Privacy Policy
Your Data, Protected by 93pak

1. Introduction

93pak ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of every user ("you", "your") who accesses our sports betting, live casino, and slot services. This Privacy Policy ("Policy") has been prepared in accordance with internationally recognised data protection principles and the requirements of our licensing jurisdiction.

This Policy applies to all personal data collected through the 93pak website at https://93pak.org, our mobile-optimised interfaces, our customer support channels, and any other touchpoints through which you interact with the 93pak brand. It should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of your overall agreement with 93pak.

We take our data protection responsibilities seriously. 93pak does not sell your personal data to third parties for their own commercial purposes. We collect only what we genuinely need, we use it only for the purposes described in this Policy, and we retain it only for as long as is necessary or required by law. Pakistani players can use 93pak with confidence that their personal information is in safe hands.

2. Data Controller

93pak acts as the data controller in respect of all personal data collected through the Platform. As data controller, 93pak determines the purposes for which your personal data is processed and the means by which that processing takes place. Where 93pak engages third-party service providers to process data on its behalf, those providers act as data processors and are bound by contractual data processing agreements that restrict their use of your data to the specific services they provide to 93pak.

All data protection queries, subject access requests, and complaints should be directed to the 93pak data protection contact detailed in Section 14 of this Policy.

3. Data We Collect

3.1 Registration Data

When you create a 93pak account, we collect the information you provide directly, including:

• Full legal name
• Date of birth
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Faisalabad)
• Email address and/or mobile number
• Username and encrypted password
• Preferred currency (Pakistani Rupees / PKR)

3.2 Identity Verification (KYC) Data

In compliance with our Know Your Customer obligations, we may collect:

• Government-issued photo identification (CNIC, passport, or driving licence)
• Proof of address documents (utility bills, bank statements)
• Payment method ownership documentation (e.g., JazzCash or EasyPaisa account screenshots)
• Selfie or liveness verification images where required

3.3 Financial and Transaction Data

We collect records of all financial activity associated with your 93pak account, including:

• Deposit and withdrawal amounts, dates, and payment method references
• Transaction identifiers from JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT TRC20 transfers
• Betting and gaming history, including stakes, odds, outcomes, and settlement details
• Bonus and promotion redemption records

3.4 Technical and Usage Data

When you access 93pak, we automatically collect certain technical data, including:

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Pages visited, features used, and time spent on the Platform
• Session logs, click paths, and search queries within the Platform
• Cookie identifiers and similar tracking technologies (see Section 9)

3.5 Communications Data

We retain records of communications between you and 93pak, including support tickets, live chat transcripts, email correspondence, and responsible gaming interaction records. These records help us maintain service quality, resolve disputes, and fulfil our compliance obligations.

4. How We Use Your Data

The table below summarises the key purposes for which 93pak uses your personal data:

Where 93pak relies on your consent as the legal basis for processing — in particular for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. You can withdraw marketing consent from within your account settings or by contacting our support team.

5. Legal Basis for Processing

93pak processes your personal data on the following legal grounds:

• Contract Performance: Processing is necessary to fulfil our contractual obligations to you, including operating your account, processing your bets, and handling deposits and withdrawals in PKR via JazzCash, EasyPaisa, and partner banks.
• Legal Obligation: Processing is required to comply with our obligations under applicable gaming regulations, AML frameworks, tax laws, and other statutory requirements. This includes age verification (21+), KYC, and suspicious transaction reporting.
• Legitimate Interests: Processing is necessary for the legitimate interests of 93pak or third parties, provided those interests are not overridden by your rights. This includes fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics.
• Consent: Where we rely on your consent — for example, for sending promotional emails or SMS messages about new 93pak offers — we will always obtain this consent clearly and separately, and you may withdraw it at any time.

6. Sharing Your Data

93pak does not sell, rent, or trade your personal data to third parties. We may share your data only in the following circumstances and only to the minimum extent necessary:

6.1 Service Providers and Data Processors

We engage trusted third-party service providers who process data on our behalf under strict contractual data processing agreements. These include:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, SadaPay, and USDT TRC20 gateway providers — to facilitate PKR transactions.
• KYC and identity verification providers: To carry out age verification, document checks, and liveness detection.
• Game studio providers: Evolution Gaming, Pragmatic Play, and other certified game suppliers — limited session and account reference data only.
• Fraud prevention and AML screening services: To detect and prevent financial crime and account abuse.
• Customer support platform providers: To manage and track support interactions.
• Analytics providers: Aggregated, anonymised usage data to help us improve the 93pak platform.

6.2 Legal and Regulatory Disclosures

We may disclose your personal data to regulatory bodies, law enforcement agencies, or courts where required by applicable law, licensing obligations, court order, or other legal process. In such cases, 93pak will disclose only the data strictly required and will notify you where legally permitted to do so.

6.3 Business Transfers

In the event that 93pak undergoes a merger, acquisition, or sale of assets, your personal data may be transferred to the successor entity. You will be notified in advance of any such transfer and informed of your rights in relation to your data in that context.

7. Data Retention

93pak retains your personal data for as long as your account is active and for such further period as is required to fulfil the purposes described in this Policy or to comply with applicable legal and regulatory requirements.

