Privacy Policy
At 92pakk, your privacy is not a formality — it is a fundamental commitment. This Privacy Policy explains in plain, formal English exactly what personal data we collect, why we collect it, how we use and protect it, and what rights you have as a user of our platform.
Privacy at a Glance
A plain-English summary of our most important privacy commitments. The full policy below is the definitive text.
We Never Sell Your Data
Your personal information is never sold, rented or traded to any third party for commercial or marketing purposes. Full stop. Data sharing is limited strictly to operational necessity and legal obligation.
Encrypted & Secured
All data transmitted between your device and the 92pakk platform is protected using industry-standard TLS encryption. Sensitive stored data is encrypted at rest using current best-practice cryptographic standards.
You Control Your Data
You have the right to access, correct, restrict, port and request deletion of your personal data. We respond to all data subject requests within 30 days. Your rights are detailed in full in Section 9 of this Policy.
Data Kept Only as Long as Needed
We retain personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable law or regulatory obligation. Retention periods for each category are explained in Section 7.
Transparent Cookie Use
We use cookies and similar tracking technologies for platform functionality, analytics and session management. We do not use cookies to build third-party advertising profiles. Cookie preferences can be managed in your browser settings.
Pakistan-Relevant Compliance
Our data practices are informed by international standards. We acknowledge that Pakistan's Personal Data Protection Act (PDPA) framework is developing and we commit to aligning with applicable requirements as they come into force.
Contents
- 1. Introduction
- 2. Definitions
- 3. Data Controller
- 4. Data We Collect
- 5. Data Processing & Legal Basis
- 6. Data Sharing
- 7. Data Retention
- 8. Security Measures
- 9. Your Rights
- 10. Cookies & Tracking
- 11. Minors & Age Policy
- 12. International Data Transfers
- 13. Third-Party Links
- 14. Policy Amendments
- 15. Contact Us
1Introduction
92pakk ("we", "us", "our", "the Platform") is an English-language online betting and casino information platform operating at https://92pakk.cam, designed primarily for users in Pakistan. We are committed to handling your personal information responsibly, transparently and in compliance with applicable data protection principles.
This Privacy Policy ("Policy") describes how 92pakk collects, uses, stores, shares and protects personal data obtained through your use of the Platform. It also describes the rights you hold over your personal data and the mechanisms available to exercise them.
This Policy applies to all users of the 92pakk Platform, including visitors who browse without registering, registered account holders and any individuals who communicate with us through our support channels. By accessing or using the Platform, you acknowledge that you have read and understood this Policy.
Note for Pakistani Users: Pakistan's data protection regulatory framework is developing. While the Personal Data Protection Act (PDPA) and associated regulations continue to evolve, 92pakk commits to aligning its data practices with applicable requirements. This Policy reflects our current practices and will be updated as relevant legislation comes into force. This document does not constitute legal advice — users are encouraged to seek independent counsel regarding their rights under Pakistani law.
2Definitions
In this Privacy Policy, the following terms carry the meanings set out below:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person, including name, CNIC number, email address, IP address, device identifiers and financial account details. |
| "Processing" | Any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction. |
| "Data Subject" | The natural person to whom Personal Data relates — in this context, you, the user of the Platform. |
| "Data Controller" | The entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, 92pakk acts as Data Controller. |
| "Data Processor" | A third party that processes Personal Data on behalf of the Data Controller, under contractual instruction and bound by data protection obligations. |
| "Cookies" | Small text files placed on your device by the Platform to enable functionality, remember preferences and collect analytics data. |
| "KYC" | Know Your Customer — the identity and source-of-funds verification process required under applicable regulatory frameworks. |
3Data Controller Identity
For the purposes of applicable data protection law, 92pakk is the Data Controller responsible for the Personal Data collected and processed through the Platform. All enquiries, requests and complaints relating to the processing of your Personal Data should be directed to our support team using the contact details provided in Section 15 of this Policy.
Where 92pakk engages third-party Data Processors — such as payment processors, identity verification providers or analytics service providers — we do so under written data processing agreements that impose obligations equivalent to those we accept under this Policy. We remain responsible for ensuring that any Data Processor engaged by us handles your Personal Data appropriately.
4Data We Collect
92pakk collects Personal Data in the following categories, depending on the nature of your interaction with the Platform:
4.1 Data Provided Directly by You
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, CNIC or passport number, nationality | Account registration; KYC verification |
| Contact Data | Email address, residential address (including city: Karachi, Lahore, Islamabad etc.), phone number | Account registration; support communications |
| Financial Data | Bank account details, mobile wallet identifiers (e.g., Easypaisa or JazzCash account numbers), transaction history | Deposit and withdrawal processing |
| Verification Documents | Copies of CNIC, passport, utility bills, bank statements | KYC compliance; withdrawal verification |
| Communications Data | Support chat transcripts, email correspondence, feedback submissions | Whenever you contact our support team |
4.2 Data Collected Automatically
| Category | Examples | When Collected |
|---|---|---|
| Technical Data | IP address, browser type and version, operating system, device type and identifiers | Every Platform visit |
| Usage Data | Pages visited, time spent on pages, navigation paths, search queries, referring URLs | Every Platform visit |
| Session Data | Login timestamps, session duration, active game categories, betting activity logs | While logged in to your Account |
| Cookie Data | Session identifiers, preference settings, analytics identifiers | As described in Section 10 |
We do not collect sensitive categories of Personal Data — such as racial or ethnic origin, political opinions, religious beliefs, health data or biometric data — except where strictly required for regulatory compliance and with your explicit consent.
