Privacy Policy — 92pkrl

Introduction

1.1 This Privacy Policy ("Policy") is issued by 92pkrl ("the Platform", "we", "us", "our") and governs the collection, use, storage and disclosure of personal data in connection with your use of the website at 92pkrl.cam and all associated services (collectively, the "Service").

1.2 92pkrl is an English-language online gaming information and wagering platform primarily serving Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and other cities. By accessing or using the Service, you acknowledge that you have read and understood this Policy and that you consent to the data practices described herein.

1.3 If you do not agree with any part of this Policy, you should discontinue use of the Service and close your account. Where a conflict arises between this Policy and our Terms & Conditions, the Terms & Conditions shall prevail unless this Policy expressly states otherwise.

1.4 Nothing in this Policy constitutes legal advice regarding data protection obligations applicable to you under Pakistani law or any other jurisdiction. If you have concerns about your data rights, we recommend seeking independent legal guidance.

Definitions

The following terms carry the meanings assigned below throughout this Policy:

• "Personal Data" means any information that directly or indirectly identifies a living natural person, including name, CNIC number, email address, phone number, IP address and payment details.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means 92pkrl, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means a third party that processes Personal Data on behalf of 92pkrl under written instruction and subject to confidentiality obligations.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences and analytics data.
• "KYC Data" means identity and address documentation submitted for Know Your Customer verification purposes, including CNIC copies and proof of address.
• "Transaction Data" means records of deposits, withdrawals, wagers and account balance movements denominated in PKR or any other currency.

Data We Collect

3.1 We collect the categories of Personal Data described in the table below. The data collected depends on how you use the Service and the point in your account lifecycle.

3.2 We do not intentionally collect Sensitive Personal Data such as racial or ethnic origin, religious beliefs, biometric data or health information, except where specifically required for responsible-gambling intervention and only with your explicit consent or where legally mandated.

How We Collect Data

4.1 Directly from You. When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team or submit feedback, you provide Personal Data directly to us.

4.2 Automatically via Technology. When you access 92pkrl, our servers automatically record Technical Data and Usage Data through server logs, cookies, web beacons and similar tracking technologies.

4.3 From Third-Party Payment Providers. When you use payment methods referenced on the Platform — including but not limited to mobile wallets, bank transfers via institutions such as HBL, UBL, Meezan Bank or Bank Alfalah, or Raast instant payment infrastructure — we may receive transaction confirmation data from the payment provider. We do not receive your full payment credentials. References to payment providers on this Platform are for informational context only and do not imply those providers endorse, support or permit gambling-related transactions.

4.4 From Identity Verification Partners. Where we engage third-party KYC or AML service providers, those partners may share verification outcomes and risk indicators with us in connection with your account.

Data Processing & Use

5.1 We process your Personal Data for the following purposes:

• Account Management: Creating, maintaining and securing your 92pkrl account, including password management and session authentication.
• Identity & Age Verification: Confirming that you meet the minimum age requirement (18+, or the higher minimum required by the operator or license jurisdiction) and verifying your identity for KYC compliance.
• Transaction Processing: Executing deposits, withdrawals and wager settlements in PKR and facilitating associated payment flows.
• Fraud Prevention & AML: Detecting, investigating and preventing fraudulent activity, money laundering, match-fixing and other prohibited conduct.
• Customer Support: Responding to queries, resolving disputes and maintaining records of our communications with you.
• Responsible Gambling: Monitoring usage patterns to identify potential problem gambling behaviour and, where appropriate, proactively applying account controls.
• Legal & Regulatory Compliance: Meeting obligations under applicable laws, including retention of records as required by anti-money laundering regulations.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve user experience, fix technical issues and develop new features.
• Marketing Communications: Sending promotional materials and bonus notifications where you have opted in to marketing. You may withdraw consent at any time.

Legal Basis for Processing

6.1 Where data protection law applicable in the operator's jurisdiction requires a lawful basis for processing, we rely on the following bases:

• Contract Performance: Processing necessary to fulfil our contractual obligations to you under the Terms & Conditions, including account operation and transaction settlement.
• Legal Obligation: Processing required to comply with applicable AML, KYC and record-keeping laws.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement and internal analytics, where our interests do not override your fundamental rights.
• Consent: Processing for marketing communications and optional analytics cookies, where you have given explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

Cookies & Tracking Technologies

7.1 92pkrl uses cookies and similar technologies (including web beacons, pixel tags and local storage) to operate the Platform and enhance your experience. The main cookie categories we use are:

• Essential Cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state and security tokens. These cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences such as language selection, display settings and previously visited sections to provide a more personalised experience.
• Analytical Cookies: Collect anonymised data on how users navigate the Platform — which pages are visited, how long sessions last and where errors occur. This data helps us improve 92pkrl for all users.
• Marketing Cookies: Used to deliver relevant promotional content and to measure the effectiveness of marketing campaigns. These are only set where you have consented.

