pakgme Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1.1 This Privacy Policy ("Policy") is issued by pakgme ("pakgme", "we", "us", "our") and applies to all personal data collected from individuals ("you", "the Player", "the User") who access or use the pakgme Platform at pakgme.one, including all associated casino games, sports betting services, promotional facilities, customer support channels, and account management features.

1.2 pakgme is committed to protecting your privacy and handling your personal data in a manner consistent with the data protection obligations imposed by our international gaming licence and with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, accuracy, integrity, and confidentiality.

1.3 This Policy should be read alongside the pakgme Terms & Conditions, which govern your use of the Platform more broadly. Capitalised terms not defined in this Policy carry the meaning assigned to them in the Terms & Conditions.

1.4 By registering a pakgme Account, accessing the Platform, or submitting personal information to pakgme via any channel, you confirm that you have read, understood, and consented to the data practices described in this Policy.

2.1 For the purposes of applicable data protection law, pakgme — operating the online gaming platform accessible at pakgme.one — acts as the Data Controller in respect of personal data collected from Players and other users of the Platform.

2.2 As Data Controller, pakgme determines the purposes for which your personal data is processed and the means by which that processing occurs. Where pakgme engages third-party service providers to process data on its behalf (for example, payment processors or KYC verification partners), those providers act as Data Processors under contractual obligations that bind them to process your data only as instructed by pakgme and in accordance with applicable data protection law.

2.3 You may direct data protection enquiries, Subject Access Requests, and other privacy-related correspondence to the pakgme support team via live chat (24/7) or by email to [email protected].

pakgme collects the following categories of personal data in connection with the registration, operation, and security of Player Accounts on the Platform:

We do not collect full payment card numbers, CVV codes, or online banking credentials. Payment authentication occurs directly through the respective Pakistani payment provider's own secure interface.

pakgme collects personal data through the following channels and mechanisms:

• Direct submission at registration: When you complete the pakgme Account registration form, you voluntarily provide your name, date of birth, email address, and mobile number.
• KYC document upload: When you submit identity documents (CNIC, selfie) through the Account verification section to unlock withdrawal access.
• Payment transactions: When you initiate a deposit or withdrawal, the payment provider returns a transaction confirmation including the relevant payment method identifier and amount to our systems.
• Platform activity: Automatically generated data from your use of the Platform — game sessions, bets placed, account settings changes — is logged in real time by our platform systems.
• Device and browser data: Collected automatically via standard web server logging and, where applicable, first-party cookies and similar technologies placed on your device when you access the Platform.
• Customer support interactions: When you contact pakgme via live chat or email, the content of those communications is retained as part of your Account record for service quality and dispute resolution purposes.
• Third-party verification services: Where pakgme engages third-party KYC or AML compliance partners to verify identity information, data may be cross-referenced against third-party databases as permitted by applicable law.

pakgme processes your personal data on the following legal grounds, which vary depending on the specific processing activity:

• Performance of a Contract: Processing necessary for the provision of the gaming and betting services you have requested — including account management, game settlement, payment processing, and customer support.
• Legal Obligation: Processing required for compliance with our gaming licence conditions, anti-money-laundering (AML) legislation, Know Your Customer (KYC) obligations, and applicable financial crime prevention frameworks. We cannot lawfully provide our services without conducting these checks.
• Legitimate Interests: Processing for fraud prevention, account security, platform abuse detection, and the general security and integrity of our gaming environment, where such interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications — including email and SMS promotional messages about bonuses, new games, and PSL/cricket betting offers — where you have provided explicit opt-in consent. Consent may be withdrawn at any time via Account settings or by contacting support.

pakgme uses the personal data we collect for the following specific purposes:

• Account creation and management: Creating and maintaining your pakgme Account, processing login authentication (including OTP), enabling account settings changes, and managing Account closure.
• Identity and age verification (KYC): Confirming that you are who you claim to be, that you are at least 21 years of age, and that your Account details match the identity documents provided — as required by our gaming licence and AML obligations.
• Payment processing: Processing deposit credits and withdrawal payments to and from your Account via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK.
• Game and betting services: Operating the casino, sportsbook, and other gaming products accessible on the Platform, including settling bets, recording game session outcomes, and applying responsible gaming limits.
• Fraud prevention and security: Detecting and preventing account takeover, collusion, bonus abuse, money laundering, and other forms of fraudulent or prohibited activity.
• Customer support: Responding to enquiries, resolving complaints, processing responsible gaming requests, and maintaining a record of communications for quality assurance and dispute evidence purposes.
• Regulatory compliance: Fulfilling reporting obligations to our licensing authority, responding to lawful requests from regulatory or law enforcement bodies, and maintaining records as required by AML legislation.
• Marketing communications (with your consent only): Sending you promotional emails and SMS notifications about bonuses, new games, PSL promotions, and other pakgme offers — only where you have opted in. You may withdraw consent at any time.
• Responsible gaming monitoring: Monitoring gameplay patterns to identify indicators of potential problem gambling behaviour, in accordance with our responsible gaming obligations. This does not involve profiling for commercial purposes.
• Platform improvement: Analysing aggregated, anonymised usage data to improve Platform performance, game selection, and user experience.

