pk35 Privacy
Policy

1 Introduction

This Privacy Policy ("Policy") describes how pk35 ("pk35", "we", "us", "our") collects, uses, stores, and protects the personal information of individuals ("Player", "User", "you") who register for or use the pk35 online casino and sports betting platform available at pk35.bet ("the Platform").

pk35 is committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner. This Policy is designed to give you a clear and honest account of our data practices so that you can make informed decisions about your use of the Platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy. By registering an account or continuing to use the pk35 Platform, you acknowledge that you have read and understood this Privacy Policy.

2 Data Controller

pk35 acts as the data controller in respect of all personal data collected through the Platform. As data controller, pk35 determines the purposes for which and the means by which personal data is processed. All data processing activities are conducted in accordance with the requirements of our international gaming license and applicable data protection principles.

For all privacy-related enquiries, including data subject rights requests, you may contact our Data Protection team directly at:

3 Data We Collect

pk35 collects personal data through several channels, including your registration form, ongoing account activity, payment transactions, and your technical interactions with the Platform. The categories of data we collect are set out below:

3.1 Registration & Identity Data

• Full legal name as it appears on your CNIC
• Computerised National Identity Card (CNIC) number and a scanned copy or photograph of your CNIC
• Date of birth (used to verify the 21+ age requirement)
• Pakistani mobile phone number
• Account username and encrypted password
• City and province of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad, Peshawar)

3.2 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts in PKR and timestamps
• Payment method details (JazzCash mobile account number, EasyPaisa wallet number, HBL / UBL / Meezan Bank account reference — stored in tokenised form only)
• Bonus credit and wagering activity records
• Account balance history

3.3 Gaming & Betting Activity Data

• Bet placement history, including market selections, stake amounts, and outcomes
• Game session data for casino products including Dragon Gate, Rummy, slots, and live casino tables
• Session duration and frequency records
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, session reminders activated)

3.4 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system version, and browser type
• Device fingerprint (used for fraud prevention and duplicate account detection)
• Session logs, including login timestamps and access events

3.5 Communications Data

• Records of communications between you and pk35 support, including live chat transcripts, email correspondence, and support ticket history
• Responses to surveys or feedback requests, where voluntarily submitted

4 How We Use Your Data

pk35 uses the personal data we collect for the following specific purposes. We do not use your data for any purpose not listed here without first obtaining your explicit consent or updating this Policy accordingly.

5 Legal Basis for Processing

pk35 processes your personal data on the following legal bases, consistent with the requirements of our international gaming license and applicable data protection law:

• Contractual necessity: Processing required to fulfil our obligations to you under the pk35 Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws, regulatory requirements, anti-money laundering obligations, and the conditions of our international gaming license — including identity verification and transaction reporting.
• Legitimate interests: Processing carried out in pk35's legitimate business interests where those interests are not overridden by your privacy rights, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics.
• Consent: Processing carried out on the basis of your explicit, freely given consent — specifically in the context of optional marketing communications. You may withdraw consent for marketing at any time through your account settings or by contacting [email protected].

6 Data Sharing & Disclosure

pk35 does not sell, rent, or trade your personal data to any third party. We share personal data only in the following limited and controlled circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive the minimum data necessary to process your deposit and withdrawal transactions. These providers are independently licensed and operate under their own data protection frameworks.
• Identity verification providers: Where required by our KYC obligations, CNIC data and verification documents may be shared with our licensed identity verification service provider for the sole purpose of validating your identity.
• Regulatory authorities: pk35 may be required to disclose player data to our gaming license authority, financial intelligence units, or law enforcement agencies where such disclosure is required by law or by the conditions of our gaming license.
• Fraud prevention services: Device fingerprint data and anonymised behavioural signals may be shared with licensed fraud prevention platforms for the purpose of detecting and preventing cheating, bonus abuse, and financial crime.
• Legal proceedings: In the event of a legal dispute, court order, or regulatory investigation, pk35 may disclose relevant player data as required by due legal process.

7 Data Retention

pk35 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by our regulatory and legal obligations. The following retention periods apply:

• Account and identity data: Retained for the duration of your active account plus a minimum of 5 years following account closure, in line with our anti-money laundering obligations under our gaming license conditions.
• Transaction records: All financial transaction records are retained for a minimum of 5 years from the date of the transaction for AML compliance and regulatory audit purposes.
• Gaming activity logs: Retained for a minimum of 3 years for responsible gaming monitoring, dispute resolution, and regulatory compliance purposes.
• Support communications: Retained for 2 years from the date of the last communication in a support thread, unless the communication relates to an ongoing dispute or compliance matter.
• Marketing consent records: Retained for the duration of your consent and for 2 years following withdrawal of consent, to evidence compliance with consent requirements.
• Anonymised analytics data: Retained indefinitely, as no personal data can be re-identified from anonymised datasets once the anonymisation process is complete.

Upon expiry of the applicable retention period, personal data is securely deleted from pk35's systems or anonymised so that it can no longer be associated with any individual.

8 Cookies & Tracking Technologies

pk35 uses cookies and similar tracking technologies on the Platform for the purposes described below. Cookies are small text files stored on your device when you visit the Platform.

