verification and is not used to draw inferences about sensitive personal characteristics.

pak65 uses the personal data it collects for the following defined purposes. Data is not used for any purpose beyond those described below without prior notice and, where applicable, consent.

4.1 Account Management and Platform Operation

pak65 uses registration data and account information to create and maintain your player account, authenticate your identity at login, manage your PKR wallet, process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK, and provide access to the pak65 game lobby, sportsbook, and associated features.

4.2 Identity Verification and Regulatory Compliance

KYC data — primarily your CNIC and selfie photograph — is used exclusively to verify that you are who you say you are, that you are at least 21 years of age, and that your use of pak65 complies with the regulatory conditions of pak65's international gaming license. This processing is mandatory and cannot be opted out of by players who wish to use the full functionality of the Platform.

4.3 Anti-Money Laundering (AML) Monitoring

pak65's international gaming license requires it to monitor financial transactions for patterns consistent with money laundering or financial crime. Financial data and gaming activity data are used for this purpose. Suspicious activity is reported to relevant authorities as required under pak65's AML obligations. This processing is a non-negotiable legal requirement and is not subject to player opt-out.

4.4 Responsible Gaming

Gaming activity data — including bet history, session duration, loss patterns, and deposit frequency — is analysed by pak65 to identify patterns consistent with problem gambling. Where such patterns are identified, pak65 may take proactive steps including imposing temporary deposit limits, issuing responsible gaming notifications, or referring a player to pak65's self-exclusion process. This use of data forms part of pak65's licensing obligations.

4.5 Customer Support

Communication data — support messages, complaint records, and interaction history — is used to process and respond to player support requests, investigate complaints, and improve pak65's support quality. Support interactions are retained for a defined period to support dispute resolution processes.

4.6 Platform Security and Fraud Prevention

Technical data — including IP address, device fingerprint, and login timestamps — is used to detect and prevent fraudulent activity, including multi-accounting, bonus abuse, and unauthorised account access. Suspicious technical patterns may result in account investigation and, where fraud is confirmed, account suspension.

4.7 Marketing Communications (Consent-Based)

Where you have expressly opted in to receive marketing communications from pak65, your registration data and marketing preference data will be used to send promotional emails and SMS messages relating to pak65 bonuses, new game launches, cricket betting promotions, and seasonal offers. This processing is conditional on your consent and may be withdrawn at any time as described in Section 13.

pak65 processes personal data under the following legal bases, which together provide the lawful foundation for all data processing activities described in this Policy:

• Contractual Necessity: Processing necessary to perform the contract between pak65 and the player — including account creation, deposit processing, game access, and withdrawal handling. Without this processing, pak65 cannot provide its services.
• Legal Obligation: Processing required to comply with pak65's legal and regulatory obligations under its international gaming license, including KYC verification, AML transaction monitoring, and responsible gaming obligations. Players cannot opt out of legally mandated processing.
• Legitimate Interests: Processing carried out for pak65's legitimate business interests, including fraud prevention, platform security, and the improvement of pak65's services, where these interests are not overridden by player privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — principally marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

pak65 does not sell, rent, or trade personal data. Personal data is shared only in the following defined circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: Financial data is shared with payment processors — including JazzCash and EasyPaisa technical integration partners, and Pakistani bank clearing systems for HBL, UBL, and Meezan Bank transfers — for the sole purpose of processing your transactions. These processors are contractually bound to handle your data securely and only for transaction processing purposes.
• Game Providers: Certain gaming activity data is shared with pak65's certified game providers — such as Pragmatic Play and Evolution Gaming — for technical platform integration, game session management, and RNG audit trail purposes. Game providers are licensed operators subject to their own regulatory data obligations.
• KYC / Identity Verification Services: Where pak65 uses a third-party identity verification provider to support the KYC process, CNIC data and selfie photographs may be transmitted to that provider's secure systems for the purpose of identity document verification. Such providers are contractually bound to handle identity data exclusively for verification purposes.
• Regulatory Authorities: pak65 is obligated under its international gaming license and applicable AML law to report certain information — including suspected money laundering activity — to relevant financial intelligence units and regulatory bodies. This disclosure is non-negotiable and is not subject to player consent.
• Legal Process: pak65 may disclose personal data in response to a valid court order, law enforcement request, or other legally binding demand. Where legally permissible, pak65 will notify the affected player of such a request before disclosure.
• Professional Advisers: pak65 may share personal data with legal advisers, accountants, and auditors in the course of obtaining professional advice, subject to professional confidentiality obligations.

