pk21 Privacy Policy

Section 1

Introduction

pk21 (accessible at pk21.cam, "we", "us", "our") is committed to protecting the privacy of every individual who accesses or uses our platform. This Privacy Policy ("Policy") describes how pk21 collects, uses, stores, discloses and safeguards personal data obtained from users ("you", "your") in connection with your use of the pk21 website and all associated services ("Platform").

pk21 is an English-language online gaming information platform serving adult users in Pakistan and other jurisdictions where access to such content is permitted. Our user base spans major Pakistani cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. This Policy applies to all users regardless of their location.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, both incorporated by reference.

Section 2

Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, phone number, IP address and financial data.
• "Data Controller" — pk21, which determines the purposes and means of processing your personal data.
• "Data Processor" — any third party that processes personal data on behalf of pk21 under a data-processing agreement.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure or deletion.
• "Consent" — a freely given, specific, informed and unambiguous indication of agreement to the processing of personal data.
• "Cookie" — a small text file stored on your device by a website to record information about your visit.
• "KYC" — Know Your Customer; the identity verification process required by anti-money-laundering regulations.
• "AML" — Anti-Money Laundering; legal and regulatory obligations to prevent financial crime.

Section 3

Data We Collect

pk21 collects personal data in the following categories. We collect only what is necessary for the stated purpose and do not retain data beyond the period required.

3.1 Registration Data

When you create an account, we collect:

• Full name
• Date of birth (for age verification)
• Email address
• Username and encrypted password
• Country and city of residence (e.g., Lahore, Karachi)
• Phone number (where provided)

3.2 Identity Verification (KYC) Data

To comply with AML obligations, we may request:

• Government-issued photo ID (e.g., CNIC, passport)
• Proof of address (utility bill, bank statement)
• Proof of payment method (card image, screenshot)
• Source of funds declarations (where required)

3.3 Transaction & Financial Data

We record details of deposits, withdrawals, wagers and bonus activity, including amounts, timestamps, payment methods used and transaction identifiers. We reference familiar Pakistani payment methods — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — only as processing references. These providers are not partners or endorsers of pk21.

3.4 Technical & Usage Data

We automatically collect:

• IP address and approximate geolocation
• Browser type and version
• Device type and operating system
• Pages visited, session duration and clickstream data
• Error logs and performance diagnostics

3.5 Communications Data

If you contact our support team, we retain records of your communications — including email content, live chat transcripts and any attachments you submit — for quality assurance and compliance purposes.

Section 4

Data Processing

We use your personal data for the following purposes:

Section 5

Legal Basis for Processing

pk21 processes personal data only where a valid legal basis exists. The principal legal bases we rely on are:

• Contract Performance: Processing necessary to provide the services you have requested — account creation, deposits, withdrawals and customer support.
• Legal Obligation: Processing required to comply with applicable laws, including AML/KYC regulations and responsible gambling requirements.
• Legitimate Interests: Processing for fraud prevention, platform security and analytical improvement of our services, provided such interests are not overridden by your rights.
• Consent: Processing for optional activities such as marketing communications. Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

Section 6

Data Sharing

pk21 does not sell, rent or trade your personal data to third parties for commercial purposes. We may share your data with the following categories of recipients only where strictly necessary:

6.1 Service Providers

Trusted third-party service providers who assist us in operating the Platform — including KYC verification services, payment processors, fraud-detection services, cloud hosting providers and analytics platforms. All such providers are subject to appropriate data-processing agreements and are prohibited from using your data for any purpose other than providing services to pk21.

6.2 Regulatory and Law Enforcement Authorities

We may disclose your personal data to competent regulatory, tax or law enforcement authorities where required to do so by applicable law, court order or legal process.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of pk21's business, your personal data may be transferred to the acquiring entity as part of that transaction, subject to this Policy continuing to apply.

Section 7

Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected or to comply with applicable legal and regulatory requirements. General retention periods are as follows:

• Account and registration data: Retained for the duration of your account plus a minimum of five (5) years after account closure, to satisfy AML and regulatory requirements.
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by applicable AML regulations.
• Transaction records: Retained for a minimum of five (5) years for financial and compliance purposes.
• Support communications: Retained for a minimum of three (3) years for quality assurance and dispute resolution purposes.
• Marketing data: Retained until you withdraw consent or request deletion.
• Technical and log data: Retained for up to twelve (12) months for security and diagnostics purposes.

Where retention is no longer legally required, we will securely delete or anonymise your personal data in accordance with applicable data protection standards.

