Privacy Policy

pk09 ("pk09", "we", "us", or "our") operates the online betting and casino information platform accessible at https://pk09.cam (the "Platform"). This Privacy Policy describes how pk09 collects, uses, stores, shares, and protects personal data relating to users ("you", "your") who access or interact with the Platform.

pk09 is an independent, English-language information and educational platform targeting Pakistani users. We do not directly operate casino games or accept sports bets. Our Platform provides content about betting markets, casino gaming, responsible gambling tools, and payment methods relevant to Pakistan, including payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, and Bank Alfalah. These payment references are provided for educational and contextual purposes only and do not imply that those providers endorse or facilitate gambling transactions.

This Privacy Policy should be read in conjunction with our Terms & Conditions and Responsible Gambling Policy, which together form the complete legal framework governing your use of the Platform.

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

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to names, contact details, identification numbers, device identifiers, and usage behaviour data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, and deletion.
• "Data Controller" means pk09, which determines the purposes and means by which Personal Data is processed.
• "Data Processor" means any third party engaged by pk09 to process Personal Data on pk09's behalf in accordance with this Policy.
• "User" means any individual who accesses, browses, or interacts with the Platform, whether or not a registered account holder.
• "Cookies" means small text files placed on a User's device by a website to store information about that User's browsing activity and preferences.
• "KYC" (Know Your Customer) means identity and age verification procedures required to comply with applicable anti-money-laundering and age-restriction obligations.
• "Applicable Law" means all relevant data protection, privacy, and gambling legislation applicable to a User and to pk09 in the relevant jurisdiction, including applicable Pakistani statutes and any international data protection frameworks.

pk09 may collect the following categories of Personal Data, depending on your level of interaction with the Platform:

We do not intentionally collect sensitive Personal Data (such as religious beliefs, health data, or biometric data) unless specifically required by applicable anti-money-laundering or KYC obligations. If such data is required, we will notify you explicitly at the point of collection.

pk09 collects Personal Data through the following channels:

• Direct interactions: When you register an account, complete a contact form, submit a support enquiry, or otherwise voluntarily provide information to us.
• Automated technologies: When you access the Platform, we automatically collect Technical Data and Usage Data via cookies, server logs, and analytics tools. See Section 10 for full cookie details.
• Third-party sources: We may receive Technical Data from analytics service providers and, where you have consented, from social media platforms or referral partners. We do not purchase Personal Data from data brokers.
• KYC and verification processes: Where age and identity verification is required, we may collect and process identity documents in accordance with applicable anti-money-laundering obligations.

pk09 processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Consent: Where you have freely given, specific, informed, and unambiguous consent to the processing — for example, opting in to communications or accepting non-essential cookies.
• Contractual necessity: Where processing is necessary to perform our obligations to you under the Terms & Conditions, including providing Platform access and support services.
• Legal obligation: Where processing is required to comply with applicable law, such as anti-money-laundering obligations, age verification requirements, or data retention mandates.
• Legitimate interests: Where processing is necessary for pk09's legitimate business interests, provided those interests are not overridden by your fundamental rights and freedoms. This includes fraud prevention, platform security, and product improvement analytics.

Where consent is the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent can be exercised by contacting us at the address in Section 15.

pk09 processes your Personal Data for the following specific, explicit, and legitimate purposes:

We do not use Personal Data for automated decision-making that produces legal or significantly adverse effects on you without human review. Where profiling is used for content personalisation, you may opt out by contacting us.

pk09 does not sell, rent, or trade your Personal Data to third parties. We may share your data in the following limited circumstances:

• Service providers and Data Processors: We engage carefully selected third-party service providers (e.g., hosting providers, analytics platforms, customer support software) who process data solely on our behalf and under contractual data processing agreements. They may not use your data for their own purposes.
• Legal and regulatory disclosure: We may disclose Personal Data when required to do so by applicable law, court order, or lawful request from a competent regulatory or governmental authority. We will notify you of such disclosure where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of assets, Personal Data may be transferred to a successor entity, subject to equivalent privacy protections.
• With your consent: We may share data with third parties where you have provided prior explicit consent to a specific sharing activity.

