Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 98pkp ("we", "us", "our" or "the Platform"), accessible at https://98pkp.cam, collects, uses, stores, shares and protects personal data relating to users of the Platform ("you", "your" or "User"). 98pkp is an English-language online gaming information and entertainment platform with a primary focus on Pakistani users.

We are committed to handling your personal data responsibly, transparently and in accordance with applicable data protection principles. By registering an account on the Platform or otherwise using our services, you acknowledge that you have read and understood this Policy and consent to the data processing activities described herein.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together govern your use of the Platform.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information that directly or indirectly identifies a natural person, including but not limited to name, date of birth, email address, phone number, payment details and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 98pkp.
• "Data Processor" means a third party that processes Personal Data on behalf of 98pkp in accordance with written instructions.
• "Consent" means freely given, specific, informed and unambiguous agreement by a User to the processing of their Personal Data.
• "KYC" means Know Your Customer — identity and document verification procedures applied for compliance and anti-money laundering purposes.
• "Cookies" means small text files placed on your device by a website to store information about your preferences and browsing activity.
• "Sensitive Data" means Personal Data requiring enhanced protection, such as financial information, identity documents and verification data.

3. Data We Collect

We collect the following categories of personal data in connection with your use of the Platform:

3.1 Registration and Identity Data

• Full legal name;
• Date of birth;
• Residential address (including city — for example, Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar);
• Email address;
• Contact phone number;
• Username and password (stored in encrypted form).

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., CNIC, passport);
• Proof of address documentation;
• Payment method verification documentation;
• Selfie or biometric verification data where required for KYC compliance.

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• Payment method details (reference only — we do not store full card numbers);
• Account balance history and betting activity records.

3.4 Usage and Technical Data

• IP address and approximate geolocation;
• Device type, operating system and browser information;
• Session duration, pages visited and features used;
• Login timestamps and security event logs.

3.5 Communications Data

• Records of communications with our support team via Live Chat, email or Help Center;
• Survey responses and feedback submissions.

4. How We Collect Your Data

We collect Personal Data through the following means:

Collection Method	Description
Direct Registration	Data you provide when creating an account, completing KYC verification or updating your profile.
Platform Activity	Data generated automatically as you use the Platform, including bets placed, games accessed and session activity.
Deposits & Withdrawals	Transaction data captured when you fund your account or request withdrawals.
Support Interactions	Data shared when you contact our support team through Live Chat, email or the Help Center.
Cookies & Tracking	Technical data collected through cookies and similar tracking technologies as described in Section 8.
Third-Party Verification	Identity and fraud-prevention data received from third-party KYC and compliance service providers.

5. Legal Basis for Processing

We process your Personal Data on one or more of the following legal grounds:

• Contractual Necessity: Processing is required to perform the contract between you and 98pkp — for example, creating your account, processing deposits and withdrawals, and administering your betting activity.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including KYC, anti-money laundering (AML) and responsible gambling obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, service improvement and analytics — provided these interests are not overridden by your rights.
• Consent: Where we rely on your consent for a specific processing activity (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

6. How We Use Your Data

We use the Personal Data we collect for the following purposes:

• Creating and managing your 98pkp account;
• Processing deposits, withdrawals and gaming transactions;
• Conducting identity verification (KYC) and anti-money laundering (AML) compliance checks;
• Enforcing our Terms & Conditions and Responsible Gambling Policy;
• Detecting, investigating and preventing fraud, collusion and prohibited conduct;
• Providing customer support in English (and Urdu where requested);
• Sending transactional communications (account notifications, security alerts, withdrawal confirmations);
• Sending promotional communications where you have given valid consent, and subject to applicable marketing preferences;
• Analysing platform usage to improve user experience and service quality;
• Monitoring and enforcing responsible gambling obligations, including activation of self-exclusion and limit controls;
• Complying with applicable legal, regulatory and reporting obligations.

7. Data Sharing & Disclosure

7.1 We Do Not Sell Your Data

98pkp does not sell, rent or trade your Personal Data to third parties for marketing or commercial purposes. Any sharing of your data occurs solely in the circumstances described below.

7.2 Service Providers and Data Processors

We share Personal Data with carefully selected third-party service providers who act as Data Processors on our behalf. These providers assist with KYC verification, payment processing, fraud detection, analytics and platform infrastructure. All processors are bound by contractual obligations to process data only on our instructions and to maintain appropriate security standards.

7.3 Legal and Regulatory Disclosure

We may disclose your Personal Data to law enforcement authorities, regulators or other government bodies where required by applicable law or where we have a good-faith belief that disclosure is necessary to comply with a legal obligation, protect the rights or safety of 98pkp or third parties, or investigate fraud or illegal activity.

7.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of our business, your Personal Data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and applicable privacy rights via a notice on the Platform.

