Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how pakgim ("Platform", "we", "us", "our"), operating at pakgim.cam, collects, uses, discloses, retains and protects the personal data of individuals ("User", "you", "your") who access or use our Platform, including our website, services and any related features.

By registering an account, depositing funds or otherwise using the pakgim Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy applies to all personal data collected through:

• Account registration and the Know Your Customer (KYC) verification process;
• Deposits, withdrawals and related payment transactions;
• Your use of sportsbook, live casino and other gaming features;
• Communications with our customer support team;
• Technical data generated through your use of the Platform (device, browser, connection data).

2. Definitions

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

• "Personal Data" means any information that can directly or indirectly identify a natural person, including name, CNIC number, email address, phone number, IP address and financial account details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the Operator entity responsible for determining the purposes and means of processing Personal Data collected through the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of the Data Controller under a contractual agreement.
• "Cookies" means small data files placed on your device by the Platform to support session management, analytics and personalisation features.
• "KYC" means Know Your Customer — the identity and age verification process required before a User may access full Platform functionality.
• "Sensitive Data" means Personal Data that warrants a higher level of protection, including financial information, identification documents and data related to problem gambling or self-exclusion status.

3. Personal Data We Collect

3.1 Registration Data

When you create an account on pakgim, we collect the following information:

• Full legal name;
• Date of birth (for age verification);
• Email address;
• Phone number;
• Residential address;
• Username and password (passwords are stored in hashed, non-reversible form).

3.2 Identity Verification (KYC) Data

To comply with anti-money-laundering (AML) obligations and to verify that you meet the minimum age requirement, we may request and retain:

• A copy of a valid government-issued identification document, such as a National Identity Card (CNIC), passport or driving licence;
• A proof of residential address document (utility bill, bank statement or similar, dated within 90 days);
• Source-of-funds documentation in cases where regulatory requirements or risk-based assessment so require.

3.3 Financial Transaction Data

We collect data related to your deposits and withdrawals, including:

• Transaction amounts, dates and reference numbers;
• Payment method details (such as bank account identifiers, mobile wallet references for familiar Pakistani payment rails including Easypaisa, JazzCash, Raast, or bank details for HBL, UBL, Meezan Bank or Bank Alfalah). These references are used solely for transaction processing — pakgim does not imply endorsement or affiliation with these providers;
• Transaction history and account balance records.

3.4 Betting and Gaming Activity Data

We record data relating to your use of our sportsbook and casino features, including:

• Wager placement history, including event type, stake amounts and outcomes;
• Casino game session data including game type, session duration and results;
• Responsible gambling tool usage, including deposit limits, session limits and self-exclusion status.

3.5 Technical and Device Data

When you access the Platform, we automatically collect certain technical data:

• IP address and approximate geographic location;
• Device type, operating system and browser version;
• Pages visited, time on page and navigation paths;
• Session timestamps and login records.

3.6 Communications Data

If you contact our customer support team via email or live chat, we retain records of those communications, including the content of your query, our responses and any supporting documentation you provide.

4. How We Use Your Personal Data

The following table summarises the primary purposes for which we process your Personal Data and the legal basis for each:

5. Data Sharing and Third-Party Disclosure

5.1 When We Share Data

We do not sell your Personal Data. We may share your data only in the following circumstances:

• Service Providers: We engage third-party data processors — including payment gateway providers, identity verification services, cloud hosting providers and analytics platforms — who process data on our behalf under contractual data processing agreements. These processors are not permitted to use your data for their own purposes.
• Legal and Regulatory Obligations: We may disclose Personal Data to law enforcement agencies, regulatory bodies or courts where we are legally required to do so, including under anti-money-laundering legislation or court orders.
• Responsible Gambling: We may share limited data with responsible gambling organisations or self-exclusion scheme operators where required by our licensing obligations or requested by you.
• Business Transfers: In the event of a merger, acquisition or sale of the Platform's business, Personal Data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

5.2 International Data Transfers

The pakgim Platform operates across international infrastructure. Your Personal Data may be transferred to, and processed in, countries outside Pakistan. Where such transfers occur, we implement appropriate safeguards — including contractual data protection clauses — to ensure your data remains protected to a standard consistent with this Policy.

6. Cookies and Tracking Technologies

6.1 What We Use Cookies For

Pakgim uses cookies and similar tracking technologies for the following purposes:

• Essential Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in during a visit and security tokens that protect your account. These cookies cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Help us understand how users interact with the Platform — which pages are visited most frequently, where users drop off in navigation flows, and how we can improve the user experience. Analytics data is aggregated and anonymised where possible.
• Preference Cookies: Remember your account settings and display preferences — such as your preferred language or currency display — across sessions.
• Marketing Cookies: Used only where you have given explicit consent to receive tailored promotional content. You may withdraw consent at any time.

6.2 Managing Cookies

You can manage or delete cookies through your browser settings. Most modern browsers allow you to block or delete specific categories of cookies. Note that disabling essential cookies may prevent certain Platform features from operating correctly.

7. Data Retention

We retain your Personal Data only for as long as necessary to fulfil the purposes set out in this Policy, or for as long as required by applicable legal, regulatory or licensing obligations. The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in line with standard AML record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years following each transaction, as required by applicable financial compliance obligations.
• Betting and gaming activity data: Retained for the duration of your account and for a minimum of two (2) years following account closure.
• Communications and support records: Retained for up to three (3) years from the date of the communication, or longer if the matter involves a dispute or legal proceeding.
• Technical and device data: Typically retained for up to thirteen (13) months for analytics purposes, then aggregated or deleted.

At the end of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our data disposal procedures.

8. Your Data Rights

Depending on the data protection laws applicable to your situation, you may hold some or all of the following rights with respect to your Personal Data. To exercise any of these rights, contact our support team using the details in Section 12.

9. Data Security

Pakgim implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers;
• Password hashing using industry-standard one-way algorithms — we never store your password in plain text;
• Two-factor authentication (2FA) options for account access;
• Role-based access controls limiting staff access to Personal Data on a need-to-know basis;
• Regular security audits and penetration testing of Platform infrastructure;
• Automated fraud detection systems monitoring for suspicious account activity.

While we take these obligations seriously, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. We will notify affected users of any material data breach in accordance with applicable obligations.

10. Children's Privacy

The pakgim Platform is strictly for users aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect Personal Data from minors. If we become aware that Personal Data has been submitted by or on behalf of an individual under the applicable minimum age, we will immediately close the account, delete the associated data and void any Account Balance pending investigation.

If you believe a minor has registered on our Platform, please contact us immediately at [email protected] (plain text — not a clickable link).

11. Updates to This Privacy Policy

Pakgim reserves the right to update this Privacy Policy at any time. Where a material change is made, we will provide notice through the Platform and update the "Last Updated" date at the top of this page. Your continued use of the Platform after the updated Policy is published constitutes acceptance of the revised terms.

We encourage you to review this Policy periodically to stay informed of how we handle your Personal Data. Material changes will be highlighted when the updated Policy is published.

12. Contact Us — Privacy Queries

If you have any questions, concerns or complaints regarding this Privacy Policy or the way in which we process your Personal Data, please contact our support team using the details below. All privacy-related enquiries are handled in English, with Urdu assistance available on request.

• Email: [email protected] Plain text only — not a clickable link. Mark the subject line "Privacy Policy Query".
• Response Time: Within 30 days for data rights requests; within 24 hours for general queries
• Languages: English (primary); Urdu on request