pakrum Privacy
Policy

pakrum operates the online casino and sports betting platform accessible at pakrum.org. For the purposes of this Privacy Policy, pakrum acts as the data controller in respect of all personal data collected from players and visitors through the pakrum Platform.

As data controller , pakrum determines the purposes and means by which your personal data is processed. Where pakrum engages third-party service providers to process data on its behalf, those providers act as data processors and are bound by contractual data processing agreements that restrict their use of your data to the purposes specified by pakrum.

If you have any questions about how pakrum processes your personal data, or wish to exercise any of your data rights, you can contact the pakrum data team at the address set out in Section 15 of this Policy.

pakrum collects the following categories of personal data in connection with your use of the Platform:

pakrum does not collect special categories of sensitive personal data (such as biometric data, health data, or political opinions) unless specifically required to fulfil a legal obligation applicable to pakrum's gaming licence, in which case you will be separately informed.

pakrum collects personal data through the following means:

• Direct Submission: Data you provide voluntarily when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in a promotion.
• Automated Technologies: Data collected automatically when you access or use the Platform, including IP addresses, device identifiers, browser fingerprints, session timestamps, and navigation behaviour, through the use of cookies, server logs, and similar tracking technologies.
• Third-Party KYC Providers: Identity and address verification data obtained from licensed identity verification partners in order to fulfil pakrum's regulatory obligations under its gaming licence.
• Payment Processors: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency networks when you initiate deposits or withdrawals.
• Fraud Prevention Services: Risk and fraud signals provided by third-party fraud prevention partners, which assist pakrum in protecting both the Platform and its players from fraudulent activity.
• Publicly Available Sources: In limited circumstances, pakrum may cross-reference data against publicly available sanctions lists, politically exposed persons (PEP) registers, or adverse media sources as part of its AML compliance obligations.

pakrum processes your personal data for the following clearly defined purposes:

• Account Registration & Management: To create and administer your pakrum account, verify your identity and age (minimum 21 years), and maintain accurate account records.
• Transaction Processing: To process your deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or cryptocurrency networks, and to maintain an accurate financial record of all transactions on your account.
• Gaming Services Delivery: To provide access to casino games (including slots, Kalaka Bingo, Teen Patti 20-20, and live dealer tables), sports betting markets (including PSL cricket and international fixtures), and all related Platform features.
• Legal & Regulatory Compliance: To fulfil pakrum's obligations under its international gaming licence, including KYC verification, anti-money-laundering (AML) monitoring, responsible gaming obligations, and record-keeping requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, bonus abuse, multi-accounting, money laundering, and other prohibited conduct as defined in pakrum's Terms & Conditions.
• Responsible Gaming: To monitor gameplay patterns for indicators of problem gambling, enforce self-exclusion and cooling-off requests, and provide responsible gaming interventions where appropriate.
• Customer Support: To respond to queries, resolve complaints, and process dispute submissions through pakrum's support channels.
• Marketing & Personalisation: To send promotional offers, bonus notifications, and personalised recommendations — but only where you have provided explicit consent, or where pakrum has a legitimate interest as described in Section 5.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the performance, security, and user experience of the pakrum Platform for all players, including those across Pakistan's major cities.

pakrum processes your personal data only where a valid legal basis exists for doing so. The applicable legal bases are as follows:

• Contract Performance: Processing that is necessary to deliver the services described in pakrum's Terms & Conditions — including account management, transaction processing, and gaming services delivery — is carried out on the basis that it is necessary for the performance of the contract between you and pakrum.
• Legal Obligation: Processing required to comply with applicable laws and licence conditions — including KYC verification, AML monitoring, age verification, and record retention — is carried out on the basis of pakrum's legal obligations.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and service improvement is carried out on the basis of pakrum's legitimate interests, provided those interests are not overridden by your rights and freedoms. Where pakrum relies on legitimate interests, it has assessed the balance of interests and concluded that the processing is necessary and proportionate.
• Consent: Processing for direct marketing communications (email, SMS) and non-essential cookies is carried out only where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

pakrum does not sell, rent, or trade your personal data. Personal data is shared only in the following circumstances and only to the extent necessary for the stated purpose:

• Identity Verification Providers: pakrum shares identity and document data with licensed KYC/AML service providers to fulfil age verification and identity confirmation obligations under pakrum's gaming licence.
• Payment Processors: Transaction data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency payment processors solely to process deposits and withdrawals on your behalf.
• Fraud Prevention Partners: Device, behavioural, and account data may be shared with third-party fraud prevention services to identify and prevent fraudulent activity on the Platform.
• Gaming Software Providers: Certain game-related data (such as account ID and session tokens) is shared with third-party game studios and live dealer providers to deliver gaming content through the pakrum Platform.
• Legal & Regulatory Authorities: pakrum will disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by law, court order, or pursuant to pakrum's obligations under its gaming licence.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of pakrum's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third-party service providers engaged by pakrum are required to enter into contractual data processing agreements confirming that they will process your data only for the specific purpose for which it was shared, in accordance with applicable data protection law.

pakrum operates as an internationally licensed gaming platform. As a result, your personal data may be transferred to, stored in, and processed in countries outside Pakistan, including the jurisdiction in which pakrum holds its gaming licence and the locations where its service providers operate.

Where personal data is transferred to jurisdictions that do not provide a level of data protection equivalent to internationally recognised standards, pakrum implements appropriate safeguards to ensure your data remains protected. These safeguards may include:

• Standard contractual clauses approved by relevant data protection authorities;
• Binding corporate rules where transfers occur within a group of companies;
• Adequacy decisions where the destination jurisdiction has been determined to offer equivalent protection.