7.2 You can manage cookie preferences through your browser settings. Blocking essential cookies will impair your ability to use the Platform. Please note that cookie settings may reset when you clear your browser cache.

Data Sharing

8.1 We do not sell your Personal Data. We may share your data with the following categories of recipients, only to the extent necessary:

• Payment Processing Partners: To facilitate deposits and withdrawals through available cashier methods. These partners act as Data Processors under contractual data protection obligations.
• KYC and Identity Verification Providers: To verify your identity and age in compliance with applicable KYC requirements.
• Fraud Prevention and AML Services: To screen transactions and account activity against fraud and money-laundering indicators.
• IT Infrastructure Providers: Cloud hosting, content delivery and database management providers who store and process data on our behalf under strict confidentiality agreements.
• Legal and Regulatory Authorities: Where required by court order, regulatory demand or applicable law, we may disclose Personal Data to competent authorities.

8.2 All third-party Data Processors are required to process your Personal Data only on our documented instructions and are prohibited from using it for their own independent purposes.

International Transfers

9.1 As an online platform serving Pakistani users with international infrastructure, your Personal Data may be transferred to and processed in countries outside Pakistan. These countries may not have data protection laws equivalent to those in your jurisdiction.

9.2 Where such transfers occur, we implement appropriate safeguards — including contractual protections — to ensure your Personal Data receives an adequate level of protection consistent with this Policy.

Data Retention

10.1 We retain your Personal Data for as long as necessary to fulfil the purposes described in this Policy or as required by applicable legal and regulatory obligations. Key retention principles are:

• Active Account Data: Retained for the full duration of your account relationship with 92pkrl.
• Transaction and KYC Records: Typically retained for a minimum of five (5) years following account closure or the last relevant transaction, to comply with AML record-keeping requirements.
• Support Communications: Retained for a period sufficient to resolve disputes and meet quality-assurance obligations, typically up to two (2) years.
• Marketing Consent Records: Retained until withdrawal of consent plus a reasonable period to evidence prior consent.

10.2 Upon expiry of the relevant retention period, Personal Data is securely deleted or irreversibly anonymised so that it can no longer be linked to an identifiable individual.

User Rights

11.1 Subject to applicable data protection law, you may exercise the following rights by contacting us at the details in Section 14:

• Access: Request a copy of the Personal Data we hold about you and information about how it is processed.
• Rectification: Request correction of inaccurate or incomplete Personal Data.
• Erasure: Request deletion of your Personal Data where the original processing purpose no longer applies and no overriding legal retention obligation exists.
• Restriction: Request that processing of your Personal Data be limited to storage only, pending resolution of a dispute or pending your exercise of another right.
• Data Portability: Request a machine-readable copy of the Personal Data you have provided to us, where technically feasible.
• Objection: Object to processing based on legitimate interests, including profiling for direct marketing purposes.
• Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

11.2 We will respond to verified rights requests within a reasonable timeframe, and in any event within thirty (30) calendar days. We may request proof of identity before processing a rights request to prevent unauthorised disclosure.

Minors & Age Verification

12.1 The 92pkrl Platform is strictly for adults. We do not knowingly collect Personal Data from individuals below the applicable minimum age (18+ or the higher minimum required by the operator or license jurisdiction). Age verification is conducted as part of the KYC process.

12.2 If we become aware that we have inadvertently collected Personal Data from a minor, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at the address in Section 14.

Changes to This Privacy Policy

13.1 We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law or Platform features. Revised versions will be published on this page with an updated effective date.

13.2 Where changes are material, we will endeavour to notify registered users via email or a prominent Platform notice. Your continued use of the Service following publication of an updated Policy constitutes acceptance of the revised terms.

13.3 We encourage you to review this Policy periodically. The "Last Updated" date at the top of this page indicates when the most recent revision was made.

Contact Us

14.1 If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data, please contact our support team:

14.2 For responsible gambling-related concerns, account closures or self-exclusion requests, please visit our Responsible Gambling page which provides additional guidance and support pathways.