Privacy Policy — pak399 🔐

1. Introduction

pak399 ("the Platform", "we", "us", "our") operates the website accessible at https://pak399.cam. This Privacy Policy ("Policy") sets out how pak399 collects, processes, uses, stores and protects the personal data of users ("you", "your") who access or interact with the Platform.

pak399 is an English-language online betting and casino information platform serving Pakistani users and players in other permitted jurisdictions. This Policy applies to all personal data collected through your use of pak399, including registration data, payment reference data, communications and usage data.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy. By using the Platform, you confirm that you have read, understood and accepted the practices described in this Policy.

2. Definitions

"Personal Data"

Any information relating to an identified or identifiable natural person — including name, email address, identification document data, payment details, IP address and usage behaviour — as applicable under relevant data protection law.

"Processing"

Any operation or set of operations performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure by transmission, erasure and destruction.

"Data Controller"

The entity that determines the purposes and means of processing personal data. For the purposes of this Policy, pak399 acts as Data Controller in relation to data collected through the Platform.

"Data Processor"

A third party that processes personal data on behalf of the Data Controller under contractual instruction. Data Processors used by pak399 include licensed identity verification providers, payment gateway operators and analytics service providers.

"KYC Data"

Identity and age verification data collected during the Know Your Customer process, including copies of government-issued photo ID (e.g., Pakistani CNIC, passport), proof of address documents and biometric liveness check data.

"Consent"

A freely given, specific, informed and unambiguous indication of agreement by the data subject to the processing of their personal data for a specified purpose.

"Cookie"

A small text file placed on a user's device by a website to store information about the user's browsing session or preferences. See Section 9 for full details.

"Platform"

The pak399 website at https://pak399.cam including all pages, content, features and services provided thereon.

3. Data Controller

For the purposes of applicable data protection legislation, pak399 is the Data Controller in respect of personal data collected through the Platform. Where pak399 engages third-party Data Processors (such as licensed identity verification providers and payment gateway operators), such processors act under contractual data processing agreements that require them to handle data securely and only for the purposes specified by pak399.

Where users interact with a separate underlying gambling operator platform, that operator may act as an independent Data Controller in respect of gambling account data, transaction records and operator-held KYC files. Users should review the operator's own privacy policy for full details of their data handling practices.

For all data-related enquiries concerning pak399's own data practices, users may contact us using the details provided in Section 17 of this Policy.

4. Data We Collect

pak399 may collect the following categories of personal data from users:

4.1 Registration and Account Data

• Full legal name;
• Date of birth (for age verification purposes);
• Email address;
• Username and encrypted password hash;
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar);
• Preferred language and currency (PKR).

4.2 Identity Verification (KYC) Data

• Copy of valid government-issued photo ID — typically a Pakistani CNIC (Computerized National Identity Card) or valid Pakistani passport;
• Proof of residential address where required (utility bill, bank statement or official correspondence);
• Selfie or video liveness check image submitted through the operator's secure HTTPS verification portal.

4.3 Payment and Transaction Data

• Payment method type (e.g., bank transfer, mobile wallet reference — Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah as applicable);
• Transaction reference numbers, amounts in PKR and timestamps;
• Partial masked payment account identifiers (e.g., last four digits of a bank account). Full payment credentials are handled exclusively by licensed payment processors and are not stored by pak399.

4.4 Usage and Technical Data

• IP address and approximate geographic location;
• Device type, operating system and browser version;
• Pages visited, features used and time spent on the Platform;
• Referral source and search terms where available;
• Session duration and interaction logs.

4.5 Communications Data

• Content of support requests submitted via email or live chat;
• Feedback, survey responses and voluntary communications submitted to pak399.

5. How We Collect Your Data

pak399 collects personal data through the following channels:

5.1 Direct Collection

Data you provide directly when creating an account, completing KYC verification, making a deposit or withdrawal, submitting a support request, completing a survey or otherwise communicating with pak399.

5.2 Automated Collection

Technical data collected automatically as you browse the Platform, including IP address, device identifiers, browser type and session behaviour, through the use of cookies, web beacons, server logs and similar technologies (see Section 9).

