Privacy Policy

This Privacy Policy ("Policy") describes how PK91 ("we", "us", "our") collects, processes, stores, shares and protects personal data provided by or relating to users ("you", "your") of the PK91 website located at https://pk91.cam and any related services, features and content (collectively, the "Service").

By accessing or using the Service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Service immediately.

PK91 is an internationally oriented online betting and casino information platform designed for Pakistani users. It does not hold a gambling licence issued by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any provincial regulatory body. This Policy is governed by the data protection standards of the jurisdiction in which PK91 holds its operating licence. Pakistani users should be aware that local data protection regulations — including any applicable provisions of the Electronic Transactions Ordinance, 2002 and the Prevention of Electronic Crimes Act, 2016 — may also apply to the processing of their personal data.

For the purposes of this Policy, the following terms have the meanings set out below:

• "Personal Data" — Any information relating to an identified or identifiable natural person. This includes name, email address, phone number, device identifiers, IP address and financial account details.
• "Processing" — Any operation or set of operations performed on personal data, including collection, storage, use, disclosure, erasure or destruction, whether by automated means or otherwise.
• "Data Controller" — The entity that determines the purposes and means of processing personal data. PK91 acts as Data Controller in respect of personal data collected through the Service.
• "Data Processor" — A third party that processes personal data on behalf of PK91 under a written data processing agreement and in accordance with this Policy.
• "Consent" — A freely given, specific, informed and unambiguous indication of agreement by which you signal acceptance of the processing of your personal data for a stated purpose.
• "KYC" — Know Your Customer — the identity and age verification process required under regulatory obligations before a user may withdraw funds or access certain platform features.
• "Cookies" — Small text files stored on your device by your browser at the instruction of the Service, used to maintain session state, analyse usage and support certain platform features.

PK91 collects personal data through multiple channels in the course of providing the Service. The categories of data we collect are described below:

3.1 Data You Provide Directly

3.2 Data Collected Automatically

When you access the Service, certain technical data is collected automatically by our systems and third-party analytics tools. This includes:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution and unique device identifiers.
• Usage Data: Pages visited, time spent on each page, click paths, betting and gaming activity logs, search queries within the platform and features accessed.
• Location Data: Approximate geographic location derived from IP address, used for fraud prevention, geo-restriction compliance and localised content delivery.
• Session Data: Login timestamps, session duration, logout events and inactivity periods — used for security monitoring and responsible gambling time-tracking features.

PK91 processes your personal data only where a valid lawful basis exists. The lawful bases on which we rely are as follows:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you — including Account creation, transaction processing, KYC completion and customer support — is carried out on the basis that it is necessary to perform the contract between us.
• Legal Obligation: Certain processing activities — including anti-money laundering (AML) checks, regulatory reporting and retention of transaction records — are carried out because we are legally required to do so under applicable law.
• Legitimate Interests: We process certain data on the basis of our legitimate interests in operating a safe, fair and commercially viable platform. This includes fraud prevention, security monitoring, internal analytics and service improvement, provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where we send marketing communications or deploy non-essential cookies, we do so only where you have provided clear and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

PK91 uses personal data for the following purposes:

• Account Management: Creating and maintaining your Account, verifying your identity, processing deposits and withdrawals, and providing customer support.
• Regulatory Compliance: Conducting KYC and AML checks, retaining records as required by applicable law, and responding to requests from competent authorities.
• Fraud Prevention & Security: Detecting and investigating suspicious activity, preventing unauthorised Account access, and maintaining the integrity of betting markets and casino games.
• Responsible Gambling: Monitoring usage patterns to identify signs of problem gambling, enforcing self-exclusion and limit settings, and facilitating interventions where appropriate.
• Service Improvement: Analysing aggregated, anonymised usage data to improve platform performance, identify technical issues and develop new features that better serve Pakistani users.
• Marketing Communications: Where you have opted in, sending you information about promotions, new features, sports betting markets — including Pakistan cricket, PSL T20 seasons and ICC tournaments — and casino game releases. You may opt out at any time via your Account settings or by contacting support.
• Legal Disputes: Retaining and using data as necessary to establish, exercise or defend legal claims arising in connection with the Service.

PK91 does not sell, rent or trade your personal data to third-party marketing organisations or data brokers under any circumstances. We share personal data with third parties only in the following limited circumstances:

• Payment Processors: To process deposits and withdrawals, we share necessary transaction data with payment service providers. References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah reflect familiar Pakistani payment references only. No endorsement of gambling by any payment provider is implied. Each payment processor operates under its own privacy policy.
• KYC & Identity Verification Providers: We engage specialist third-party providers to carry out identity and age verification. These providers receive only the data necessary to complete verification and are bound by strict confidentiality and data processing agreements.
• Fraud Prevention Services: We share risk-relevant data with fraud-detection providers and industry-wide responsible gambling registries to prevent misuse of the platform and protect vulnerable users.
• Analytics Providers: Aggregated and pseudonymised usage data may be shared with analytics platforms to help us understand how users interact with the Service. Individual user identities are not disclosed to analytics providers.
• Legal & Regulatory Authorities: We will disclose personal data to law enforcement agencies, regulatory bodies or courts where required by applicable law, a valid legal process or to protect the rights, property or safety of PK91, its users or the public.
• Corporate Transactions: In the event of a merger, acquisition or sale of all or part of PK91's business, personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third-party Data Processors engaged by PK91 are required to enter into written data processing agreements that obligate them to process personal data only for specified purposes, maintain appropriate security standards and not to engage sub-processors without our prior written consent.

