92pke Privacy Policy

Introduction

92pke ("we", "us" or "our") operates the website accessible at https://92pke.cam (the "Platform"). This Privacy Policy explains how 92pke collects, uses, stores, shares and protects personal data relating to users ("you" or "your") of the Platform.

This Policy applies to all personal data processed by 92pke in connection with the Platform, including data collected during account registration, identity verification (KYC), payment processing, use of responsible gambling tools, and general browsing of the site.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described in this Policy, please discontinue use of the Platform. This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform more broadly.

Definitions

In this Privacy Policy, the following terms carry the meanings set out below:

Data Controller Identity

92pke acts as the Data Controller in respect of personal data collected through the Platform. As Data Controller, 92pke is responsible for ensuring that your personal data is processed lawfully, fairly and transparently in accordance with this Privacy Policy and applicable data protection law.

For any data-related enquiries, requests to exercise your rights, or concerns about how your personal data is handled, please contact us using the details in Section 17 of this Policy. All correspondence must be submitted in English.

Personal Data We Collect

Depending on how you interact with the Platform, 92pke may collect the following categories of personal data:

4.1 Account & Registration Data

• Full name as it appears on your identity document;
• Date of birth (for age verification purposes);
• Email address;
• Mobile phone number;
• Username and hashed password;
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar).

4.2 Identity Verification (KYC) Data

• Scanned copy or photograph of a valid Computerised National Identity Card (CNIC) or passport;
• Proof of address document (where required);
• Selfie or liveness-check image to confirm document authenticity.

4.3 Financial & Transaction Data

• Deposit and withdrawal transaction records (amounts in PKR or other supported currency);
• Payment method type (for example, bank transfer reference or digital wallet identifier — such as Easypaisa, JazzCash or Raast account reference, for transaction matching purposes only);
• Bonus activation and wagering records.

Note: Payment method names (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are referenced for transaction-record purposes only. Their mention here does not imply endorsement, affiliation or support of gambling by those providers.

4.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system and browser;
• Session duration, pages visited and features accessed;
• Referral URL and search terms used to reach the Platform;
• Cookie identifiers and similar tracking technologies.

4.5 Communications Data

• Content of support communications submitted via email;
• Feedback, complaint or enquiry records;
• Marketing preference selections (opt-in / opt-out records).

4.6 Responsible Gambling Data

• Self-exclusion requests and status;
• Deposit, loss and session time limits set by the user;
• Responsible gambling tool usage history.

How We Collect Your Data

92pke collects personal data through the following means:

Legal Basis for Processing

92pke processes personal data on one or more of the following legal bases, depending on the purpose of processing:

• Contractual Necessity: Processing required to perform the contract with you — including account creation, payment processing and KYC verification;
• Legal Obligation: Processing required to comply with applicable law, including anti-money laundering (AML) requirements, age verification obligations and law-enforcement data-retention mandates;
• Legitimate Interests: Processing necessary for 92pke's legitimate business interests — including fraud prevention, platform security, product improvement and responsible gambling monitoring — where those interests are not overridden by your privacy rights;
• Consent: Processing based on your explicit consent, primarily for optional marketing communications. You may withdraw consent at any time by contacting us as described in Section 17.

How We Use Your Personal Data

92pke uses your personal data for the following purposes:

7.1 Account Management

To create, operate and maintain your account; to authenticate you when you log in; and to communicate important account-related information to you.

7.2 Identity Verification & Compliance

To verify your identity and age as required by applicable operator requirements and anti-money laundering (AML) obligations; to prevent and detect fraud, money laundering and other financial crime; and to comply with law-enforcement requests where legally required.

7.3 Payment Processing

To process deposits and withdrawals, to maintain transaction records as required by applicable law, and to reconcile payment discrepancies.

7.4 Responsible Gambling

To facilitate deposit limits, loss limits, session time reminders, cool-off periods and self-exclusion requests; and to identify and act on indicators of problem gambling behaviour consistent with our responsible gambling obligations.

7.5 Platform Operation & Improvement

To monitor, maintain and improve the technical performance, security and content quality of the Platform; to analyse usage patterns to understand how Pakistani users engage with different content sections; and to resolve technical issues.

7.6 Customer Support

To respond to your enquiries, support requests and complaints; to maintain records of communications for quality assurance purposes; and to provide support in English and Urdu as appropriate.

7.7 Marketing (Consent-Based Only)

To send you promotional communications about 92pke, upcoming offers or relevant platform updates — only where you have given your explicit consent to receive such communications. You may opt out at any time. 92pke does not send unsolicited marketing messages.

Sharing & Disclosure of Personal Data

92pke does not sell, rent or trade your personal data. We may share your data in the following limited circumstances:

8.1 Service Providers (Data Processors)

We may share personal data with trusted third-party service providers who process data on our behalf under written data-processing agreements. These may include KYC and identity verification providers, payment processing providers, cloud infrastructure providers and customer support platforms. All processors are required to maintain appropriate security standards and to use your data only for the purposes for which it was shared.

