Privacy Policy

This Privacy Policy (the "Policy") describes how PKR939 ("we", "us", "our" or the "Platform") collects, uses, stores, shares and protects the personal data of users ("you", "your") who access or use the pkr939 website at https://pkr939.cam and all associated services and features.

By registering an Account on pkr939 or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with any aspect of this Policy, please discontinue use of the Platform and contact our support team to close your Account.

This Policy should be read in conjunction with our Terms & Conditions, which are incorporated by reference. Where this Policy and the Terms & Conditions address the same subject, this Policy governs with respect to personal data matters.

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

PKR939, operating through the website at https://pkr939.cam, acts as the Data Controller in respect of personal data collected through the Platform. As Data Controller, we are responsible for determining why and how your personal data is processed.

pkr939 is not affiliated with any Pakistani government authority, financial institution, payment provider or regulatory body. The Platform does not claim authorisation from the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any provincial authority with respect to data processing activities.

For all data protection queries, requests to exercise your rights, or complaints, please contact our Data Protection contact using the details provided in Section 16 (Contact Us) of this Policy.

pkr939 collects personal data in the following categories, depending on your interaction with the Platform:

4.1 Registration Data

When you create a pkr939 Account, we collect: full legal name, date of birth, email address, mobile phone number, residential address (including city — for example Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) and account credentials (username and encrypted password).

4.2 Identity Verification (KYC) Data

To verify your identity and age, we may collect copies of government-issued identity documents such as a valid CNIC (Computerised National Identity Card) or passport, proof of address documents, and biometric verification data (such as a selfie photograph or liveness check image) where required.

4.3 Financial and Transaction Data

We collect records of deposits, withdrawals, wagers placed and winnings received. We also collect payment method reference information (for example, the type of payment channel used — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah) necessary to process and verify transactions. We do not store full payment card numbers or mobile wallet PINs.

4.4 Usage and Behavioural Data

We automatically collect data about how you interact with the Platform, including: pages visited, features used, games played, session duration, betting patterns, device type, operating system, browser type and version, IP address and general geographic location derived from IP.

4.5 Communications Data

When you contact our customer support team, we retain records of the communication including chat transcripts, email correspondence and any attachments submitted. This data is retained to resolve disputes, improve support quality and maintain a record of regulatory compliance interactions.

4.6 Responsible Gambling Data

Where you interact with responsible gambling tools — including deposit limits, session controls, cool-off periods or self-exclusion requests — we record those preferences and the circumstances of their activation. This data is used solely to enforce your responsible gambling settings and to identify where proactive intervention may be appropriate.

We use personal data collected through the Platform for the following purposes:

pkr939 processes personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you have accepted — including operating your Account and processing transactions.
• Legal Obligation: Processing required to comply with applicable laws, including AML regulations, licensing conditions and court orders.
• Legitimate Interests: Processing carried out to pursue legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring and service improvement — provided those interests are not overridden by your fundamental rights.
• Consent: Processing for marketing communications and certain non-essential cookie activities, where we have obtained your prior consent. You may withdraw consent at any time by contacting support or adjusting your account settings.

pkr939 does not sell, rent or otherwise disclose your personal data to third parties for their independent commercial use. Data is shared only in the following limited circumstances:

7.1 Service Providers (Data Processors)

We engage third-party service providers who process personal data on our behalf under written data processing agreements. These include: payment processing services, identity verification (KYC) providers, fraud detection services, cloud hosting providers and customer support software platforms. All processors are contractually required to handle data only for specified purposes and to maintain equivalent security standards.

7.2 Regulatory and Law Enforcement Authorities

We may disclose personal data to regulatory bodies, law enforcement agencies or courts where required to do so by applicable law, court order, or where disclosure is necessary to protect the legal rights of pkr939 or third parties.

7.3 AML and Fraud Prevention Services

Personal data may be shared with licensed anti-money laundering screening services and fraud prevention databases for the purpose of verifying the legitimacy of transactions and detecting prohibited activity. Such sharing is conducted under strict confidentiality obligations.

7.4 Business Transfers

In the event of a merger, acquisition, sale of assets or other corporate restructuring involving pkr939, personal data held by the Platform may form part of the transferred assets. Affected users will be notified of any material change to the Data Controller's identity.

pkr939 and its service providers may process or store personal data outside Pakistan, including in countries where the operator's licensing jurisdiction is located and where cloud infrastructure providers maintain data centres.

Where personal data is transferred internationally, pkr939 takes steps to ensure that appropriate safeguards are in place to protect the data in accordance with this Policy. Such safeguards may include contractual clauses requiring the recipient to apply equivalent data protection standards.