7.5 Aggregated and Anonymised Data

We may share aggregated, anonymised or pseudonymised data with partners or for public reporting purposes. Such data does not identify individual users and is not subject to this Policy's sharing restrictions.

8. Cookies & Tracking Technologies

98pkp uses cookies and similar tracking technologies (including web beacons and local storage) to provide, maintain and improve the Platform. The categories of cookies we use are as follows:

Cookie Type	Purpose	Can Be Disabled?
Strictly Necessary	Required for core platform functions — session management, login authentication and security. The Platform cannot function properly without these.	No
Functional	Remember your preferences such as language settings, display preferences and session continuity.	Yes
Analytical	Collect anonymised usage data to help us understand how users interact with the Platform and identify areas for improvement.	Yes
Marketing	Track browsing activity to deliver relevant promotional content where consent has been provided.	Yes

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Refer to your browser's help documentation for instructions on cookie management.

9. Data Retention

We retain your Personal Data only for as long as is necessary for the purposes described in this Policy, unless a longer retention period is required by applicable law or regulatory obligation. The following general retention guidelines apply:

• Active Account Data: Retained for the duration of your account and for a minimum period thereafter as required by applicable compliance obligations;
• KYC and Identity Verification Records: Retained for a minimum of five (5) years following the closure of your account, in accordance with standard AML and compliance requirements;
• Transaction and Betting Records: Retained for a minimum of five (5) years following the relevant transaction, subject to applicable regulatory requirements;
• Support Communications: Retained for up to three (3) years following the closure of the relevant support interaction;
• Marketing Consent Records: Retained until you withdraw your consent or for as long as reasonably necessary to demonstrate that consent was obtained.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

10. Data Security

98pkp implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• Industry-standard SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encrypted storage for sensitive account credentials including passwords;
• Access controls limiting data access to authorised personnel with a documented need;
• Regular security reviews and vulnerability assessments;
• Two-factor authentication (2FA) options available to Users for account protection.

No system is entirely immune to security risks. In the event of a data breach that is likely to result in significant risk to your rights and freedoms, we will notify you and relevant authorities in accordance with applicable legal requirements.

11. International Data Transfers

As an online platform serving a global user base, your Personal Data may be transferred to and processed in countries other than Pakistan. Where such transfers occur, we take appropriate steps to ensure that your data receives an adequate level of protection, including through the use of contractual safeguards with receiving parties.

By using the Platform, you acknowledge that your data may be processed in jurisdictions that have different data protection laws from those in Pakistan. We remain committed to applying our data protection standards regardless of where processing occurs.

12. Your Data Rights

Subject to applicable law and our legal obligations, you have the following rights with respect to your Personal Data:

• Right of Access: You may request a copy of the Personal Data we hold about you;
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data;
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal obligations to retain certain data;
• Right to Restrict Processing: You may request that we limit processing of your data in specific circumstances;
• Right to Data Portability: You may request that we provide your data in a structured, machine-readable format;
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes;
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team via Live Chat or email. We will respond to verified requests within a reasonable timeframe and in accordance with applicable obligations. We may need to verify your identity before processing certain requests.

13. Children's Privacy

The Platform is strictly intended for adults aged 18 years and over, or the higher minimum age required by the operator/license jurisdiction. We do not knowingly collect Personal Data from individuals under the age of 18. If we become aware that we have inadvertently collected Personal Data from a minor, we will take prompt steps to delete that data and close the relevant account.

If you are a parent or guardian and believe that a minor has registered on the Platform, please contact us immediately through Live Chat or at the email address listed in Section 16.

14. Third-Party Links and Services

The Platform does not include outbound links to third-party websites. However, our payment processing and KYC services involve interactions with third-party service providers who have their own privacy policies. 98pkp is not responsible for the privacy practices of third-party processors beyond the contractual protections we have in place with them.

Payment method names referenced on the Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are cited as familiar Pakistani payment rails for contextual reference only. Their respective privacy policies govern how they handle data in connection with transactions made through their systems.

15. Changes to This Privacy Policy

98pkp reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will provide notice through the Platform — for example, by displaying a prominent notice upon login or by updating the "Last Updated" date at the top of this page. Your continued use of the Platform following any amendment to this Policy constitutes your acceptance of the updated terms.

We encourage you to review this Policy periodically. If you do not agree with changes to this Policy, you should discontinue using the Platform and contact us to close your account.

16. Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the way we handle your Personal Data, please contact us through the following channels:

• Live Chat: Available 24/7 directly from the Platform dashboard — the fastest way to raise a data query;
• Help Center: Accessible from the Platform's support section — contains detailed guidance on account data and privacy settings;
• Email: [email protected] (plain text — not a clickable link)

For requests related to your data rights under Section 12, please include sufficient detail to allow us to verify your identity and locate the relevant records. We aim to respond to all data-related enquiries within 30 days of receipt, unless a shorter timeframe is required by applicable law.