pak65 uses cookies and similar tracking technologies on the pak65 Platform. Cookies are small text files placed on your device that help pak65 deliver a functional, secure, and personalised experience. The following categories of cookies are used by pak65:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session authentication cookies that maintain your logged-in state, security cookies that protect against CSRF attacks, and load-balancing cookies. No opt-out is available for strictly necessary cookies as they are required for basic Platform operation.
• Functional Cookies: These cookies remember your preferences — such as your preferred language, game lobby filter settings, and responsible gaming limit configurations — to improve your experience on return visits. They do not track you across external websites.
• Analytical Cookies: pak65 uses analytics cookies to understand aggregate Platform usage patterns — such as which game categories are most visited, typical session durations by device type, and deposit funnel completion rates. This data is used to improve the Platform and is not linked to individual player identities for analytical purposes.
• Security and Fraud Prevention Cookies: Technical cookies used to detect multi-accounting, bot activity, and other fraudulent use patterns. These cookies form part of pak65's licensed fraud prevention obligations.

You may manage non-essential cookie preferences through your browser settings. Disabling functional or analytical cookies will not prevent you from using the Platform but may affect certain preference-based features. Disabling strictly necessary cookies will impair core Platform functionality.

pak65 implements a layered approach to data security, combining technical, organisational, and procedural measures to protect personal data against unauthorised access, loss, alteration, or disclosure. The following security measures are in place:

• Encryption at Rest: All personal data stored on pak65 systems — including account records, KYC documents, and financial data — is encrypted at rest using AES-256 encryption.
• Encryption in Transit: All data transmitted between player devices and pak65 servers is encrypted using TLS 1.2 or higher, enforced site-wide without exception. Plain HTTP connections are not accepted.
• Access Controls: pak65 systems operate on a role-based access control model. Staff access to personal data is restricted to the minimum required for the performance of their specific duties. All access is logged and subject to periodic audit.
• Security Testing: pak65 conducts regular penetration testing and vulnerability assessments of its platform infrastructure in accordance with its licensing requirements. Identified vulnerabilities are remediated within defined timeframes based on severity.
• Incident Response: pak65 maintains a documented data breach response procedure. In the event of a personal data breach, affected players will be notified in accordance with applicable regulatory timelines where the breach poses a significant risk to player rights.

pak65 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by legal and regulatory obligations. The following retention periods apply as a general framework:

• Account and Registration Data: Retained for the duration of the active account relationship plus five (5) years after account closure, to support any subsequent regulatory or legal obligations arising from the account history.
• KYC / Identity Documents: Retained for a minimum of five (5) years after account closure in accordance with anti-money laundering regulatory requirements applicable under pak65's international gaming license. Identity documents are stored in encrypted form throughout the retention period.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction in accordance with AML and financial record-keeping obligations. This applies to all deposit and withdrawal records denominated in PKR.
• Gaming Activity Data: Retained for a minimum of three (3) years to support responsible gaming monitoring, dispute resolution, and licensing audit requirements.
• Support Communications: Retained for two (2) years from the date of the last interaction, or longer where the communication is relevant to an ongoing dispute or regulatory matter.
• Marketing Preference Data: Retained until consent is withdrawn, after which the preference record (including the withdrawal) is retained for three (3) years as evidence of the consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with pak65's data deletion procedures. Anonymised data — from which individual players cannot be identified — may be retained indefinitely for aggregate analytical purposes.

As an online platform operating under an international gaming license, pak65 may transfer personal data to recipients located outside Pakistan. This can occur in the following contexts:

• Data transmitted to pak65's licensed game providers — including studios operating in Europe and other regulated markets — for technical integration and game session management;
• Data processed by pak65's cloud infrastructure providers, whose server facilities may be located in jurisdictions outside Pakistan;
• Data shared with international KYC verification service providers for identity document processing.