Pakistan does not currently operate a comprehensive data protection framework equivalent to, for example, the EU's General Data Protection Regulation (GDPR). pkr939 nonetheless applies data protection principles consistent with recognised international standards. Users acknowledge that by using the Platform they consent to such cross-border transfers as described in this section.

pkr939 retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to the following general principles:

• Active Account Data: Retained for the full duration of the Account relationship plus any mandatory post-closure retention period required by law or licensing conditions.
• Transaction Records: Financial transaction records, including deposits, wagers and withdrawals, are typically retained for a minimum of five (5) years from the date of the transaction for AML compliance purposes. The applicable period may be longer depending on the licensing jurisdiction's requirements.
• KYC Documents: Identity verification documents are retained in accordance with AML regulations applicable to the operator's licensing jurisdiction, typically for a minimum of five (5) years following Account closure.
• Communications Data: Customer support communications are retained for up to two (2) years from the date of the interaction unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Consent Records: Records of consent given or withdrawn for marketing communications are retained for the duration of the account relationship and for a period thereafter sufficient to demonstrate compliance.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

pkr939 uses cookies and similar technologies (including local storage and session identifiers) to operate the Platform, maintain session security, remember your preferences and collect anonymised usage analytics. The table below describes the categories of cookies used:

You may manage cookie settings through your browser preferences at any time. Please note that disabling strictly necessary cookies will prevent the Platform from functioning correctly. For further information about managing cookies, refer to your browser's support documentation.

pkr939 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction or alteration:

• Transport Layer Encryption: All data transmitted between your device and pkr939 is encrypted using SSL/TLS protocols. The padlock icon in your browser confirms an active HTTPS connection.
• Password Security: Account passwords are stored using one-way cryptographic hashing. pkr939 employees cannot view your password in plain text.
• Two-Factor Authentication (2FA): Where available, 2FA adds a second verification step to Account login, significantly reducing the risk of unauthorised access.
• Access Controls: Internal access to personal data is restricted to authorised personnel who require it to perform their duties. Access is logged and reviewed.
• Secure KYC Submission: Identity documents must be submitted only through the Platform's official HTTPS verification portal. Never send sensitive documents through unsecured channels or third-party applications.
• Incident Response: pkr939 maintains procedures for detecting, containing and responding to personal data security incidents. Where a breach is identified that is likely to affect your rights, we will notify affected users promptly.

Subject to applicable law and regulatory retention obligations, you have the following rights with respect to personal data that pkr939 holds about you. To exercise any of these rights, contact our support team using the details in Section 16.

pkr939 will respond to verified rights requests within thirty (30) days where reasonably practicable. We may require verification of your identity before processing a rights request to protect against unauthorised data disclosure. Where a request is refused or partially refused, we will provide written reasons.

pkr939 is strictly an adults-only platform. The Platform is not directed at, and does not knowingly collect personal data from, any person under the age of 18, or the higher minimum age required by the operator's license jurisdiction.

If pkr939 becomes aware that personal data has been collected from a minor without appropriate parental consent, we will take immediate steps to delete that data and close the associated Account. All funds held in such an Account will be withheld pending investigation.

If you believe that a minor has accessed the Platform or provided personal data without authorisation, please contact our support team immediately.

The pkr939 Platform may reference or link to third-party websites, applications or services. This Policy applies only to data processed by pkr939 and does not extend to any third-party platform. pkr939 is not responsible for the privacy practices, terms of service or data security standards of any third-party operator.

You are encouraged to review the privacy policies of any third-party platforms you access through or in connection with pkr939 before providing them with personal data.

pkr939 reserves the right to update or revise this Privacy Policy at any time. Where changes are material — affecting the nature of data collected, how it is used or your rights — we will provide advance notice by email to registered Account holders and/or by a prominent notice on the Platform.

Minor updates, such as clarifications that do not alter the substance of the Policy, may be made without specific notification. The effective date displayed at the top of this Policy will be updated whenever changes are made.

Your continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Policy. If you do not accept the revised Policy, you must discontinue use of the Platform and contact support to request Account closure.

For all privacy-related queries, requests to exercise your data rights, concerns about how your personal data is being processed, or to report a potential data security incident, please contact the pkr939 team using the details below.

Email addresses are displayed as plain text only and are not clickable links. Please copy the address manually into your email client.

For responsible gambling queries, self-exclusion requests or account restriction concerns, please also visit our dedicated Responsible Gambling page.