Privacy Policy
for pk165 Users

pk165 (referred to in this document as "pk165", "we", "us" or "our") operates the online betting and casino information platform accessible at https://pk165.cam (the "Platform"). We are committed to protecting the privacy and personal data of everyone who uses our Platform.

This Privacy Policy explains how pk165 collects, uses, shares, retains and protects your personal data when you access our Platform, create an account, place wagers, use our customer support services or interact with us in any other way.

By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described here, please do not use the Platform.

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

• "Personal Data" — Any information that identifies or could identify a living individual, directly or indirectly, including name, email address, IP address, device identifiers and payment details.
• "Processing" — Any operation performed on Personal Data, including collection, recording, storage, use, disclosure, deletion and destruction.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, pk165 acts as the Data Controller in respect of the data it processes about you.
• "Data Processor" — A third party that processes Personal Data on behalf of the Data Controller under a written agreement and only on the Data Controller's documented instructions.
• "User" — Any individual who accesses, browses or registers an account on the Platform.
• "KYC" — Know Your Customer — the identity, age and source-of-funds verification process applied to registered account holders before certain account actions are permitted.
• "Cookie" — A small data file stored on your device by the Platform to facilitate session management, analytics and personalisation.

pk165 collects the following categories of Personal Data, depending on how you interact with the Platform:

We do not collect special categories of sensitive Personal Data — such as racial or ethnic origin, health data, or biometric identifiers — except where expressly required for regulatory compliance and with your explicit consent.

pk165 collects your Personal Data through the following means:

• Direct interactions: Data you provide when you register an account, complete the KYC process, make a deposit or withdrawal, contact customer support, participate in promotions, or submit any form or feedback on the Platform.
• Automated technologies: Technical and usage data collected automatically when you visit the Platform, including through cookies, server logs, pixel tags and similar tracking technologies. See Section 8 for further details on our Cookie Policy.
• Third-party sources: Identity and fraud-prevention data received from KYC verification providers, payment processors and fraud-detection services engaged by pk165 as Data Processors.
• Payment providers: Transaction confirmation and status data from payment services used to process your deposits and withdrawals. References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah or other providers are for contextual reference only; pk165 does not receive more payment data than is necessary to confirm transaction status.

Where applicable data protection law requires that processing be conducted on a recognised lawful basis, pk165 relies on one or more of the following:

• Contract performance: Processing necessary to fulfil the agreement between pk165 and you — including operating your account, processing transactions and resolving disputes.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, fraud prevention requirements and obligations imposed by the operator's gaming licence jurisdiction.
• Legitimate interests: Processing necessary for the legitimate interests of pk165 — including platform security, fraud detection, abuse prevention, service improvement and responsible gambling monitoring — where those interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent for specific processing activities, such as sending you promotional communications. You may withdraw consent at any time without affecting the lawfulness of processing already carried out.

pk165 uses the Personal Data it collects for the following purposes:

• Account management: Creating, operating and administering your pk165 account, including processing deposits and withdrawals, applying bonuses and maintaining account preferences.
• Identity and age verification: Conducting KYC checks to confirm that you meet minimum age requirements (18+ or the higher minimum required by the operator's licence jurisdiction) and to verify your identity in accordance with AML obligations.
• Transaction processing: Facilitating and recording your deposits, wagers and withdrawal requests, and reconciling these against payment provider records.
• Security and fraud prevention: Monitoring account activity for signs of fraud, multi-accounting, money laundering, bonus abuse or other prohibited conduct, and taking appropriate action where such conduct is detected.
• Responsible gambling: Monitoring wagering patterns to identify potential problem gambling behaviour and providing access to responsible gambling tools, limit adjustments and self-exclusion where appropriate.
• Customer support: Responding to your enquiries, complaints and requests, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Marketing communications: Sending you promotional offers, newsletters and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: Analysing usage data to understand how users interact with the Platform and to improve features, content and overall user experience.
• Legal compliance: Fulfilling obligations under applicable laws, responding to lawful requests from regulatory or law enforcement authorities, and defending or pursuing legal claims.

pk165 does not sell your Personal Data. We may share your data with the following categories of third parties strictly to the extent necessary to operate the Platform and fulfil our legal obligations:

• KYC and identity verification providers: Third-party services that process identity documents and perform age, identity and source-of-funds checks on our behalf, acting as Data Processors under a written agreement.
• Payment processors: Services that process your deposit and withdrawal transactions. These providers receive only the data required to complete and verify the transaction. They are bound by their own data protection obligations.
• Fraud prevention and security services: Third-party services that help detect and prevent fraud, multi-accounting and money laundering. Data shared is limited to what is necessary for the risk assessment in question.
• IT infrastructure and cloud providers: Services that host Platform infrastructure, databases and backups. These providers process data under strict confidentiality agreements and do not use the data for their own purposes.
• Game and content providers: Game studios and sports data providers whose content is made available via the Platform. Data shared is limited to session and wallet interaction data necessary to operate the game or odds feed.
• Legal and regulatory authorities: We may disclose Personal Data to competent courts, regulators or law enforcement agencies where we are legally required to do so, or where disclosure is necessary to protect our legal rights or the safety of Platform users.

