pkr91 Privacy Policy

1. Introduction

1.1 pkr91 is committed to protecting the privacy and personal data of every player on its platform. This Policy has been drafted to be clear, transparent, and comprehensive — covering every aspect of how pkr91 handles your personal information from the moment you first visit pkr91.net through to the closure or dormancy of your account.

1.2 pkr91 operates as an online gaming and sports betting platform serving Pakistani players. As part of our operations, we are required by international gaming regulations and applicable anti-money-laundering (AML) frameworks to collect and process certain categories of personal data. This Policy explains the legal basis for that processing and how your rights are protected throughout.

1.3 This Policy should be read alongside the pkr91 Terms & Conditions and Responsible Gaming Policy, both of which are available on the pkr91 platform and are incorporated by reference into this document.

2. Data Controller

2.1 For the purposes of applicable data protection legislation, pkr91 acts as the data controller in respect of all personal data collected through the pkr91 platform. As data controller, pkr91 determines the purposes and means of processing your personal information.

2.2 Where pkr91 engages third-party service providers — such as payment processors, KYC verification providers, or fraud detection services — those providers act as data processors on pkr91's behalf and are contractually bound to process your data only in accordance with pkr91's documented instructions and applicable data protection law.

2.3 Any queries regarding the data controller relationship, requests to exercise your data rights, or complaints about pkr91's data practices should be directed to the pkr91 Data Protection contact, details of which are set out in Section 17 of this Policy.

3. Personal Data We Collect

3.1 pkr91 collects personal data across several categories. The table below summarises the types of data collected and the primary context in which each category is obtained:

3.2 pkr91 does not intentionally collect sensitive personal data beyond what is required for identity verification and AML compliance. Where CNIC data is collected for KYC purposes, it is handled with the highest level of access controls and is not used for any purpose beyond identity and age verification.

4. How We Collect Your Data

4.1 pkr91 collects personal data through the following primary channels:

• Direct submission: Information you provide when registering an account, completing KYC, making a deposit or withdrawal request, contacting support, or updating your account settings.
• Automated collection: Technical and behavioural data collected automatically as you navigate and interact with the pkr91 platform, including via cookies, web beacons, and server logs.
• Third-party sources: Identity verification data returned by KYC providers following document checks; fraud signals and device reputation data from fraud prevention partners; payment confirmation data from JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank.

4.2 pkr91 does not purchase personal data lists from data brokers or marketing list providers. Any third-party data received by pkr91 is received solely in the context of operational service delivery as described above.

5. Legal Basis for Processing

5.1 pkr91 processes your personal data under one or more of the following legal bases depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between you and pkr91, including operating your account, processing deposits and withdrawals, and delivering gaming services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, KYC requirements, and regulatory reporting duties imposed by pkr91's gaming licence conditions.
• Legitimate interests: Processing carried out in pursuit of pkr91's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where such interests are not overridden by your rights and interests.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent, primarily in the context of optional marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

6. How We Use Your Personal Data

6.1 pkr91 uses collected personal data for the following purposes:

• To create, verify, and manage your pkr91 Account;
• To process PKR deposits and withdrawals through your chosen payment method;
• To verify your age (21+) and identity in compliance with KYC requirements;
• To detect, investigate, and prevent fraudulent transactions, bonus abuse, and other prohibited conduct as defined in the pkr91 Terms & Conditions;
• To comply with AML obligations, including transaction monitoring and suspicious activity reporting;
• To monitor your gaming behaviour for responsible gaming indicators and, where necessary, to apply protective account restrictions;
• To personalise your platform experience, including game recommendations based on activity history;
• To communicate with you about your account, including transaction confirmations, security alerts, and support responses;
• To send promotional communications where you have opted in to receive them;
• To maintain accurate records for regulatory, audit, and dispute resolution purposes;
• To improve the pkr91 platform through aggregated, anonymised analytics.

6.2 pkr91 does not use personal data for automated individual decision-making that produces significant legal or similarly significant effects, except where this is required by law or expressly consented to by you.

7. Data Sharing & Disclosure

7.1 pkr91 does not sell, rent, or trade your personal data to third parties for commercial purposes. Personal data is shared only in the following limited circumstances:

7.1 Service Providers (Data Processors)

pkr91 engages carefully selected third-party service providers to assist in platform operations. These include:

• Payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) — for the processing of PKR transactions;
• KYC and identity verification providers — for CNIC validation and age verification;
• Fraud prevention and device intelligence providers — for security and AML compliance;
• Cloud hosting and infrastructure providers — for secure data storage and platform delivery;
• Customer support software providers — for live chat and ticketing services.

All service providers are subject to written data processing agreements that prohibit use of your data for any purpose other than the services they provide to pkr91.

7.2 Legal & Regulatory Disclosure

pkr91 may disclose personal data to regulatory authorities, law enforcement agencies, courts, or other government bodies where required to do so by applicable law, a valid court order, or in response to a lawful request in connection with a criminal investigation, AML inquiry, or regulatory audit.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of pkr91's business assets, personal data held by pkr91 may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any material changes to data processing that result from it.

8. International Data Transfers

8.1 pkr91 may transfer personal data to, or store it in, countries outside Pakistan in connection with its cloud hosting infrastructure or the use of international service providers. Where such transfers occur, pkr91 ensures that adequate safeguards are in place to protect your data to a standard equivalent to that provided within Pakistan, including through the use of standard contractual clauses or equivalent data transfer mechanisms.

