pak11 Privacy Policy — How We Collect, Use & Protect Your Personal Data

pak11 ("we", "us", "our", or "the Platform") is committed to protecting the privacy and personal data of every player who registers and uses the pak11 online gaming platform at pak11.bio. This Privacy Policy is issued in accordance with the data protection obligations embedded in pak11's international gaming license and applicable data protection principles.

This Privacy Policy applies to all personal data processed in connection with your use of pak11, including data collected during the account registration process, during active use of the platform's sports betting, casino, and slot game services, during payment transactions, and during any interactions with pak11's customer support team.

By registering a pak11 account or by continuing to use the platform, you acknowledge that you have read, understood, and consented to the data processing activities described in this Privacy Policy. If you do not agree with any aspect of this Policy, you should not register a pak11 account or, if already registered, should contact pak11 support to request account closure.

This Privacy Policy should be read in conjunction with pak11's Terms & Conditions, which form the primary agreement governing your use of pak11.

2.1 For the purposes of applicable data protection law, pak11 is the Data Controller in respect of the personal data of registered players and platform visitors. As Data Controller, pak11 determines the purposes and means by which personal data is processed.

2.2 pak11 operates under an international gaming license that imposes specific data governance obligations, including the maintenance of a data processing register, the implementation of appropriate technical and organisational security measures, and the facilitation of data subject rights requests within defined timeframes.

2.3 Where pak11 engages third-party service providers to process personal data on its behalf (for example, KYC verification services or payment processors), those service providers act as Data Processors under written data processing agreements that prohibit the use of player data for any purpose beyond the specific service being provided to pak11.

3.1 Registration Data. When you create a pak11 account, we collect the following data:

• Full legal name (as it appears on your Pakistani CNIC)
• Date of birth (for age verification — 21+ requirement)
• Pakistani mobile telephone number
• Email address
• Account username selected during registration
• Password (stored in hashed, non-reversible form — pak11 cannot see your actual password)
• City and country of residence

3.2 KYC Verification Data. Prior to processing any withdrawal, pak11 collects:

• CNIC number and scanned copy of CNIC (front and back)
• Selfie photograph for biometric comparison against CNIC photograph
• Proof of payment method ownership where required
• Source of funds documentation for high-value accounts (e.g., payslip, bank statement)

3.3 Transaction Data. Every financial transaction conducted through your pak11 account is recorded, including deposit amounts, payment methods used (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK), timestamps, transaction reference numbers, withdrawal amounts, and wallet balance history.

3.4 Gaming Activity Data. pak11 records your gaming activity on the platform, including games played, bet amounts, wins and losses, session duration, game type preferences, and responsible gaming tool usage. This data is used for account management, responsible gaming monitoring, and — in anonymised, aggregated form — for platform improvement.

3.5 Technical Data. When you access pak11, we automatically collect certain technical data including your IP address, device type, operating system, browser type and version, screen resolution, and approximate geographic location derived from IP. This data is used for security monitoring, fraud prevention, and platform optimisation.

3.6 Communications Data. If you contact pak11 customer support — whether via email, live chat, or any other channel — the content of those communications and associated metadata is retained for service quality, dispute resolution, and compliance purposes.

pak11 collects personal data through the following means:

• Direct collection: Data you provide during registration, KYC submission, deposit and withdrawal requests, support interactions, or responsible gaming tool configuration.
• Automated collection: Technical data collected automatically when you access pak11 through cookies, server logs, and device fingerprinting technologies. See Section 8 for full cookie details.
• Third-party collection: Data received from licensed KYC verification partners who confirm the authenticity of identity documents; payment processors who confirm transaction success or failure; and fraud prevention services that cross-reference account data against known fraudulent identity patterns.

pak11 does not purchase personal data lists from third-party data brokers or marketing services, and does not receive personal data from social media platforms without explicit player consent.

pak11 processes personal data on the following legal bases:

• Contractual necessity: Processing required to create and manage your pak11 account, process deposits and withdrawals, enable game play, and provide customer support. Without this processing, pak11 cannot provide the Services to you.
• Legal obligation: Processing required to comply with gaming license obligations, anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and tax reporting obligations. pak11 cannot waive these legal processing requirements regardless of player preference.
• Legitimate interests: Processing carried out in pak11's legitimate interests in maintaining platform security, preventing fraud, detecting and preventing bonus abuse, managing responsible gaming risk, and improving the platform — provided these interests are not overridden by your fundamental data rights.
• Consent: Processing of personal data for direct marketing communications (promotional emails, SMS notifications about offers) is based on your explicit consent, which may be withdrawn at any time without affecting the legality of prior processing or your ability to continue using pak11.

pak11 uses the personal data collected from Pakistani players for the following specific purposes:

