92pka Privacy Policy — How We Collect, Use, and Protect Your Personal Data

92pka operates 92pka.org — an internationally licensed online casino and sports betting platform serving Pakistani players across Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and all other regions of Pakistan. For the purposes of this Privacy Policy, "92pka", "we", "us", and "our" refer to the operator of the 92pka platform.

92pka is the data controller for all personal data collected through 92pka.org and associated platforms. As data controller, 92pka is responsible for determining the purposes for which, and the means by which, your personal data is processed. Our international gaming licence imposes data protection obligations on 92pka that are reflected throughout this policy.

This Privacy Policy applies to all visitors to 92pka.org, all registered 92pka account holders, and anyone who interacts with 92pka through any channel including live chat, email, or payment systems. It should be read alongside our Terms & Conditions, which are available at 92pka.org/terms-conditions.

92pka collects the following categories of personal data, grouped by type and the stage of your relationship with the platform at which they are typically collected:

92pka does not intentionally collect sensitive personal data relating to race, ethnicity, religion, health conditions, or political opinions. If any such data is incidentally included in documents submitted for KYC purposes, it is used solely to verify your identity and is not otherwise processed.

92pka collects personal data through the following mechanisms:

Data you provide directly when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, respond to promotions, or interact with any form or feature on 92pka.org.

Data collected automatically when you access 92pka.org, including through cookies, web server logs, device fingerprinting technology, and analytics tools. This includes IP addresses, device identifiers, session data, and behavioural usage patterns that 92pka uses for platform security, fraud prevention, and service optimisation.

Data received from third-party service providers engaged by 92pka, including NADRA-integrated KYC verification services for CNIC validation, payment processors (JazzCash, EasyPaisa, and Pakistani banks) who confirm transaction authenticity, and fraud prevention agencies that provide risk scoring based on known patterns of online gaming fraud.

92pka processes personal data on the following legal bases, in accordance with international data protection standards and our licensing obligations:

• Contractual Necessity: Processing required to perform the contract between you and 92pka — including operating your account, processing deposits and withdrawals via JazzCash and EasyPaisa, settling bets, and providing customer support. Without this processing, 92pka cannot deliver its services to you.
• Legal Obligation: Processing required to comply with 92pka's international gaming licence obligations, Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) requirements, and any applicable statutory reporting obligations. This processing cannot be opted out of while you hold a 92pka account.
• Legitimate Interests: Processing necessary for 92pka's legitimate business interests, provided those interests are not overridden by your rights. This includes fraud detection and prevention, platform security monitoring, responsible gaming analysis, and improving the 92pka platform based on aggregated usage data.
• Consent: Where 92pka relies on your consent — for example, for certain categories of marketing communication — you may withdraw that consent at any time by contacting our support team or using the opt-out tools available in your account settings. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

92pka uses your personal data for the following specific purposes:

• Account Creation and Management: Registering your 92pka account, verifying your identity via CNIC, maintaining your account settings, and managing your login and session security.
• Service Delivery: Processing your bets on cricket (including PSL and T20 internationals), casino games, slots, lottery, and fishing games; crediting winnings to your PKR balance; and executing deposits and withdrawals via your chosen Pakistani payment method.
• KYC and Identity Verification: Verifying your identity, age (21+), and payment method ownership as required by 92pka's gaming licence and AML obligations.
• Fraud Prevention and Platform Security: Monitoring for suspicious account activity, detecting and preventing multi-accounting, identifying bonus abuse patterns, and protecting 92pka and its players from financial fraud.
• Responsible Gaming: Analysing gaming activity patterns to identify signs of problematic gambling behaviour, administering self-imposed limits and self-exclusion requests, and proactively intervening where 92pka's responsible gaming monitoring identifies at-risk players.
• Customer Support: Responding to your enquiries, resolving disputes, and maintaining records of your support interactions for quality assurance and regulatory purposes.
• Legal and Regulatory Compliance: Maintaining the records required by our gaming licence, responding to lawful requests from regulatory and law enforcement authorities, and reporting suspicious financial activity as required by AML obligations.
• Platform Improvement: Analysing anonymised and aggregated usage data to understand how Pakistani players interact with 92pka, identify areas for improvement, and develop new features and game categories.
• Communications: Sending you account-related notifications (deposit confirmations, withdrawal processing updates, security alerts), promotional communications where you have consented to receive them, and responsible gaming reminders.