8.2 Legal & Regulatory Disclosure

We may disclose personal data to law enforcement agencies, regulatory bodies or other authorities where required by applicable law, court order or legal process. We will notify you of such disclosures where legally permitted to do so.

8.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or a material part of 92pke's assets, personal data held by 92pke may be transferred to the acquiring entity. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.

8.4 Professional Advisers

We may share limited personal data with legal counsel, accountants, auditors or insurers in the course of obtaining professional advice, where those advisers are subject to obligations of confidentiality.

Your Rights as a Data Subject

Subject to applicable law, you have the following rights in relation to your personal data held by 92pke. To exercise any of these rights, contact us using the details in Section 17. We will respond within a reasonable timeframe and in any event within 30 days unless the request is unusually complex.

Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the Platform. They allow the Platform to recognise your device, remember your preferences and collect usage data. Cookies do not contain executable code and cannot access files stored on your device beyond what you allow.

10.2 Types of Cookies We Use

10.3 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that blocking strictly necessary cookies may affect the functionality of the Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

Data Retention

92pke retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal or regulatory obligations.

• Account Data: Retained for the duration of your active account relationship with 92pke, plus a period thereafter as required for legal, audit and AML compliance purposes.
• KYC & Identity Documents: Retained for the period required by applicable AML, counter-terrorism financing (CTF) and identity-verification regulations, which may extend to five or more years from the date of the last transaction.
• Transaction Records: Retained for a minimum of five years from the date of each transaction, in compliance with financial regulation requirements.
• Support Communications: Retained for a period of up to three years for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained until you withdraw consent, after which records of the consent and withdrawal are archived for compliance evidence.
• Analytics Data: Retained in anonymised or aggregated form indefinitely; identifiable session data is deleted within 24 months.

Where retention is no longer legally or operationally justified, personal data is securely deleted or irreversibly anonymised. Deletion requests submitted under your right to erasure will be processed subject to overriding legal retention requirements.

Data Security

92pke implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• HTTPS/TLS encryption for all data transmitted to and from the Platform;
• Encryption of sensitive personal data (including identity documents and financial records) at rest;
• Role-based access controls limiting data access to authorised personnel only;
• Regular security assessments and vulnerability monitoring;
• Incident response procedures for data breach detection, containment and notification.

While we take reasonable precautions, no method of internet transmission or electronic storage is 100% secure. We cannot guarantee absolute security but will notify affected users and relevant authorities promptly in the event of a significant data breach, as required by applicable law.

Children's Privacy

The Platform is strictly intended for adults aged 18 years or over — or the higher minimum age required by the applicable operator or license jurisdiction. 92pke does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor, we will delete that data promptly and close the associated account.

If you are a parent or guardian and believe that a minor has provided personal data to 92pke, please contact us immediately using the details in Section 17.

Meeting the minimum age requirement does not in itself make gambling lawful in Pakistan. Users in Pakistan must understand and comply with applicable local law, including the Prevention of Gambling Act, 1977.

International Data Transfers

92pke may process or store personal data on servers located outside Pakistan, including in jurisdictions that may have different data protection frameworks. Where personal data is transferred internationally, 92pke takes appropriate steps to ensure that the transfer is lawful and that adequate protections are in place, including:

• Entering into appropriate data transfer agreements with recipients in third countries;
• Ensuring that cloud and infrastructure providers maintain certified data security standards;
• Reviewing and updating transfer mechanisms as applicable law evolves.

By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside Pakistan. If you have concerns about international transfers of your data, please contact us using the details in Section 17.

Third-Party Links & Platforms

The Platform may contain references to third-party Operator platforms and services. 92pke is not responsible for the privacy practices of those third parties. When you click through to an Operator's platform, you leave the 92pke Platform and that Operator's own privacy policy governs the processing of your data on their site.

We encourage you to read the privacy policy of any third-party platform you visit, particularly before submitting any personal data. The mention of payment providers (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) in illustrative examples on 92pke does not mean we share data with those providers, nor does it imply any endorsement of gambling by those institutions.

Updates to This Privacy Policy

92pke reserves the right to update or revise this Privacy Policy at any time. When material changes are made, we will update the "Last updated" date displayed at the top of this page. Where required by applicable law or where changes are particularly significant, we may provide additional notice (for example, by email notification or a prominent banner on the Platform).

Your continued use of the Platform following publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. We recommend that you review this Policy periodically to stay informed about how we protect your personal data.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact 92pke using the details below. All correspondence must be submitted in English.

The email address above is for written correspondence only and is displayed as plain text. Please do not send sensitive identity documents (CNIC scans, passport copies) by email — use only the secure document upload portal within your account as directed during the KYC verification process.

To exercise any of the data subject rights described in Section 9 of this Policy, please email us with the subject line "Data Rights Request" and include your full name and registered email address so we can identify your account. We will respond within 30 days.