5Data Processing & Legal Basis
We process your Personal Data only where we have a valid legal basis to do so. The following table summarises our primary processing activities and the corresponding legal basis for each:
| Processing Purpose | Legal Basis |
|---|---|
| Account registration and management | Performance of contract — necessary to provide account services you have requested. |
| Identity verification (KYC) | Legal obligation — required to comply with anti-money laundering (AML) regulations and the Operator's licensing conditions. |
| Processing deposits and withdrawals | Performance of contract — necessary to execute financial transactions you have authorised. |
| Fraud prevention and security monitoring | Legitimate interests — protecting the Platform, other users and ourselves from fraudulent or malicious activity. |
| Customer support communications | Performance of contract and legitimate interests — necessary to respond to your enquiries and maintain service quality. |
| Analytics and platform improvement | Legitimate interests — understanding how the Platform is used to improve functionality and user experience. |
| Responsible gambling monitoring | Legal obligation and legitimate interests — identifying patterns that may indicate problem gambling to fulfil our duty of care. |
| Sending service-related communications | Performance of contract — necessary to inform you of account changes, security alerts and transaction confirmations. |
| Sending promotional communications | Consent — only where you have affirmatively opted in to receive marketing content. Withdrawal of consent does not affect prior processing. |
6Data Sharing
92pakk does not sell, rent or trade your Personal Data to any third party for their own commercial or marketing purposes under any circumstances. We may share your Personal Data with third parties only in the following limited circumstances:
6.1 Service Providers and Data Processors
We engage trusted third-party service providers to support the operation of the Platform. These include payment processing companies, identity verification providers, cloud hosting providers, analytics platforms and customer support tooling vendors. Each provider is engaged under a written Data Processing Agreement and is permitted to use your data solely for the purpose of providing services to 92pakk.
6.2 The Operator
Where you access betting or gaming functionality through 92pakk, the licensed Operator of those services will receive the Personal Data necessary to create and manage your betting account, process transactions and comply with their own regulatory obligations. The Operator operates under its own privacy policy, which you should review independently.
6.3 Legal and Regulatory Disclosure
We may disclose your Personal Data to courts, regulatory authorities, law enforcement agencies or other competent bodies where we are legally required to do so, or where disclosure is necessary to protect the rights, property or safety of 92pakk, our users or the public.
6.4 Business Transfers
In the event of a merger, acquisition, reorganisation or sale of all or substantially all of the assets of 92pakk, your Personal Data may be transferred to the successor entity. You will be notified of any such transfer and your rights under this Policy will continue to apply.
Payment Provider Clarification: When we reference Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah in the context of payment processing, we do so as familiar contextual examples for Pakistani users only. None of these providers endorse, affiliate with or support 92pakk or any gambling activity. Their involvement is limited to executing financial transactions you initiate, and they operate under their own independent privacy policies and terms of service.
7Data Retention
92pakk retains your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, or to resolve disputes and enforce our agreements. The following retention periods apply as a general guide:
| Data Category | Retention Period |
|---|---|
| Account and Identity Data | Duration of account plus 5 years following account closure, to comply with AML and regulatory requirements. |
| Financial Transaction Records | 7 years from the date of each transaction, in accordance with standard financial record-keeping obligations. |
| KYC Verification Documents | 5 years following account closure or the end of the business relationship. |
| Support Communications | 3 years from the date of the last communication, for quality assurance and dispute-resolution purposes. |
| Technical and Usage Data | Up to 24 months, used for platform analytics and security monitoring. |
| Cookie Data | Session cookies expire when you close your browser. Persistent cookies expire as described in Section 10. |
Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised so that it can no longer be linked to an identifiable individual.
8Security Measures
92pakk implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include, but are not limited to:
- Transport Layer Security (TLS): All data transmitted between your device and our servers is encrypted using current TLS standards.
- Encryption at Rest: Sensitive stored data, including KYC documents and financial data, is encrypted using AES-256 or equivalent standards.
- Access Controls: Access to Personal Data is restricted on a strict need-to-know basis. Internal access is managed through role-based access controls and logged for audit purposes.
- Two-Factor Authentication (2FA): Available and recommended for all user accounts to prevent unauthorised access.
- Regular Security Audits: Our systems are subject to regular vulnerability assessments and security reviews.
- Incident Response: We maintain a documented data breach response plan. In the event of a breach likely to result in a risk to your rights and freedoms, we will notify affected users and relevant authorities within the timeframes required by applicable law.