92pka does not sell your personal data. We share personal data only in the following limited and controlled circumstances:

Third-party companies engaged by 92pka to provide specific services required to operate the platform. These include KYC identity verification providers (integrated with NADRA for CNIC validation), payment processors handling JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank transactions, gaming software providers whose games are accessible on 92pka, fraud prevention and risk management services, IT infrastructure and cloud hosting providers, and customer support platform operators. Each service provider is bound by a data processing agreement that prohibits use of your data for any purpose other than delivering the specified service.

92pka may disclose personal data to its gaming regulator, financial intelligence units, or law enforcement authorities where required by law, court order, or regulatory direction. Such disclosures are made only to the extent necessary and in compliance with applicable legal requirements.

In the event of a merger, acquisition, or sale of all or substantially all of 92pka's assets, personal data held by 92pka may be transferred to the acquiring entity. Players will be notified of any such transfer and the privacy policy applicable to their data following the transaction.

92pka uses cookies and similar tracking technologies to operate the platform securely, remember your preferences, and understand how Pakistani players use the site. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the basic functioning of 92pka.org — including login session management, security token storage, and load balancing. These cannot be disabled without preventing you from using the platform.
• Functional Cookies: Remember your preferences and settings — such as your preferred display language, stored JazzCash or EasyPaisa account details, and game lobby filters — to provide a more personalised experience on return visits.
• Analytics Cookies: Collect anonymised data about how users navigate 92pka.org — which pages are visited, how long sessions last, and which features are used most — to help 92pka improve the platform experience for Pakistani players.
• Security Cookies: Used by 92pka's fraud detection systems to identify unusual device or behaviour patterns that may indicate account compromise or fraudulent activity.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use 92pka. Disabling analytics cookies will not affect your ability to play, bet, or transact on the platform.

92pka is an internationally licensed platform, and some of the service providers and gaming software partners used to deliver the 92pka experience may process or store personal data outside of Pakistan. This includes cloud hosting infrastructure and game streaming servers that may be located in various international data centre regions.

Where personal data is transferred internationally, 92pka ensures that appropriate safeguards are in place to protect that data to a standard consistent with our licensing obligations. These safeguards may include contractual data transfer agreements, standard contractual clauses, or reliance on the adequacy decisions of the relevant regulatory authority.

All international transfers of financial data — including payment processing records related to JazzCash, EasyPaisa, and Pakistani bank transactions — are conducted through payment processors who comply with PCI-DSS security standards. 92pka does not transmit raw payment credentials to any international server.

92pka implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 92pka.org;
• Encrypted storage of sensitive personal data, including CNIC information and financial records, using AES-256 encryption at rest;
• Role-based access controls ensuring that 92pka staff can only access personal data where it is necessary for their specific job function;
• Two-factor authentication requirements for all 92pka internal system access;
• Regular penetration testing and security audits of 92pka's platform infrastructure;
• Real-time intrusion detection and prevention systems monitoring for anomalous access patterns;
• Secure, encrypted backup systems with geographically separated storage for disaster recovery purposes.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 92pka will notify affected players without undue delay and in accordance with the notification obligations imposed by our gaming licence. We will provide details of the nature of the breach, the data affected, and the steps we have taken or intend to take to address it.

92pka retains personal data for the following periods, or longer where required by law or regulatory obligation:

• Account Data (Identity, Contact, Financial): Retained for the duration of your active account plus a minimum of five (5) years following account closure, as required by our gaming licence's AML and record-keeping obligations.
• KYC Documentation: CNIC copies, selfies, and supporting identity documents are retained for a minimum of five (5) years from the date of submission, or from the date of account closure, whichever is later.
• Transaction Records: All deposit and withdrawal records — including JazzCash, EasyPaisa, and bank transaction data — are retained for a minimum of five (5) years to satisfy anti-money laundering reporting requirements.
• Gaming Activity Data: Bet and game history records are retained for a minimum of three (3) years from the date of each activity, or five (5) years where they form part of an AML or dispute investigation record.
• Communications Data: Support chat transcripts and email correspondence are retained for three (3) years from the date of the interaction.
• Technical and Behavioural Data: Retained in anonymised or aggregated form for up to twenty-four (24) months from collection for platform analytics purposes.