• Account creation and management: Creating, maintaining, and administering your pak11 player account throughout its lifetime.
• Identity and age verification: Confirming your identity and verifying that you meet the 21+ age requirement as a mandatory condition of platform access.
• Payment processing: Facilitating deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK; processing withdrawal requests; reconciling PKR balances; and maintaining financial transaction records.
• Platform security and fraud prevention: Monitoring login activity, detecting unauthorised account access, identifying suspicious transaction patterns, preventing the use of multiple accounts by a single player, and protecting the integrity of gaming outcomes.
• Responsible gaming: Monitoring gaming activity to identify potential signs of problem gambling, enforcing responsible gaming limits set by you, processing self-exclusion requests, and proactively applying responsible gaming interventions where pak11 identifies concerning behavioural patterns.
• Customer support: Responding to account queries, resolving payment disputes, processing responsible gaming requests, and maintaining records of support interactions for quality assurance and regulatory compliance.
• Legal and regulatory compliance: Fulfilling pak11's obligations under its international gaming license, AML regulations, and any applicable reporting requirements to gaming regulators or law enforcement authorities.
• Platform improvement: Analysing anonymised, aggregated gaming behaviour data to improve game selection, user interface design, and overall platform performance.
• Marketing communications (consent-based only): Sending promotional offers, bonus notifications, and platform updates to players who have explicitly opted in to marketing communications.

7.1 Service Providers. pak11 shares personal data with a limited set of contractually bound service providers who process data on pak11's behalf for specific operational purposes:

• KYC verification partners: Licensed identity verification services that authenticate CNIC documents and process biometric comparisons. These partners are bound by written data processing agreements and may not use pak11 player data for any other purpose.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK receive transaction data necessary to process deposits and withdrawals. Each payment provider operates under its own regulatory framework and privacy obligations as regulated Pakistani financial institutions.
• Fraud prevention services: Third-party fraud detection providers who cross-reference account and transaction data against known fraud indicators. Data shared is pseudonymised where technically feasible.
• Cloud infrastructure providers: pak11's platform is hosted on secure cloud infrastructure. The infrastructure provider stores encrypted data on pak11's behalf and does not have access to decrypted personal data.

7.2 Regulatory Disclosure. pak11 is legally obligated to disclose personal data to gaming regulators, law enforcement agencies, financial intelligence units, and other government authorities where required by applicable law, by a court order, or by the terms of pak11's gaming license. pak11 will endeavour to notify affected players of such disclosures where legally permitted to do so.

7.3 Business Transfers. In the event of a merger, acquisition, or sale of all or a material portion of pak11's assets, personal data held by pak11 may be transferred to the acquirer as part of that transaction. Players will be notified in advance of any such transfer, with the opportunity to request account closure and data deletion prior to completion of the transfer.

7.4 No Sale of Data. pak11 does not sell, rent, trade, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. This commitment is absolute and is not subject to any commercial exception.

8.1 pak11 uses cookies and similar tracking technologies to operate the platform effectively, maintain your logged-in session, remember your preferences, and analyse platform usage patterns. By continuing to use pak11 after being presented with cookie information, you consent to the use of cookies as described below.

8.2 The following categories of cookies are used on pak11:

8.3 You can manage cookie preferences through your browser settings. Note that disabling cookies categorised as "Strictly Necessary" or "Security & Fraud" will impair your ability to use pak11 normally, including the ability to remain logged in between pages.

8.4 pak11 does not use third-party advertising cookies or retargeting pixels that would result in pak11-related advertisements appearing to you on other websites.

9.1 pak11 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure:

• Transport encryption: All data transmitted between your device and pak11 servers is encrypted using 256-bit TLS (Transport Layer Security) — the same standard used by major Pakistani banks.
• Data at rest encryption: All personal data stored in pak11 databases is encrypted at rest using AES-256 encryption.
• Password hashing: Account passwords are processed through bcrypt hashing and stored only in hashed, non-reversible form. pak11 cannot retrieve or view your password.
• Access controls: Access to systems containing personal data is restricted on a strict need-to-know basis. All staff access is logged, reviewed, and subject to multi-factor authentication.
• Intrusion detection: pak11 operates automated intrusion detection and anomaly monitoring systems that generate alerts for unusual access patterns, bulk data queries, or suspicious administrative activity.
• Penetration testing: pak11's security infrastructure is subject to periodic independent penetration testing to identify and remediate vulnerabilities before they can be exploited.
• Incident response: pak11 maintains a documented data breach incident response plan. In the event of a data breach affecting your personal data, pak11 will notify affected players within the timeframe required by applicable law or gaming license obligations.