5.3 Third-Party Sources

Data received from third-party sources where applicable, including identity verification providers (who return verification status and flags), fraud prevention services, payment processors (who return transaction status and reference data) and analytics partners. Data received from third parties is handled in accordance with this Policy and applicable contractual data processing arrangements.

6. Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing personal data, pak399 relies on the following lawful bases:

Where processing is based on legitimate interests, pak399 has assessed that those interests are not overridden by the rights and interests of data subjects. Where processing is based on consent, you have the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. How We Use Your Data

pak399 uses personal data for the following purposes:

• Account Operations: Creating, managing and securing your account; verifying your identity and age; processing login and session management.
• KYC Compliance: Fulfilling identity verification and age-checking obligations required by the operator's licensing terms and applicable AML regulations.
• Payment Processing: Facilitating deposits and withdrawals in PKR through selected payment channels; maintaining transaction records for audit and compliance purposes.
• Fraud and Security: Detecting and preventing fraud, bonus abuse, money laundering, underage access and other prohibited conduct; monitoring for suspicious account activity.
• Customer Support: Responding to support requests submitted via email or live chat; resolving disputes and account queries.
• Platform Improvement: Analysing aggregated usage data to improve Platform performance, user experience and content relevance for Pakistani users.
• Legal Compliance: Meeting obligations imposed by applicable data protection law, AML legislation, licensing regulations and court orders.
• Responsible Gambling: Monitoring account activity for indicators of problem gambling behaviour; facilitating access to self-exclusion and deposit-limit tools where requested.
• Communications: Sending service-related notifications, policy updates and, where consent has been obtained, relevant promotional communications.

pak399 does not use personal data for automated decision-making that produces legal or similarly significant effects on users without human review, except where required for fraud detection and KYC compliance under applicable regulatory obligations.

8. Data Sharing & Disclosure

pak399 may share personal data with the following categories of recipients:

8.1 Licensed Gambling Operators

Where you access betting or casino services through pak399, relevant account and KYC data may be shared with the underlying licensed operator for the purposes of account creation, verification and transaction processing. The operator processes such data as an independent Data Controller under their own privacy policy.

8.2 Identity Verification Providers

KYC documents (CNIC copies, passport scans, liveness data) are processed by licensed identity verification service providers under contractual data processing agreements. These providers are prohibited from using your data for any purpose other than identity verification on pak399's behalf.

8.3 Payment Processors

Transaction data is shared with licensed payment processors as necessary to process deposits and withdrawals in PKR. Payment processors referenced in context for Pakistani users include services such as Easypaisa, JazzCash, Raast and major bank transfer networks (HBL, UBL, Meezan Bank, Bank Alfalah), where these are active in the operator's live cashier. These institutions process payment data as independent data controllers under their own privacy policies.

8.4 Analytics & Technology Providers

Aggregated and pseudonymised usage data may be shared with analytics platforms and technology service providers for Platform performance analysis. These providers are bound by contractual obligations to handle data securely and in accordance with applicable data protection law.

8.5 Regulatory and Legal Authorities

pak399 may disclose personal data to competent regulatory authorities, law enforcement agencies or courts where required to do so by applicable law, court order or regulatory obligation. Such disclosures will only be made to the extent required by applicable legal process.

8.6 No Sale of Personal Data

pak399 does not sell, rent or trade personal data to third-party advertisers, marketing data brokers or any other unauthorised parties. Data is shared only as described in this Section and only to the extent necessary for the stated purposes.

9. Cookies & Tracking Technologies

pak399 uses cookies and similar tracking technologies to enable core Platform functionality, analyse usage patterns and optimise the user experience for Pakistani players accessing the Platform across a range of devices and network conditions.

9.1 Types of Cookies Used

Essential Cookies — Required for core functionality including session management, login state and security. Cannot be disabled without breaking basic Platform operation.

Analytics Cookies — Used to collect aggregated data about Platform usage, page performance and user journeys. Help us understand how Pakistani users interact with pak399 across cities and device types.

Preference Cookies — Store user preferences such as display settings, language and PKR currency selection to improve the browsing experience on return visits.

Security Cookies — Used to detect and prevent fraudulent activity, session hijacking and unauthorised access attempts.