As a general guide:

• Account and KYC records are retained for a minimum of five years following account closure, in line with standard AML record-keeping requirements.
• Transaction and betting records are retained for a minimum of five years to support dispute resolution, audit, and regulatory reporting.
• Communications data (support tickets, live chat transcripts) is retained for up to three years following the closure of the relevant support interaction.
• Marketing consent records are retained for as long as necessary to demonstrate consent and for three years following its withdrawal.
• Technical and usage logs are typically retained for twelve months in identifiable form, after which they may be retained in aggregated, anonymised format indefinitely for analytical purposes.

Where retention beyond these periods is required by applicable law, regulatory instruction, or ongoing legal proceedings, 93pak will retain the relevant data for the duration of that requirement. When data is no longer required, it is securely deleted or anonymised in accordance with our internal data destruction procedures.

8. Data Security

93pak implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 93pak platform.
• Encryption at rest for sensitive data categories, including KYC documents and financial records, stored on our servers.
• Access controls and role-based permissions ensuring that only authorised 93pak personnel can access personal data, and only to the extent required for their specific role.
• Two-factor authentication (2FA) available on all 93pak player accounts and enforced for all staff with access to personal data systems.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Incident response procedures to detect, contain, and report any personal data breaches within the timeframes required by applicable regulation.

While 93pak takes all reasonable and practicable steps to protect your data, no system or network can guarantee absolute security. You play an important role in keeping your account secure — please use a strong, unique password for your 93pak account and enable two-factor authentication at the earliest opportunity. If you suspect your account has been accessed by an unauthorised party, contact our support team at once.

9. Cookies & Tracking Technologies

93pak uses cookies and similar tracking technologies to operate the Platform, remember your preferences, detect fraud, and — where you have consented — deliver relevant promotional content. The categories of cookies we use are as follows:

You can manage your cookie preferences at any time through the cookie consent panel available on the 93pak platform. Please note that disabling strictly necessary cookies will affect your ability to use core Platform features including logging in and placing bets. Withdrawing analytics or marketing cookie consent does not affect your access to 93pak services.

10. Your Rights

As a user of the 93pak platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team using the details in Section 14:

• Right of Access: You have the right to request a copy of the personal data 93pak holds about you. We will provide this within a reasonable period and at no cost for standard requests.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request that 93pak delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing. Note that certain data may be retained to meet our legal and regulatory obligations even following an erasure request.
• Right to Restriction of Processing: In certain circumstances, you may request that 93pak restrict the processing of your personal data — for example, while the accuracy of data is being verified.
• Right to Data Portability: Where processing is based on your consent or on a contract with you, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to have it transferred to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data based on 93pak's legitimate interests. We will consider your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: If you believe 93pak has handled your personal data unlawfully, you have the right to lodge a complaint with the relevant supervisory authority in our licensing jurisdiction.

11. Minors & Age Verification

93pak is strictly a 21+ platform. We do not knowingly collect personal data from individuals under the age of 21. Our registration process includes an age declaration step, and our KYC verification procedures are designed to identify and reject underage applicants.

If 93pak discovers that personal data has been collected from a user who is under 21 years of age, we will immediately suspend the account, void any associated transactions, and securely delete the data to the fullest extent possible. Any balance will be returned to the verified payment source after review.

Parents and guardians who believe that a minor has registered a 93pak account should contact our support team immediately at [email protected]. We will investigate and take appropriate action without delay. We strongly encourage the use of parental control software to prevent minors from accessing online gambling platforms.

12. International Data Transfers

As an internationally operated platform, 93pak may transfer your personal data to service providers and infrastructure providers located outside of Pakistan. Where such transfers occur, 93pak ensures that appropriate safeguards are in place to protect your data, including:

• Contractual data processing agreements incorporating standard contractual clauses or equivalent transfer mechanisms recognised by our licensing jurisdiction.
• Transfer only to jurisdictions or recipients that provide an adequate level of data protection as assessed by 93pak or recognised by applicable international frameworks.
• Ongoing assessment of the data protection standards applied by international service providers.

Your personal data will never be transferred to a jurisdiction or recipient that does not meet 93pak's data protection standards. If you require further information about the safeguards governing international transfers of your data, please contact our support team.

13. Changes to This Privacy Policy

93pak reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform features. When we make material changes to this Policy, we will:

• Post the updated Policy to this page with a revised "Last Updated" date.
• Where the changes are significant, notify registered users via email or an in-platform notification prior to the changes taking effect.
• Where required by applicable law, seek fresh consent for new processing activities before they commence.

Your continued use of the 93pak platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We strongly recommend reviewing this Policy periodically to stay informed of how 93pak handles your personal data. The version date at the top of this page always reflects the most current revision.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 93pak handles your personal data, please get in touch with our data protection team:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Coverage: Serving players across Pakistan — Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and beyond

For responsible gaming concerns, self-exclusion requests, or problem gambling support, please visit our dedicated Responsible Gaming page, where you will find full details of available tools and resources. Our support team is trained to handle these matters with the highest level of sensitivity and without delay.