Upon expiry of the applicable retention period, personal data is securely and permanently deleted or irreversibly anonymised. Players who close their 92pka account should be aware that their data will be retained for the regulatory retention periods above even after account closure.

As a 92pka player, you have the following rights in relation to your personal data. To exercise any of these rights, contact 92pka's data compliance team at [email protected] with "Data Rights Request" in the subject line. 92pka will respond to all valid requests within thirty (30) days.

As part of the registration and KYC process, 92pka verifies the age of every account holder against their CNIC data. Automated age-check controls are applied at registration to prevent underage access. Where 92pka discovers or reasonably suspects that personal data has been collected from a person under 21 — whether through a falsified CNIC, a borrowed identity, or any other means — 92pka will immediately:

• Suspend and subsequently permanently close the account;
• Void all bets and gaming activity associated with the account;
• Forfeit all funds in the account (including deposits) in accordance with our Terms & Conditions;
• Securely delete all personal data associated with the underage account beyond what is required for regulatory reporting;
• Report the incident to the relevant gaming regulatory authority.

If you are a parent or guardian and believe that a person under 21 in your household has accessed 92pka using falsified credentials, please contact us immediately at [email protected] so that we can take the above steps without delay. 92pka also recommends the use of parental control software on shared devices to prevent underage access to online gaming platforms.

The 92pka platform may reference or interact with third-party services including gaming software providers, payment gateway interfaces for JazzCash and EasyPaisa, and KYC verification tools. While 92pka selects and audits these providers carefully and requires them to comply with data protection obligations contractually, 92pka is not responsible for the privacy practices of third-party service providers once data is transmitted to their systems for the purpose of service delivery.

Where 92pka's platform integrates live game streams from third-party providers such as Evolution Gaming, Pragmatic Play Live, or similar licensors, those game sessions involve the transmission of certain technical data (such as your session token and game ID) to the provider's servers for the purpose of delivering the game. Such transfers are governed by 92pka's data processor agreements with each provider and do not involve the transfer of your identity or financial data.

92pka does not endorse any third-party website or service and is not responsible for the content or privacy practices of any external platform.

92pka reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, platform services, regulatory requirements, or applicable law. The "Last Updated" date at the top of this document and in the page header reflects when the most recent revision was published.

When material changes are made to this Privacy Policy — meaning changes that significantly affect your rights or the way your data is processed — 92pka will notify you by one or more of the following means: a prominent notice on 92pka.org, an email notification to your registered address, or an in-platform message. Minor clarificatory changes that do not affect the substance of data processing will be published without individual notification.

Your continued use of 92pka following publication of a revised Privacy Policy constitutes your acknowledgement of the updated document. If you do not agree with any material change to this Privacy Policy, you should stop using 92pka and submit an account closure request before the effective date of the change.

If you have any questions, concerns, or requests relating to this Privacy Policy or 92pka's handling of your personal data, please contact our data compliance team using the following contact details:

• Email: [email protected] — Subject line: "Privacy / Data Request"
• Live Chat: Available 24/7 on 92pka.org — identify your enquiry as a "Privacy Matter"
• Response Time: 92pka will acknowledge all privacy-related enquiries within 48 hours and provide a substantive response within 30 calendar days.

If you are dissatisfied with 92pka's response to a privacy-related complaint, you have the right to escalate your complaint to the data protection supervisory authority in your jurisdiction or to the regulatory authority under whose licence 92pka operates. 92pka will provide details of the applicable regulatory authority on request.

92pka is committed to resolving all privacy complaints fairly, promptly, and transparently. We treat all privacy complaints as serious matters and escalate unresolved complaints internally to senior management for review.