• Essential cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and cookies that remember your login state. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Used to remember your preferences such as language settings, responsible gaming tool configurations, and last-visited game categories. These improve your experience but are not strictly necessary.
• Analytics cookies: pk35 uses anonymised, first-party analytics to understand how players navigate the Platform, which game categories are most visited, and where technical issues are occurring. These analytics do not use any personally identifiable information.

pk35 does not use third-party advertising cookies, social media tracking pixels, or cross-site behavioural profiling technologies of any kind on the Platform.

You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling essential cookies may prevent certain features of the pk35 Platform from functioning correctly.

9 Data Security

pk35 implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, loss, disclosure, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the pk35 Platform.
• AES-256 encryption for all sensitive data at rest within pk35's database infrastructure.
• Tokenisation of all payment credentials — full payment account numbers are never stored on pk35 servers.
• Role-based access controls ensuring that pk35 staff can only access the player data necessary for their specific job function.
• Multi-factor authentication required for all pk35 administrative system access.
• Regular security penetration testing and vulnerability assessments conducted by independent third-party security firms.
• 24/7 automated monitoring for anomalous access patterns and data exfiltration attempts.

While pk35 takes all reasonable steps to protect your data, no system connected to the internet can be guaranteed to be 100% secure. You also play an important role in protecting your account by safeguarding your login credentials and enabling two-factor authentication through your account settings.

10 International Data Transfers

pk35 is operated under an international gaming license, and certain data processing activities — including infrastructure hosting, fraud screening, and identity verification — may involve the transfer of personal data to servers or service providers located outside of Pakistan.

Where such transfers occur, pk35 ensures that appropriate safeguards are in place to protect the security and integrity of your data, consistent with the requirements of our gaming license and international data protection best practices. These safeguards include contractual data processing agreements with all third-party processors and restrictions on how those processors may use the data shared with them.

pk35 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual safeguards.

11 Your Data Rights

As a pk35 player, you hold the following rights in respect of your personal data. To exercise any of these rights, submit a written request to [email protected] with "Privacy Request" in the subject line. pk35 will respond within 30 days of receiving your request.

• Right of access: You have the right to request a copy of all personal data pk35 holds about you, along with information about how it is being used and with whom it has been shared.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held on your account. Minor corrections such as name spelling or contact details can also be made 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, subject to pk35's legal and regulatory retention obligations. Note that data subject to mandatory retention periods under our gaming license cannot be deleted before those periods expire.
• Right to restrict processing: You have the right to request that pk35 temporarily restricts the processing of your data while a dispute or review is in progress.
• Right to data portability: You have the right to receive a copy of the personal data you have provided to pk35 in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent — specifically for marketing communications — you have the right to withdraw that consent at any time with immediate effect, without affecting the lawfulness of processing carried out before withdrawal.
• Right to object: You have the right to object to processing carried out on the basis of pk35's legitimate interests where you believe your privacy rights outweigh those interests.

12 Children & Minors

The pk35 Platform is strictly intended for individuals aged 21 years and older. pk35 does not knowingly collect, use, or retain personal data belonging to anyone under the age of 21.

pk35 enforces a mandatory age verification process at registration, requiring CNIC submission and date of birth confirmation. Any account found to have been opened by a person under 21 years of age will be closed immediately, and any associated personal data will be deleted in accordance with our underage player policy.

If you believe that a minor has accessed the pk35 Platform or that pk35 has inadvertently collected personal data belonging to a minor, please contact us immediately at [email protected]. We will investigate and take corrective action without delay.

13 Third-Party Services

The pk35 Platform may reference or provide access to third-party services including payment gateways (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) and identity verification providers. Once you leave the pk35 Platform and interact with a third-party service, your data is governed by that service's own privacy policy and data practices.

pk35 is not responsible for the privacy practices, data security standards, or content of any third-party services. We encourage you to review the privacy policies of any third-party providers you interact with in connection with your pk35 account.

14 Marketing Communications

pk35 may send you promotional communications — including information about bonuses, new game launches, PSL betting promotions, and platform updates — where you have provided your explicit consent to receive such communications at registration or through your account settings.

• Marketing communications are sent via your registered mobile number (SMS) only.
• You may withdraw consent for marketing messages at any time by updating your communication preferences in your account settings, or by contacting [email protected] with the subject line "Unsubscribe".
• Withdrawal of marketing consent will take effect within 5 business days. You may continue to receive transactional messages (deposit confirmations, withdrawal notifications, security alerts) regardless of your marketing preference, as these are necessary for account operation.
• pk35 does not share your contact details with third-party marketers under any circumstances.

15 Policy Amendments

pk35 reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or gaming license conditions. When material changes are made, we will notify registered players via their registered mobile number and will publish the updated Policy on the Platform with a revised effective date clearly displayed at the top of the document.

Your continued use of the pk35 Platform following notification of any material amendment constitutes your acceptance of the updated Privacy Policy. If you do not accept the amended Policy, you should cease using the Platform and close your account before the effective date of the change.

16 Contact & Complaints

If you have any questions, concerns, or complaints about how pk35 processes your personal data, or if you wish to exercise any of your data rights as described in Section 11, please contact our Data Protection team:

If you are not satisfied with pk35's handling of your privacy complaint following our internal review, you may escalate the matter to the data protection authority or dispute resolution body designated by our international gaming license jurisdiction. Details of the relevant authority will be provided in pk35's written response to your initial complaint.