You may request further information about the safeguards applied to international transfers of your personal data by contacting pakrum's data team at the address in Section 15.

pakrum uses cookies and similar technologies (including web beacons and local storage) on the Platform. These technologies serve the following purposes:

• Strictly Necessary Cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform — including pages visited, time spent, and navigation paths — to help pakrum improve the Platform experience.
• Functionality Cookies: Used to remember your preferences (such as language settings, preferred games, and display options) so that your experience is personalised on return visits.
• Marketing & Retargeting Cookies: Used — only with your consent — to deliver relevant promotional content and to measure the effectiveness of pakrum's marketing campaigns.

You may manage your cookie preferences at any time through your browser's settings or through the cookie consent banner displayed on your first visit to pakrum.org. Please note that disabling certain cookies may affect the functionality of the Platform.

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

• TLS encryption for all data in transit between your device and pakrum's servers;
• AES-256 encryption for sensitive data stored at rest, including payment information and identity documents;
• Multi-factor authentication requirements for account access and administrative systems;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular penetration testing and security audits conducted by independent third-party security specialists;
• Continuous monitoring of pakrum's systems for suspicious activity and potential data security incidents.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pakrum will notify you without undue delay and will take all reasonable steps to contain the breach, assess its impact, and prevent recurrence.

While pakrum takes every reasonable precaution to protect your personal data, no system is completely immune from security threats. You are responsible for maintaining the confidentiality of your account credentials and for notifying pakrum immediately if you suspect any unauthorised access to your account.

pakrum retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, or as required by applicable law or licence conditions. The following retention periods apply as a general guide:

• Account Data: Retained for the duration of the active account relationship plus a minimum of five years following account closure, to satisfy AML record-keeping obligations under pakrum's gaming licence.
• Transaction & Financial Records: Retained for a minimum of five years from the date of each transaction, in line with standard financial regulatory requirements.
• KYC & Identity Documents: Retained for a minimum of five years following the end of the business relationship, or longer where required by applicable law or a regulatory investigation.
• Gameplay & Wagering Logs: Retained for a minimum of three years to support dispute resolution, game integrity audits, and responsible gaming monitoring.
• Customer Support Records: Retained for two years from the date of the last support interaction, unless the matter is subject to an ongoing dispute or legal claim.
• Marketing Consent Records: Retained for the duration of the active marketing relationship plus two years following withdrawal of consent.

At the end of the applicable retention period, personal data is securely deleted or anonymised in a manner that ensures it can no longer be attributed to an identifiable individual.

Subject to applicable law and pakrum's legitimate interests and legal obligations, you have the following rights in respect of your personal data:

• Right of Access: You have the right to request a copy of the personal data pakrum holds about you, together with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. You may update many account details directly through your account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to pakrum's legal retention obligations.
• Right to Restriction: You have the right to request that pakrum restricts the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or object to its processing.
• Right to Data Portability: Where processing is based on consent or contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on pakrum's legitimate interests. You also have an unconditional right to object to the processing of your data for direct marketing purposes at any time.
• Rights Related to Automated Decision-Making: Where pakrum makes solely automated decisions that produce significant effects on you (for example, automated account suspension following fraud detection), you have the right to request human review of that decision.

To exercise any of the above rights, please contact pakrum's data team as described in Section 15. pakrum will respond to all valid data rights requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days, in which case you will be notified of the extension and the reason for it.

The pakrum Platform is strictly intended for adults aged 21 years and above. pakrum does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step during the account registration process and is reinforced through pakrum's KYC procedures.

If pakrum discovers or has reasonable grounds to believe that personal data has been collected from a person under the age of 21, it will immediately suspend the relevant account, delete all associated personal data, and refund any real money balance in accordance with its licence obligations.

Parents and guardians who believe that their child may have accessed pakrum or provided personal data to the Platform are encouraged to contact pakrum's support team immediately so that appropriate action can be taken without delay.

pakrum may send you promotional communications about bonuses, new games, special events, and other offers relevant to your pakrum account — but only where you have provided your explicit consent to receive such communications during registration or through your account settings.

Marketing communications may be delivered by email or SMS to the contact details associated with your account. The frequency and content of marketing communications are tailored based on your account activity and stated preferences, where consent has been given for such personalisation.

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email sent by pakrum;
• Updating your communication preferences in your account settings; or
• Contacting pakrum's support team with a request to unsubscribe from all marketing communications.

Opting out of marketing communications does not affect your receipt of transactional and account-related communications, such as deposit confirmations, withdrawal notifications, account security alerts, or updates to pakrum's Terms & Conditions or this Privacy Policy.

pakrum reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or pakrum's data processing practices. The "Effective Date" at the top of this Policy will be updated each time a new version is published.

Where a change to this Policy is material — meaning it significantly affects how pakrum processes your personal data or materially reduces your privacy rights — pakrum will notify you by email to the address associated with your account at least 14 calendar days before the change takes effect.

Your continued use of the pakrum Platform following the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. If you do not agree with the amended Policy, you may close your account in accordance with the terms set out in pakrum's Terms & Conditions.

Previous versions of this Privacy Policy are available upon request by contacting pakrum's data team.

If you have any questions, concerns, or requests relating to this Privacy Policy or pakrum's processing of your personal data, please contact the pakrum data team through the following channels:

If you are not satisfied with pakrum's handling of a data privacy concern, you have the right to lodge a complaint with the relevant supervisory authority in the jurisdiction applicable to pakrum's licensing and data processing operations. Contact details for the relevant supervisory authority are available upon request.

pakrum takes all privacy complaints seriously and will conduct a full internal review of every complaint received, issuing a written response within 28 calendar days.