pak111 Privacy Policy

pak111 is the operator of the online casino and sports betting platform accessible at pak111.site (the "Platform"). In the context of this Privacy Policy, pak111 acts as the data controller — meaning we are the entity that determines why and how your personal data is processed. We are responsible for ensuring that your data is handled lawfully, fairly, and in a transparent manner in accordance with applicable data protection standards.

The pak111 Platform is built specifically for Pakistani players and is administered under an internationally recognised gaming operating licence. Our privacy practices are designed to comply with the data protection requirements imposed by our licensing authority and reflect internationally accepted standards of responsible data handling.

If you have any questions about this Privacy Policy or how pak111 handles your personal data, you may contact our Data Protection contact at [email protected]. Please use the subject line "Privacy Enquiry" for prompt routing to the appropriate team.

pak111 collects personal data through several channels — primarily during account registration, identity verification, gameplay, transactions, and communications with our support team. The categories of personal data we collect include the following:

pak111 uses the personal data collected for the following specific purposes. We do not use your data for any purpose not listed below without first obtaining your explicit consent or being required to do so by law:

• Account Management: To create, maintain, verify, and manage your pak111 Account, including processing deposits and withdrawals and maintaining your PKR wallet balance.
• Identity Verification (KYC): To verify your identity and age using your CNIC and associated documentation as required under our licensing obligations and anti-money laundering compliance requirements.
• Transaction Processing: To process deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK, and to process withdrawal requests back to your verified payment methods.
• Platform Provision: To make the casino lobby, sports betting markets, slot games, Teen Patti, and all other Platform services available to you during your authenticated sessions.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and any other conduct prohibited under our Terms and Conditions.
• Legal & Regulatory Compliance: To meet obligations imposed by our gaming licence, including filing reports with relevant financial intelligence authorities where required by applicable anti-money laundering regulations.
• Responsible Gaming: To operate and enforce responsible gaming tools including deposit limits, loss limits, session reminders, cooling-off periods, and self-exclusion — and to monitor for indicators of problem gambling behaviour.
• Customer Support: To respond to your enquiries, resolve disputes, investigate complaints, and maintain a record of communications for quality assurance and training purposes.
• Platform Improvement: To analyse anonymised usage data in aggregate to improve the pak111 Platform, optimise game loading performance for Pakistani mobile connections, and develop new features.
• Direct Communications: To send you important Account notices, transaction confirmations, security alerts, and — where you have consented — promotional offers tailored to your gaming preferences.

pak111 processes your personal data on the following legal bases, depending on the specific purpose of the processing:

• Performance of a Contract: The majority of our data processing — including Account management, transaction processing, and Platform provision — is necessary to perform the contract between you and pak111 as set out in our Terms and Conditions.
• Legal Obligation: Processing for KYC verification, anti-money laundering compliance, age verification, and regulatory reporting is required by applicable law and our operating licence conditions.
• Legitimate Interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, customer support quality assurance, and aggregate analytics serves pak111's legitimate interests and those of our players, provided these interests do not override your fundamental rights.
• Consent: Where we send you optional promotional communications or use non-essential cookies, we do so on the basis of your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing already carried out.

5.1 Principle of Minimal Sharing. pak111 shares your personal data only to the extent strictly necessary for the provision of our services, compliance with legal obligations, and protection of our players and platform. We do not sell, rent, or licence your personal data to any third party for their own marketing or commercial purposes.

5.2 Authorised Third-Party Recipients. pak111 may share your personal data with the following categories of carefully selected third-party service providers who process data on our behalf under binding data processing agreements:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK receive the minimum transaction data necessary to process your deposits and withdrawals in PKR.
• KYC Verification Providers: Certified identity verification service providers who assist with CNIC validation and AML screening. These providers are contractually prohibited from using your data for any purpose beyond the verification task.
• Game Software Providers: pak111's certified game providers may receive anonymised or pseudonymised player session data for the purpose of game performance optimisation and RNG audit compliance.
• Regulatory and Law Enforcement Authorities: Where required by our gaming licence conditions or by applicable law — including anti-money laundering reporting obligations — pak111 may disclose personal data to relevant authorities without prior notice to the data subject.
• IT and Infrastructure Providers: Secure cloud hosting and technical infrastructure providers who maintain pak111's servers and systems under strict confidentiality and security obligations.