Section 8

Data Security

pk21 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and our servers;
• Encrypted storage of sensitive account credentials;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing;
• Incident response procedures for data breach notification.

Section 9

Cookies & Tracking Technologies

pk21 uses cookies and similar tracking technologies to operate and improve the Platform. By continuing to use the Platform with cookies enabled in your browser, you consent to the use of cookies as described below.

9.1 Types of Cookies We Use

• Essential Cookies: Required for core Platform functionality — session management, authentication and security. These cannot be disabled without impairing Platform operation.
• Functional Cookies: Remember your preferences such as language, display settings and login state to improve your experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping us identify and resolve usability issues.
• Responsible Gambling Cookies: Used to enforce session time limits and cooling-off periods you have set on your account.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling essential cookies may prevent you from logging in or accessing certain features of the Platform. Detailed cookie management instructions are available in the help documentation of major browsers (Chrome, Firefox, Safari, Edge).

Section 10

Minors

pk21 is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator or applicable license jurisdiction. We do not knowingly collect personal data from individuals under the age of 18. If you become aware that a minor has provided personal data to pk21, please contact us immediately at [email protected] so that we can take appropriate steps to delete such data.

Section 11

User Rights

Subject to applicable data protection law and regulatory retention requirements, you hold the following rights in respect of your personal data:

11.1 Right of Access

You may request a copy of the personal data we hold about you. We will respond to verified access requests within 30 days. We may request proof of identity before fulfilling the request.

11.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Account holders may update basic profile information directly through their account settings.

11.3 Right to Erasure

You may request the deletion of your personal data. We will honour such requests where the data is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis applies. Please note that we are legally required to retain certain data (particularly AML and KYC records) for defined periods and cannot delete such data on request during that retention window.

11.4 Right to Restrict Processing

You may request that we restrict the processing of your personal data in certain circumstances — for example, where you contest its accuracy or object to our processing on grounds of legitimate interest.

11.5 Right to Data Portability

You may request a copy of personal data you have provided to us in a structured, commonly used and machine-readable format (e.g., CSV or JSON), where technically feasible and where the processing is based on consent or contract performance.

11.6 Right to Object

You may object at any time to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, in which case we will assess whether our legitimate interests override your rights.

11.7 Exercising Your Rights

To exercise any of the rights described above, please submit your request in writing to [email protected]. Please include your full name, registered email address and a description of your request. We will respond within 30 calendar days. No fee is charged for standard requests, however we reserve the right to charge a reasonable administrative fee for manifestly unfounded or repetitive requests.

Section 12

International Data Transfers

pk21 may transfer personal data to, or process it in, countries outside of Pakistan. Where such transfers occur, we take reasonable steps to ensure that appropriate safeguards are in place — including contractual protections in the form of data-processing agreements with service providers — to maintain a standard of protection consistent with applicable data protection principles.

By using pk21, you acknowledge and consent to the transfer and processing of your personal data outside Pakistan where necessary for the provision of Platform services.

Section 13

Payments & Financial Data

When you make a deposit or withdrawal through the Platform, financial transaction data is processed by third-party payment service providers. pk21 does not store full card numbers, bank account credentials or full payment instrument details on its own servers. Payment data is handled in accordance with the security standards maintained by the relevant payment processor.

Payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced as familiar Pakistani financial options. Users should consult each provider's own privacy policy for information on how their data is handled by that provider. pk21 has no control over third-party providers' data practices and does not represent that any of these providers support or endorse gambling activity.

Section 14

Amendments to This Policy

pk21 reserves the right to update this Privacy Policy at any time to reflect changes in legal requirements, platform functionality or data practices. Where changes are material, we will make reasonable efforts to notify registered users via their registered email address or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent review is displayed at the top of this page. Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree with the updated Policy, you must cease using the Platform and request account closure.

Section 15

Contact Us

For all privacy-related enquiries, data subject access requests, complaints or requests to exercise your rights under this Policy, please contact pk21 using the details below. All requests must be submitted in English and will be handled within 30 calendar days.

• Email: [email protected] — plain text, not a clickable link
• Response Time: Within 30 days for data subject requests; within 24 hours for general support queries
• Languages Supported: English (primary); Urdu available on request
• Operating Hours: 24/7 (as per operator-provided service levels)

You also have the right to lodge a complaint with the competent data protection authority in your jurisdiction if you believe your data protection rights have been infringed. This does not affect your right to seek a remedy through the courts.