No security system is completely impenetrable. While we apply industry-standard measures, we cannot guarantee absolute security against all threats. You play an important role in protecting your own data by maintaining strong, unique passwords and not sharing your login credentials with any third party.
9Your Data Rights
Depending on applicable data protection law in your jurisdiction, you may hold some or all of the following rights in relation to your Personal Data held by 92pakk. We will respond to all verified data subject requests within 30 calendar days. Where a request is complex or numerous, we may extend this period by a further 30 days with prior notification.
Right of Access
Request a copy of the Personal Data we hold about you and information about how we process it.
Right to Rectification
Request correction of inaccurate or incomplete Personal Data held in your account records.
Right to Erasure
Request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal obligations.
Right to Restriction
Request that we restrict the processing of your Personal Data in certain circumstances — for example, while accuracy is being contested.
Right to Data Portability
Request your Personal Data in a structured, commonly used and machine-readable format for transmission to another data controller.
Right to Object
Object to processing based on legitimate interests, including profiling, and to direct marketing communications at any time.
Right to Withdraw Consent
Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of prior processing.
Right to Lodge a Complaint
Where applicable, lodge a complaint with a competent supervisory authority if you believe your data rights have not been respected.
To exercise any of these rights, please contact our support team using the details in Section 15. We will require verification of your identity before processing any request to protect against unauthorised access to your data.
10Cookies & Tracking Technologies
10.1 What Cookies We Use
92pakk uses the following categories of cookies and similar technologies on the Platform:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Enable core Platform functionality: session management, login authentication, security tokens. | Session (deleted on browser close) |
| Functional / Preference | Remember your language preferences, currency display and layout settings. | Up to 12 months |
| Analytics | Collect aggregated usage data to understand how users navigate the Platform and identify areas for improvement. Data is anonymised where possible. | Up to 24 months |
10.2 Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. Note that disabling strictly necessary cookies may impair your ability to use core Platform functionality, including logging in and maintaining a session. Disabling analytics cookies will not affect your use of the Platform but may reduce our ability to improve the service over time.
We do not use cookies to build advertising profiles or serve targeted third-party advertisements.
11Minors & Age Policy
92pakk is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals under the age of 18 (or the higher minimum age required by the Operator's license jurisdiction). Our registration process includes an age declaration requirement and, where necessary, age verification through KYC documentation.
If we discover that Personal Data has been collected from a minor, we will take immediate steps to delete that data from our systems and close the associated account. Any parent or guardian who believes their minor child has accessed or registered on the Platform is encouraged to contact our support team immediately at the details provided in Section 15.
🔞 Adults Only: This Platform is intended solely for adults aged 18 or older, or the higher minimum age required by the Operator's licensing jurisdiction. Being 18 or older does not, in itself, confirm that accessing gambling content is lawful in Pakistan — users must independently ensure compliance with applicable Pakistani law.
12International Data Transfers
92pakk operates in an international environment and may transfer your Personal Data to countries outside Pakistan for processing and storage. Such countries may include those where our technology infrastructure providers and the Operator maintain data centres.
Where Personal Data is transferred internationally, we take steps to ensure that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under applicable data protection law. These safeguards may include:
- Contractual data protection clauses in agreements with international service providers.
- Transfer to jurisdictions recognised as providing an adequate level of data protection.
- Binding corporate rules where applicable within group entities.
You may request further information about the specific safeguards applied to international transfers of your Personal Data by contacting us at the details in Section 15.
13Third-Party Links
The 92pakk Platform may contain references or contextual information relating to third-party services, such as payment providers (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) and sports organisations (Pakistan cricket, PSL, ICC). These references are for informational context only — 92pakk does not embed outbound links to third-party websites on this Platform, and no endorsement of or affiliation with any third party is implied by their mention.
If you independently navigate to any third-party website, 92pakk has no control over and accepts no responsibility for the privacy practices or content of those websites. We encourage you to review the privacy policy of any external service you engage with.
14Policy Amendments
92pakk reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or the services we provide. The effective date of the most recent update is displayed at the top of this page.
Where amendments are material — for example, where we intend to process your Personal Data for a new purpose — we will notify you in advance by email or by a prominent notice on the Platform. Your continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised Policy.
We encourage you to review this Policy periodically to stay informed about how we are protecting your data.
15Contact Us
If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how 92pakk handles your Personal Data, please contact us using the details below. All data-related enquiries are handled by our support team with dedicated attention to privacy matters.
Data Enquiries — Contact Details
Email:
[email protected]
Platform:
https://92pakk.cam
Response Time:
We acknowledge all privacy-related requests within 5 business days and provide a substantive response within 30 calendar days. Complex requests may require an extension of up to an additional 30 days, for which we will provide prior notification.
Support Hours:
24 hours a day, 7 days a week — English and Urdu assistance available.
If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the relevant data protection supervisory authority in the jurisdiction applicable to your situation.
Your Privacy is Protected at 92pakk
Now that you understand how we handle your data, explore the rest of the 92pakk platform — cricket guides, sports betting education, responsible gambling tools and more, all built for Pakistani players.