pak111 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming licence conditions. The following retention schedule applies:

• Account and Identity Data (including CNIC): Retained for the duration of your Account and for a minimum period of five (5) years following Account closure, as required by AML compliance obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction to satisfy financial regulatory requirements.
• Support and Communication Records: Retained for three (3) years from the date of each interaction for dispute resolution, quality assurance, and legal purposes.
• Responsible Gaming Records (self-exclusion, limits): Retained for a minimum of five (5) years to prevent circumvention of self-exclusion through re-registration.
• Technical and Usage Data: Retained in anonymised aggregate form for up to two (2) years for Platform analytics and improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with pak111's data destruction procedures.

pak111 uses cookies and similar browser-based technologies on the Platform. A cookie is a small text file stored on your device by your browser when you visit a website. pak111 uses cookies for the following purposes:

• Essential Session Cookies: Required for the Platform to function — including maintaining your logged-in state, remembering your language preferences, and preserving your active game session. These cannot be disabled without affecting Platform functionality.
• Performance Cookies: Collect anonymised data about how players use the Platform — including which pages are visited most frequently and how long sessions last — to help us improve the user experience, particularly for Pakistani mobile users on variable data connections.
• Functionality Cookies: Remember your preferences such as display settings, last-visited game category, and notification preferences to personalise your experience on subsequent visits.

You can manage cookie preferences through your browser settings. Disabling essential cookies will affect your ability to remain logged into your pak111 Account. Most browsers allow you to view, manage, and delete cookies through their Privacy or Settings menus.

pak111 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration:

• Transmission Security: All data exchanged between your device and pak111's servers is encrypted using 256-bit TLS/SSL protocols. This protects login credentials, financial data, and personal information from interception during transmission.
• Storage Encryption: Personal data, including CNIC details and payment account information, is stored in encrypted form. Encryption keys are managed separately from data storage systems.
• Access Controls: Access to personal data within pak111's systems is strictly controlled on a role-based need-to-know basis. Staff with access to sensitive player data are subject to background screening and ongoing training obligations.
• Password Security: Player Account passwords are hashed using modern cryptographic algorithms before storage. pak111 does not store passwords in plain text and cannot retrieve your password — only reset it through a verified identity process.
• Fraud Monitoring: pak111 employs automated systems to detect unusual account activity — including login attempts from unfamiliar devices or locations — and will alert you via your registered mobile number where suspicious activity is detected.
• Incident Response: In the event of a data security incident that poses a significant risk to your rights, pak111 will notify affected players and, where required by applicable law, the relevant regulatory authority within the timeframe specified by our licence conditions.

Subject to applicable law and certain exceptions — including where exercise of a right would conflict with pak111's legal obligations — you have the following rights in relation to your personal data held by pak111:

• Right of Access: You may request a copy of all personal data pak111 holds about you. We will provide this in a structured, commonly used format within a reasonable timeframe. Available
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct it. For CNIC or identity data corrections, supporting documentation may be required. Available
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where processing was unlawful. This right is subject to our legal retention obligations — we cannot delete transaction records required by AML regulations. Available (subject to retention obligations)
• Right to Restrict Processing: You may request that we limit how we use your data in certain circumstances — for example, while the accuracy of data is under dispute. Available
• Right to Data Portability: Where processing is based on consent or contract and is carried out by automated means, you may request your data in a machine-readable format for transfer to another service provider. Available
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. Where you object to marketing, we will cease all marketing communications immediately. Available
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal. Available

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Rights Request," stating the specific right you wish to exercise and the data to which your request relates. pak111 will acknowledge your request within 48 hours and respond substantively within thirty (30) days.

The pak111 Platform is strictly intended for individuals who are 21 years of age or older. pak111 does not knowingly collect personal data from individuals under the age of 21. Age verification through CNIC is a mandatory step in the pak111 Account verification process specifically to prevent access by minors.