8.2 By using the pkr91 platform, you consent to the transfer of your personal data to the countries in which pkr91 and its service providers operate, subject to the safeguards described in this section.

9. Data Retention

9.1 pkr91 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any overriding legal obligations. The following retention guidelines apply:

• Account and identity data: Retained for the lifetime of the Account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by financial regulatory frameworks;
• Gaming activity logs: Retained for three (3) years from the date of the activity, unless a longer retention period is required for regulatory or dispute resolution purposes;
• Customer support communications: Retained for two (2) years from the date of the communication;
• Marketing consent records: Retained for the duration of your marketing opt-in and for one (1) year following withdrawal of consent.

9.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with pkr91's data deletion procedures.

10. Security Measures

10.1 pkr91 implements a multi-layered security architecture to protect personal data against unauthorised access, loss, destruction, or alteration. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the pkr91 platform;
• AES-256 encryption for personal data stored in pkr91's databases;
• Role-based access controls ensuring that staff access to personal data is limited strictly to what is necessary for their job function;
• Two-factor authentication for all internal systems that contain personal data;
• Regular third-party penetration testing and security audits of the pkr91 platform infrastructure;
• Incident response procedures for the detection, reporting, and remediation of personal data breaches.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pkr91 will notify you without undue delay in accordance with its obligations under applicable data protection law.

10.3 While pkr91 takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is entirely secure. You are also responsible for maintaining the security of your pkr91 Account credentials and should contact pkr91 support immediately if you suspect unauthorised access to your Account.

11. Cookies & Tracking Technologies

11.1 pkr91 uses cookies and similar tracking technologies on the pkr91 platform. A cookie is a small text file placed on your device by a web server when you access a website. pkr91 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the pkr91 platform, including session management, account authentication, and security. These cannot be disabled without affecting platform functionality.
• Analytical / performance cookies: Used to collect anonymised information about how players interact with the pkr91 platform, enabling pkr91 to improve the user experience. These cookies do not identify individual users.
• Functional cookies: Used to remember your preferences and settings, such as language selection and responsible gaming limits, to provide a more personalised experience.

11.2 pkr91 does not deploy third-party advertising or behavioural targeting cookies on its platform.

11.3 You may control cookie settings through your browser's privacy or settings menu. Please note that disabling strictly necessary cookies may impair your ability to use the pkr91 platform effectively.

12. Your Data Rights

12.1 Subject to applicable data protection law and pkr91's legal retention obligations, you have the following rights in relation to your personal data held by pkr91:

• Right of access: You may request a copy of the personal data pkr91 holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held about you.
• 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 pkr91's overriding legal obligations to retain certain records.
• Right to restriction: You may request that pkr91 restricts the processing of your personal data in certain circumstances, for example while a rectification request is being assessed.
• Right to data portability: You may request that pkr91 provides your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider, where technically feasible.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including direct marketing. pkr91 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

12.2 To exercise any of the above rights, please contact the pkr91 Data Protection team using the details in Section 17. pkr91 will respond to all valid requests within 30 calendar days of receipt, or within such extended period as is permitted by applicable law, with written notification provided where an extension is required.

12.3 pkr91 will not charge a fee for responding to a data rights request unless the request is manifestly unfounded or excessive. In such cases, a reasonable administrative fee may apply.

13. Marketing Communications

13.1 pkr91 may send you promotional communications about bonuses, new games, sports betting offers, and platform updates where you have provided explicit consent to receive such communications at registration or subsequently via your account settings.

13.2 You may opt out of marketing communications at any time by updating your preferences in your pkr91 Account dashboard or by contacting pkr91 support. Opting out of marketing communications does not affect the delivery of transactional communications relating to your Account, such as deposit confirmations, withdrawal notifications, and security alerts.

13.3 pkr91 does not share your contact details with third-party marketing organisations for the purpose of sending unsolicited communications on behalf of those organisations.

14. Children & Minors

14.1 The pkr91 platform is strictly for persons aged 21 years and older. pkr91 does not knowingly collect, process, or store personal data relating to individuals under the age of 21. If pkr91 becomes aware that personal data belonging to a person under 21 has been collected, that data will be deleted immediately and the associated Account will be closed.

14.2 If you believe that a person under the age of 21 has registered an Account on pkr91, please notify pkr91 support immediately using the contact details in Section 17. pkr91 takes under-age access to gambling services extremely seriously and will act on all such reports as a matter of priority.

15. Third-Party Links

15.1 The pkr91 platform may contain links to third-party websites or services, for example links to payment provider portals or responsible gaming support organisations. pkr91 is not responsible for the privacy practices of third-party websites and this Policy does not apply to those sites. Players are encouraged to review the privacy policies of any third-party site before submitting personal data to it.

16. Changes to This Policy

16.1 pkr91 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or pkr91's data processing practices. The most current version of this Policy will always be available on the pkr91 platform at pkr91.net/privacy-policy, with the "Last Updated" date revised accordingly.

16.2 Where a change to this Policy materially affects the way pkr91 processes your personal data, pkr91 will notify you via your registered email address prior to the change taking effect, and will seek fresh consent where the legal basis for processing requires it.

16.3 Continued use of the pkr91 platform following the publication of a revised Privacy Policy constitutes your acknowledgement of the updated terms.

17. Contact Us

17.1 For all data protection queries, requests to exercise your data rights, or complaints about pkr91's handling of your personal information, please contact the pkr91 Data Protection team through the following channel:

17.2 If you are not satisfied with pkr91's response to a data protection complaint, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction or to the independent dispute resolution body specified by pkr91's gaming regulator.