Payment method providers referenced on pk09 (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are mentioned for Pakistan market educational context only. pk09 does not share User data with these providers, nor does it imply any partnership or data-sharing arrangement with them.

pk09 retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. Our general retention principles are:

• Account data: Retained for the duration of your active account and for a reasonable period thereafter to handle post-closure enquiries, subject to legal retention obligations.
• KYC and identity verification records: Retained in accordance with applicable anti-money-laundering requirements, which may prescribe minimum retention periods of several years.
• Support and communication records: Retained for up to 3 years from the date of the last communication, unless a longer period is required for legal or dispute-resolution purposes.
• Technical and usage data: Typically retained in aggregated or anonymised form for analytics purposes. Where associated with identifiable users, retained for no longer than 13 months from collection.
• Cookie data: Retention periods vary by cookie type — see Section 10 for specific durations.

When retention is no longer necessary, data is securely deleted or irreversibly anonymised. You may request earlier deletion subject to our legal retention obligations — see Section 11 (Your Rights).

pk09 implements appropriate technical and organisational security measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• Encryption: All data transmitted between your browser and the Platform is encrypted using SSL/TLS protocols. Sensitive data at rest is stored with appropriate encryption.
• Access controls: Access to Personal Data within pk09's systems is restricted to authorised personnel on a need-to-know basis, governed by role-based access controls.
• Regular security reviews: We conduct periodic reviews of our data security practices, infrastructure, and third-party processor arrangements.
• Incident response: We maintain documented data breach response procedures. In the event of a breach that poses a risk to your rights and freedoms, we will notify you and relevant authorities in accordance with applicable law.

pk09 uses cookies and similar tracking technologies to operate the Platform, analyse usage, and improve user experience. The following categories of cookies are used:

You may control cookie settings through your browser preferences. Disabling strictly necessary cookies may affect Platform functionality. For performance and targeting cookies, a consent mechanism is presented on your first visit to the Platform.

We do not use cookie data to build profiles for sale to third-party advertisers. Cookie data associated with identifiable users is not shared with any third party beyond our contracted analytics service providers.

Subject to applicable law, you have the following rights in relation to your Personal Data held by pk09:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how and why it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete Personal Data we hold about you.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal retention obligations.
• Right to Restrict Processing: You may request that we restrict the processing of your Personal Data in certain circumstances, for example while accuracy is being verified.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including profiling. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

pk09 does not knowingly collect, store, or process Personal Data relating to children under 18. If we become aware that Personal Data has been collected from a person under the minimum age, we will take immediate steps to delete that data and terminate the relevant account without notice.

Parents and guardians who believe that a minor may have accessed the Platform or submitted Personal Data are encouraged to contact us immediately at [email protected] so that we can take appropriate action.

We strongly encourage parents and guardians to use parental control software to prevent minors from accessing online gambling and gambling-related information content. This responsibility rests with the adult members of the household, not with pk09 alone.

pk09 may transfer Personal Data to third-party service providers or infrastructure located outside the country in which you reside, including countries that may not have data protection laws equivalent to those applicable in your jurisdiction.

Where such transfers occur, pk09 ensures that appropriate safeguards are in place to protect your data, including:

• Contractual data processing agreements incorporating standard data protection clauses;
• Transfers only to jurisdictions or service providers with adequate privacy protections as assessed by pk09; and
• Ensuring that all processors are bound by obligations no less protective than those in this Privacy Policy.

If you are a Pakistani user and have concerns about how your data may be processed outside Pakistan, you are entitled to request information about the safeguards in place by contacting us at the address in Section 15.

pk09 reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, applicable law, or operational requirements. The "Last Updated" date at the top of this page will be revised whenever the Policy is updated.

Material changes — those that significantly affect how we process your Personal Data or your rights in relation to that data — will be communicated to registered users via the email address associated with their account and/or through a prominent notice on the Platform.

Your continued use of the Platform following publication of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, please cease using the Platform and contact us to request deletion of your data.

For any questions, concerns, or requests relating to this Privacy Policy, your Personal Data, or your rights as a data subject, please contact the pk09 Privacy team using the details below.

If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. We encourage you to contact us first so that we can attempt to resolve your concern directly.