In the event that pak111 discovers that personal data has been collected from an individual under the age of 21 — whether through misrepresentation during registration or any other means — the following actions will be taken immediately:

• The Account will be suspended and access to the Platform will be blocked
• All winnings associated with the Account will be forfeited
• Any deposited Real Money Funds will be returned to the payment source, subject to verification of ownership and deduction of applicable costs
• A record of the incident will be retained in accordance with our responsible gaming obligations

pak111 operates under an international gaming licence, and certain service providers — including cloud infrastructure providers and certified game software providers — may be located outside Pakistan. Where your personal data is transferred to, or accessed from, a jurisdiction outside Pakistan, pak111 ensures that appropriate safeguards are in place to maintain the protection of your data at a standard equivalent to that which applies within our operational framework.

Safeguards used by pak111 for international data transfers include:

• Contractual clauses in agreements with all third-party service providers that impose data protection obligations equivalent to those applicable under our gaming licence
• Transfer only to providers whose home jurisdiction maintains data protection standards recognised as adequate under internationally accepted frameworks
• Strict limitations on the scope of data transferred — only the minimum data necessary for the specific service function is transferred internationally

The pak111 Platform may, from time to time, contain references or links to resources hosted by third parties. pak111 does not control the content, privacy practices, or data handling of any external website or platform, and this Privacy Policy does not apply to any external sites you may access through links from the pak111 Platform.

pak111 is not responsible for the privacy or security practices of any third party, and we encourage you to review the privacy policy of any external platform before submitting personal data to it. The presence of a link or reference on the pak111 Platform does not constitute an endorsement by pak111 of that external platform's privacy practices.

13.1 Consent-Based Marketing. pak111 will only send you promotional communications — including bonus offers, deposit match notifications, VIP tier updates, and cricket betting market alerts — where you have expressly consented to receive such communications during registration or through your Account preferences. Marketing messages are sent to your registered Pakistani mobile number via SMS or in-Platform notification.

13.2 Opting Out. You may withdraw consent for marketing communications at any time through one of the following methods:

• Updating your notification preferences in your pak111 Account settings
• Replying "STOP" to any SMS marketing message received from pak111
• Contacting pak111 support at [email protected] with the subject line "Marketing Opt-Out"

Withdrawal of marketing consent does not affect your ability to use the pak111 Platform or receive transactional communications — such as deposit confirmations, withdrawal notices, and security alerts — which are not marketing and cannot be disabled.

13.3 No Third-Party Marketing. pak111 does not share your personal data with third parties for the purpose of those third parties sending you marketing communications. Your contact details will never be passed to an advertising network, affiliate, or partner for their own marketing use.

pak111 reserves the right to update, amend, or replace this Privacy Policy at any time. Where changes are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — pak111 will notify you in advance of the changes taking effect through one or more of the following methods:

• An in-Platform notification visible upon your next login to pak111
• An SMS notification to your registered mobile number where the change is significant enough to warrant direct contact
• A clear notice on the Privacy Policy page indicating that changes have been made and the date on which they took effect

Your continued use of the pak111 Platform after any revised Privacy Policy takes effect constitutes your acknowledgement of the revised Policy. The effective date at the top of this page always reflects the date of the most recent review. We encourage you to revisit this Policy periodically.

For any questions, concerns, or requests relating to this Privacy Policy or to the personal data pak111 holds about you, please contact us using the details below. We take all privacy enquiries seriously and aim to respond to all written requests within the timeframes stated in Section 9.

• Data Protection Enquiries (Email): [email protected] — Subject line: "Privacy Enquiry" or "Data Rights Request"
• Live Chat: Available 24 hours a day, 7 days a week within your pak111 Account. For privacy and data rights enquiries raised via live chat, agents will route your case to the data protection team and provide a written response via email within the applicable timeframe.
• Complaints: If you believe pak111 has handled your personal data in a manner that violates this Privacy Policy or applicable data protection law, you have the right to lodge a complaint with the relevant supervisory authority under our operating licence. Contact pak111 support for details of the applicable authority.