7.1 pakgme does not sell, rent, or trade your personal data to any third party for that party's own commercial purposes. The following categories of third party may receive personal data from pakgme solely to the extent necessary for the services they provide to us:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers receive transaction data necessary to process deposits and withdrawals. Each provider processes this data under their own privacy policies and regulatory obligations.
• KYC and AML verification partners: Third-party identity verification and sanctions screening providers may receive Identity Data for the purpose of fulfilling our legal KYC and AML obligations. These providers act as Data Processors under contractual data processing agreements with pakgme.
• Game software providers: Licensed game developers whose titles are available on the pakgme Platform may receive session and gameplay data necessary for game operation and result verification. No personally identifiable information is shared with game providers beyond a pseudonymous session identifier.
• Customer support platform: The third-party live chat software used to deliver customer support retains chat transcripts. This provider is contractually bound to process data only as instructed by pakgme and not for its own purposes.
• Regulatory and law enforcement authorities: pakgme will disclose personal data to gaming regulators, financial intelligence units, law enforcement agencies, or courts where required to do so by law or by our licensing authority. We will, where legally permissible, notify you of such disclosure.

7.2 All third-party Data Processors engaged by pakgme are required to maintain appropriate technical and organisational security measures and are prohibited from using your data for purposes beyond those specified in their Data Processing Agreement with pakgme.

8.1 pakgme uses first-party cookies and similar browser-based technologies on the Platform for the following limited purposes:

• Session cookies (strictly necessary): Used to maintain your login session and keep you authenticated while you navigate the Platform. These expire when you close your browser and are necessary for the Platform to function. They cannot be disabled without preventing access to the Platform.
• Security cookies: Used for CSRF (Cross-Site Request Forgery) protection and for detecting unusual login activity from new devices or locations. These are essential security components of the Platform.
• Preference cookies: Used to remember your language settings and responsible gaming preference configurations between sessions.
• Analytics cookies (first-party only): Used to collect anonymised aggregate data on how the Platform is used — such as which pages are most visited and where users experience navigation difficulties — for the sole purpose of improving the Platform. This data is anonymised and cannot be used to identify individual users.

8.2 pakgme does not use third-party advertising cookies, social media tracking pixels, or cross-site behavioural tracking technologies on the Platform.

8.3 You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from accessing the Platform. Disabling analytics cookies will not affect your ability to use any Platform features.

9.1 pakgme retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to longer retention periods required by legal, regulatory, or contractual obligations:

9.2 Upon expiry of the applicable retention period, personal data is either securely deleted or irreversibly anonymised so that it can no longer be linked to an identifiable individual.

9.3 Where a data erasure request is made by a Player but a mandatory retention period applies to the relevant data, pakgme will inform the Player of the minimum retention obligation and the earliest date at which erasure can be effected.

As a data subject, you have the following rights with respect to your personal data held by pakgme. These rights are subject to certain conditions and limitations under applicable law:

To exercise any of these rights, contact the pakgme support team via live chat or email at [email protected]. We will verify your identity before processing any rights request to ensure we do not disclose or modify personal data in response to an unauthorised request.

11.1 pakgme implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your device and the pakgme Platform is encrypted using TLS 1.3 (256-bit). This applies to all pages, not only the login screen.
• Encryption at rest: Sensitive data fields — including CNIC numbers, payment identifiers, and personal identity information — are encrypted at the database level using AES-256 encryption.
• Password security: User passwords are never stored in plaintext. All passwords are processed through a strong cryptographic hashing algorithm with individual salting before storage. pakgme staff cannot retrieve passwords.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff with access to personal data undergo background screening and are bound by confidentiality obligations.
• Intrusion detection: The Platform operates continuous monitoring for unusual access patterns, brute-force login attempts, and other indicators of account compromise or data exfiltration attempts.
• Regular security audits: pakgme engages independent third-party security specialists to conduct platform penetration testing and security assessments on a quarterly basis.

11.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pakgme will notify affected individuals without undue delay and in accordance with our obligations to our licensing authority.

12.1 Registration on the pakgme Platform requires confirmation that the registering individual is at least 21 years of age. Age is further verified through the KYC process via CNIC submission, which carries a date of birth field that pakgme verifies against the declared age at registration.

12.2 If pakgme discovers or is notified that personal data has been collected from a person under the age of 21, all such data will be immediately and securely deleted, the associated Account will be permanently closed, and any deposits will be refunded to the originating payment method where technically possible.

12.3 Parents or guardians who believe a minor has registered a pakgme Account should contact our support team immediately via live chat or email so that the Account can be investigated and closed without delay.

13.1 pakgme reserves the right to update or amend this Privacy Policy at any time. The current version is always accessible at pakgme.one/privacy-policy, with the "Last Updated" date prominently displayed at the top of the document.

13.2 Where changes to this Policy are material — meaning they significantly affect how we use your personal data or materially alter your privacy rights — pakgme will provide notice to registered Players via the email address associated with their Account at least 14 calendar days before the changes take effect.

13.3 Minor changes — such as typographical corrections, clarifications that do not alter the substance of the Policy, or updates required to reflect routine operational changes — may be implemented without advance notice.

13.4 Your continued use of the Platform following the effective date of any material Policy amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the changes, you should close your Account before the effective date and withdraw any remaining verified balance.