Where personal data is transferred internationally, pak65 ensures that appropriate contractual safeguards are in place — including data processing agreements with standard contractual clauses or equivalent protections — to maintain the level of data protection applicable to the data in Pakistan. pak65 does not transfer personal data to jurisdictions or recipients that do not meet minimum data protection standards.

pak65 players and website visitors have the following rights in relation to their personal data, as described in the Rights Summary section above. To exercise any of these rights, the process is as follows:

1. Submit Your Request: Send your data rights request to [email protected] with the subject line "Data Rights Request – [Type of Request]". Clearly describe the right you wish to exercise and the specific data or processing activity to which your request relates.
2. Identity Verification: Before pak65 can action a data rights request, it must verify that the request is being made by the registered account holder. You will be asked to confirm your identity by providing details consistent with your account registration. This step protects against unauthorised requests by third parties.
3. Response: pak65 will acknowledge your request within 3 business days and provide a substantive response within 30 calendar days. Where a request is complex or involves a large volume of data, pak65 may extend this period by a further 30 days with prior notice.
4. No Charge: Exercising your data rights is free of charge. pak65 reserves the right to charge a reasonable administrative fee only where requests are manifestly unfounded or excessive — a determination that will be explained to the requesting player in writing.

Where a data rights request is refused — for example, because fulfilling it would conflict with pak65's AML legal retention obligations — pak65 will explain the reason for refusal in writing and inform the player of any available means of recourse.

The pak65 Platform is strictly for individuals aged 21 and above. pak65 does not knowingly collect personal data from individuals under the age of 21. The 21+ minimum age is enforced through the KYC identity verification process, which requires submission of a Pakistani CNIC confirming the player's date of birth.

If pak65 discovers or has reason to believe that a player account has been registered by an individual under 21 years of age, the following steps will be taken immediately:

• The account will be suspended pending investigation;
• Any funds deposited will be returned to the originating payment method (JazzCash, EasyPaisa, or bank account) after verification, minus any bonuses claimed;
• All personal data associated with the account will be deleted as soon as regulatory retention obligations permit, typically upon completion of the AML review period;
• The incident will be reported to relevant authorities where required under pak65's licensing obligations.

pak65 sends marketing communications — including promotional emails and SMS messages relating to bonuses, new games, cricket betting offers, and seasonal promotions — only to players who have expressly opted in to receive such communications at the point of registration or through their account settings.

You may withdraw consent for marketing communications at any time through any of the following methods:

• Using the unsubscribe link included in every marketing email sent by pak65;
• Replying "STOP" to any marketing SMS received from pak65;
• Updating your marketing preferences in the Notifications section of your pak65 account settings;
• Contacting pak65 support at [email protected] with the subject "Marketing Opt-Out".

Withdrawal of marketing consent takes effect within 5 business days. Please note that transactional communications — such as deposit confirmation messages, withdrawal notifications, KYC status updates, and responsible gaming alerts — are not marketing communications and will continue regardless of your marketing preference settings, as they form part of the contractual service relationship.

pak65 reserves the right to update or amend this Privacy Policy at any time to reflect changes in its data processing practices, regulatory obligations, or Platform features. The effective date at the top of this Policy indicates when the current version was last updated.

Where a proposed change is material — meaning it significantly affects how pak65 uses or shares personal data — pak65 will notify registered players by email to their registered address prior to the change taking effect. Continued use of the pak65 Platform following the effective date of any amended Policy constitutes acknowledgement of the updated terms.

The current version of this Privacy Policy is always available at pak65.bio/privacy-policy. Pakistani players are encouraged to review this Policy periodically, particularly following any notification of an update.

For any privacy-related enquiry, data rights request, or complaint relating to how pak65 handles personal data, Pakistani players should contact pak65 through the following channels:

• Email: [email protected] — use the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate. pak65 aims to acknowledge all privacy-related emails within 3 business days.
• Live Chat: Available within your pak65 account dashboard after login. English and Urdu-language support agents are available 24 hours a day. For complex privacy matters, following up by email is recommended to create a documented record.

pak65 takes privacy complaints seriously. If you submit a complaint and are not satisfied with the response you receive, you may escalate the matter to the relevant data protection supervisory authority under pak65's licensing jurisdiction. pak65 will cooperate fully with any regulatory investigation relating to its data protection practices.

pak65 encourages transparency in its data practices and welcomes feedback from Pakistani players on how the Platform can improve its approach to privacy and data protection. Your feedback genuinely contributes to how pak65 develops its data governance practices over time.