PK91 uses cookies and similar tracking technologies to operate the Service, remember your preferences and analyse platform usage. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the Service to function. These include session authentication cookies, security tokens and load-balancing cookies. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your preferences — such as language settings, responsible gambling limit configurations and login state — so you do not need to re-enter them on each visit.
• Analytics Cookies: Used to collect pseudonymised data about how users navigate the Service, which pages are most visited and where technical errors occur. This data helps us improve the platform. Analytics cookies are deployed only where you have consented.
• Marketing Cookies: Used — with your consent — to deliver relevant promotional content based on your browsing and betting activity. You may withdraw consent at any time via the cookie preference centre accessible in the platform footer.

You may control cookie preferences through your browser settings. Please note that disabling certain categories of cookies may impair the functionality of the Service. Most modern browsers allow you to view, block or delete cookies via their privacy or security settings menus.

PK91 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account & KYC Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, to meet AML, regulatory and legal obligations.
• Transaction Records: Deposit, withdrawal and betting transaction logs are retained for a minimum of five (5) years from the date of each transaction, in line with financial record-keeping requirements.
• Support Communications: Customer support records, including live chat transcripts and email correspondence, are retained for three (3) years from the date of the final interaction in the relevant case.
• Marketing Data: Retained only while you remain subscribed to marketing communications and for up to twelve (12) months following opt-out, to ensure suppression lists are maintained accurately.
• Technical & Usage Logs: Server and access logs are retained for up to thirteen (13) months and are then anonymised or deleted, except where retention is required for an active security investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with industry-standard data destruction procedures.

PK91 implements a comprehensive set of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your device and PK91 servers is encrypted using TLS 1.2 or higher. Our SSL certificate status is publicly verifiable.
• Encryption at Rest: Sensitive personal data stored in our databases — including KYC documents and financial records — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorised personnel whose roles require it. Role-based access controls, multi-factor authentication and session timeout policies are enforced across all internal systems.
• Audit Logging: All access to personal data by internal staff is logged and subject to periodic review. Anomalous access patterns trigger automated alerts.
• Penetration Testing: PK91 engages independent security specialists to conduct regular penetration testing and vulnerability assessments of the platform infrastructure.
• Incident Response: We maintain a formal data breach response procedure. In the event of a breach likely to result in risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours and affected users without undue delay, as required by applicable law.

PK91 operates internationally and may transfer your personal data to servers, processors or affiliates located outside your country of residence — including outside Pakistan. Such transfers may occur in connection with KYC verification, fraud prevention, payment processing or platform hosting services.

Where personal data is transferred to a jurisdiction that does not offer an equivalent level of data protection to that applicable in the originating jurisdiction, PK91 ensures that appropriate safeguards are in place, which may include:

• Standard Contractual Clauses (SCCs) or equivalent contractual safeguards approved by a competent data protection authority.
• Binding Corporate Rules where transfers occur within the PK91 group of entities.
• Adequacy decisions issued by a relevant supervisory authority confirming that the destination country offers adequate data protection.

By using the Service, you acknowledge that your personal data may be transferred and processed in jurisdictions outside Pakistan. If you have questions about the specific safeguards applied to any particular transfer, please contact our Data Protection team using the details in Section 14.

Subject to applicable law and certain exemptions, you hold the following rights in relation to your personal data held by PK91. To exercise any of these rights, please contact us using the details in Section 14. We will respond to verified requests within 30 days.

The Service is strictly intended for adults aged 18 years or above — or the higher minimum age required by the applicable operator or licence jurisdiction. PK91 does not knowingly collect, process or retain personal data relating to individuals under the age of 18.

If we become aware that personal data has been collected from a person below the minimum age without verifiable parental or guardian consent, 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 our support team immediately.

Parents and guardians in Pakistan and elsewhere are strongly encouraged to use device-level parental control software to prevent minors from accessing online gambling platforms, in addition to any controls available within the Service itself.

PK91 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or platform features. The "Last Updated" date at the top of this page indicates when the most recent revision was made.

Where changes are material — meaning they significantly affect your rights or the way we handle your personal data — we will notify you by a prominent notice on the Service and, where we hold a valid email address for your Account, by email. Minor clarifications or corrections may be made without individual notification.

Your continued use of the Service following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you should cease using the Service and may request Account closure in accordance with the Terms & Conditions.

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection team through one of the following channels:

• Live Chat: Available 24/7 via the support widget on the PK91 platform. For data protection queries, please select "Privacy & Data" as the topic on initiation.
• Email: [email protected] (plain text only — not a clickable link; please copy and paste into your email client)
• Response Time: We aim to acknowledge all written privacy requests within 5 business days and to provide a substantive response within 30 calendar days. Complex requests may require additional time; we will notify you if this is the case.

Support is available in English as standard. Urdu-speaking agents are available on request during business hours. When submitting a rights request, please include your registered email address and a description of your request to help us locate your data and respond efficiently.