9.2 Managing Cookies

You can manage, restrict or delete cookies through your browser settings. Please note that disabling essential cookies will impair or prevent the use of core Platform features including account login and secure session management. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

9.3 Third-Party Cookies

Third-party analytics and performance tools may set their own cookies when you interact with the Platform. Such third-party cookies are governed by the respective provider's privacy policy. pak399 does not control third-party cookie behaviour and recommends reviewing third-party privacy policies where applicable.

10. Data Retention

pak399 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy or as required by applicable law and regulatory obligations. The following indicative retention periods apply:

Following the expiry of applicable retention periods, personal data will be securely deleted or anonymised in accordance with pak399's data deletion procedures. Where data is subject to an ongoing regulatory investigation, dispute or legal proceeding, retention may be extended until final resolution.

11. Data Security

pak399 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. Security measures include, but are not limited to:

• Industry-standard SSL/TLS encryption for all data transmitted between your device and the Platform;
• Secure encrypted storage for personal data at rest;
• Strict access controls limiting personal data access to authorised personnel on a need-to-know basis;
• Regular security assessments and vulnerability testing;
• Contractual security obligations imposed on all third-party Data Processors;
• KYC document handling exclusively through secure HTTPS verification portals — not via email or messaging applications.

While pak399 takes all reasonable steps to protect your data, no transmission over the internet or electronic storage system is entirely secure. If you have reason to believe your account or personal data has been compromised, please contact our support team immediately using the details in Section 17.

12. International Data Transfers

pak399 operates as a platform serving Pakistani users and other permitted jurisdictions. Personal data may be transferred to, processed or stored in countries outside of Pakistan where our licensed operators, identity verification providers, payment processors and technology partners are located.

Where personal data is transferred internationally, pak399 ensures that appropriate safeguards are in place, including contractual data transfer agreements with receiving parties that impose data protection standards equivalent to those described in this Policy.

Pakistani users should be aware that data protection laws in other jurisdictions may differ from those applicable in Pakistan. pak399 takes reasonable steps to ensure that international data transfers are conducted securely and in accordance with applicable legal requirements.

13. Your Data Rights

Subject to applicable data protection law, you may have the following rights in relation to your personal data held by pak399. To exercise any of these rights, please contact us using the details in Section 17.

We will respond to data rights requests within a reasonable period and in accordance with applicable legal timelines. We may need to verify your identity before processing a request. Where a request cannot be fulfilled — for example, due to overriding legal obligations — we will explain the reasons in writing.

14. Children's Privacy

pak399 is strictly intended for users aged 18 years or above — or the higher minimum age required by the operator's licensing jurisdiction. We do not knowingly collect personal data from individuals under the age of 18.

If we become aware that personal data has been collected from a person under the minimum age, we will take immediate steps to delete that data and close any associated account. If you have reason to believe that a minor has accessed or registered on the Platform, please notify us immediately using the contact details in Section 17.

15. Third-Party Links & External Platforms

pak399 may contain references or links to third-party operator platforms, payment services or other external websites. This Privacy Policy applies only to data collected through the pak399 Platform itself — it does not govern the data practices of third-party websites, operators or payment service providers.

pak399 is not responsible for the privacy practices of third-party platforms. We recommend that users review the privacy policy of any third-party platform they access through or alongside pak399, including the privacy policies of gambling operators and payment providers.

16. Amendments to This Policy

pak399 reserves the right to update, amend or replace this Privacy Policy at any time. Where material changes are made, we will publish the updated Policy on this page with a revised effective date. Where practicable, we will provide reasonable advance notice of significant changes via a prominent Platform notice or by email to the registered address.

Continued use of the Platform following the publication of an amended Privacy Policy constitutes your acceptance of the revised terms. If you do not accept any amendment, you must cease using the Platform and may request account closure and deletion of your personal data subject to applicable retention obligations.

17. Contact Us

For any queries relating to this Privacy Policy, to exercise your data rights, or to report a potential data security concern, please contact the pak399 data team using the details below. Please note that the support email address is displayed as plain text and is not a clickable link.

To help us process your request efficiently, please include your registered account email address, the nature of your request and, where applicable, any relevant reference numbers. We may need to verify your identity before processing certain requests.