10.1 pak11 retains personal data for different periods depending on the type of data and the purpose for which it was collected:

• Account data (active accounts): Retained for the full duration of your account's active status plus a period following closure as detailed below.
• Account data (closed accounts): Following account closure, account identification and transaction data is retained for a minimum of five (5) years to fulfil AML compliance obligations and gaming license requirements. After this period, data is securely deleted or anonymised.
• KYC documentation: Retained for a minimum of five (5) years following the conclusion of the account relationship, as required under anti-money laundering regulations applicable to licensed gaming operators.
• Financial transaction records: Retained for a minimum of five (5) years for financial audit and regulatory compliance purposes.
• Customer support communications: Retained for two (2) years following the resolution of the relevant support interaction, unless the communication relates to a dispute that remains unresolved, in which case it is retained until final resolution.
• Marketing consent records: Retained for the period that consent remains active plus two (2) years following withdrawal of consent, to evidence the validity of marketing communications sent during the consent period.
• Technical and security logs: Retained for ninety (90) days under normal circumstances, extended to twelve (12) months where a security incident investigation is ongoing.

10.2 Upon expiry of the applicable retention period, personal data is either securely and permanently deleted or rendered permanently anonymous in a manner that cannot be reversed, at pak11's election.

11.1 As a pak11 player, you have the following rights with respect to your personal data. These rights are subject to applicable legal exceptions and the specific retention obligations that apply to gaming platform operators:

12.1 pak11 may send promotional communications — including bonus offers, PSL betting promotions, new game announcements, and platform news — to players who have explicitly opted in to receiving such communications during registration or through account marketing preference settings.

12.2 Marketing communications from pak11 are sent only to players who have provided valid consent. We do not send unsolicited commercial communications to players who have not opted in.

12.3 Withdrawing Marketing Consent. You may withdraw your consent to receive marketing communications from pak11 at any time through one of the following methods:

• Updating your communication preferences in your pak11 Account Settings → Notifications.
• Clicking the unsubscribe link included in any marketing email from pak11.
• Contacting pak11 customer support at [email protected] with a request to opt out of all marketing communications.

12.4 Withdrawing marketing consent will not affect your ability to continue using pak11 or receiving service-related transactional communications (such as deposit confirmations, withdrawal notifications, responsible gaming alerts, and security notifications, which are sent regardless of marketing preferences).

13.1 pak11 is strictly an adults-only platform. The minimum age requirement to register and use pak11 is 21 years of age. pak11 does not knowingly collect or process personal data from individuals under the age of 21.

13.2 Where pak11 discovers or has reasonable grounds to believe that an account has been registered by or on behalf of a person under 21 years of age, pak11 will immediately suspend the account, delete or securely quarantine any personal data collected in connection with that account, and return any deposited funds to the payment source following verification of the refund destination.

13.3 If you are a parent or guardian and believe that a person in your care under 21 years of age has registered a pak11 account, please contact pak11 support immediately at [email protected]. pak11 will investigate the matter promptly and take appropriate action.

14.1 pak11's platform infrastructure and some of its service providers may be located in jurisdictions outside Pakistan. As a result, your personal data may be transferred to and processed in countries other than Pakistan in the course of operating the platform.

14.2 Where personal data is transferred internationally, pak11 implements appropriate transfer safeguards, which may include: contractual clauses between pak11 and the receiving entity that impose data protection obligations equivalent to those applicable in the operating jurisdiction; the transfer being to a jurisdiction recognised as providing an adequate level of data protection; or the transfer being necessary for the performance of a contract between you and pak11 (for example, processing a JazzCash payment that routes through international payment rails).

14.3 pak11 does not transfer personal data to jurisdictions that lack adequate data protection frameworks without implementing the appropriate contractual safeguards described above.

15.1 pak11 reserves the right to update this Privacy Policy at any time to reflect changes in data processing practices, applicable law, gaming license requirements, or the services offered on the platform. Material changes to this Policy will be communicated to registered players via the email address or mobile number associated with their pak11 account at least 7 days prior to the changes taking effect.

15.2 The effective date of the current version of this Privacy Policy is displayed at the top of this page. We recommend reviewing this Policy periodically to remain informed about how pak11 handles your personal data.

15.3 Continued use of pak11 following notification of changes to this Privacy Policy constitutes acceptance of the updated Policy. If you do not accept the revised Policy, you must cease using pak11 and contact support to request account closure.

16.1 For any questions, concerns, or requests relating to this Privacy Policy or to the personal data pak11 holds about you, please contact pak11's data handling team using the following contact information:

16.2 When submitting a data rights request, please include your registered pak11 mobile number or email address, the nature of your request, and any relevant context. Identity verification will be conducted before personal data is disclosed or actioned in response to a rights request.

16.3 For additional information about the responsible gaming protections available to you on pak11, please visit our Responsible Gaming page.