All third parties engaged by pk165 as Data Processors are required to process data only on our documented instructions, to maintain appropriate technical and organisational security measures, and to delete or return data upon termination of the engagement.

pk165 uses cookies and similar technologies to operate and improve the Platform. When you first visit the Platform, you will be asked to consent to the use of non-essential cookies. You may withdraw or adjust your cookie preferences at any time via your browser settings or the Platform's cookie preference tool.

The following categories of cookies are used on the Platform:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication, security tokens and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional cookies: Store your preferences such as language, display settings and in-game configuration to personalise your experience on return visits.
• Analytics cookies: Collect aggregate, anonymised data about how users navigate the Platform — which pages are visited most frequently, where users arrive from and where they exit. This data is used solely for internal improvement purposes.
• Marketing cookies: Used only with your consent to measure the effectiveness of promotional campaigns. pk165 does not use marketing cookies to build third-party advertising profiles.

You can manage cookie preferences at the browser level. Disabling certain cookies may affect the functionality of the Platform, including session persistence and personalised features.

pk165 retains Personal Data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law. The following general retention principles apply:

• Account data: Retained for the duration of your account and for a period thereafter as required by AML regulations and gaming licence obligations — typically a minimum of five years from account closure.
• Transaction records: Financial and wagering transaction records are retained for a minimum of five to seven years in accordance with standard AML and financial record-keeping requirements.
• KYC documents: Identity verification documents are retained for the period required by the operator's licensing jurisdiction, typically five years after the end of the customer relationship.
• Support communications: Customer support records are retained for up to three years from the date of the last interaction, unless a dispute or legal claim requires longer retention.
• Analytics data: Anonymised aggregate analytics data may be retained indefinitely as it cannot be used to identify individual users.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

pk165 implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, alteration or disclosure. These measures include, but are not limited to:

• SSL/TLS encryption for all data in transit between your device and our servers.
• Encrypted storage of sensitive data fields, including passwords and payment method references.
• Role-based access controls ensuring that Personal Data is accessible only to authorised personnel with a demonstrated need.
• Regular security testing and vulnerability assessments of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems that process Personal Data.
• Incident response procedures to contain, investigate and remediate any data security event.

While pk165 takes data security seriously, no transmission over the internet and no data storage system can be guaranteed to be 100% secure. You are responsible for keeping your account credentials confidential and for reporting any suspected unauthorised access promptly via [email protected].

Depending on the data protection laws applicable in your jurisdiction, you may hold some or all of the following rights in relation to your Personal Data held by pk165. We will respond to verified requests within a reasonable period, typically 30 days.

To exercise any of the rights above, please contact our support team at [email protected] with the subject line "DATA RIGHTS REQUEST" and include sufficient information to verify your identity as the account holder.

pk165 is strictly an adults-only Platform. We do not knowingly collect, process or store Personal Data relating to individuals under the age of 18 — or the higher minimum age required by the relevant gaming licence jurisdiction.

If we become aware that Personal Data has been submitted by or on behalf of an individual below the minimum required age, we will immediately close the associated account, delete the Personal Data in question and, where required by applicable law, report the matter to the relevant authority.

If you believe that a minor has registered an account on pk165, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

pk165 may transfer your Personal Data to third-party service providers located in countries other than the country in which you reside. Such transfers may occur in the course of providing KYC verification, hosting infrastructure, payment processing and customer support services.

Where Personal Data is transferred to a jurisdiction that does not provide an equivalent level of data protection, pk165 will implement appropriate safeguards — such as contractual data protection clauses binding the recipient to standards consistent with those applied by pk165 — to ensure that your data remains adequately protected.

By using the Platform and providing your Personal Data, you acknowledge that your data may be transferred, stored and processed in jurisdictions outside Pakistan.

pk165 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or regulatory requirements. The "Last updated" date at the top of this page will be revised whenever a material change is made.

Where a change materially affects the way in which we process your Personal Data, we will endeavour to notify you by email to the address registered on your account or by a prominent notice on the Platform prior to the change taking effect. Your continued use of the Platform after the effective date of an updated Privacy Policy constitutes your acceptance of those changes.

We encourage you to review this Privacy Policy periodically to stay informed about how pk165 is protecting your information.

If you have any questions, concerns or requests relating to this Privacy Policy or the way pk165 handles your Personal Data, please contact our support team using the details below. Please write to us in English to ensure your request is handled promptly.

For erasure or self-exclusion requests, please mark your message "DATA DELETION REQUEST" or "SELF-EXCLUSION REQUEST" respectively to ensure priority routing to the correct team.