pakgem Privacy Policy — How We Handle Your Personal Data

1.1  pakgem, operating the platform accessible at pakgem.asia, is the data controller responsible for the personal data of all registered account holders. As data controller, pakgem determines the purposes and means by which your personal data is processed and is accountable under this Privacy Policy and applicable data protection principles for the lawful handling of that data.

1.2  All privacy-related queries, data subject requests, and complaints may be directed to pakgem's support team at [email protected] (displayed as plain text — this address is not a clickable link). Our team will acknowledge receipt of all privacy-related communications within five (5) business days and provide a substantive response within thirty (30) calendar days.

2.1  Information You Provide Directly. When you register a pakgem account, complete KYC verification, make deposits or withdrawals, participate in promotions, or contact our support team, you provide us with personal data that we process for the purposes described in this policy. This includes identity documents, contact details, payment account references, and any information you voluntarily share during support interactions.

2.2  Information Collected Automatically. When you access and use the pakgem Platform, certain technical and usage data is collected automatically by our systems. This includes your IP address, the type and version of browser and operating system you are using, device identifiers, page views, session durations, click paths, login timestamps, and geolocation data derived from your IP address. This data is used to maintain Platform security, detect and prevent fraud, and improve the player experience.

2.3  Information from Third Parties. pakgem may receive personal data about you from third-party sources in limited circumstances. These include identity verification service providers who assist with KYC compliance, payment processors who confirm the status of transactions involving your JazzCash or EasyPaisa wallet, and fraud prevention services that provide signals about potentially suspicious account activity.

pakgem uses your personal data for the following specific purposes:

• Account Creation and Management: To register and maintain your pakgem account, authenticate your identity at login, and communicate essential account information to you;
• Payment Processing: To process PKR deposits via JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, 1LINK, and Cash OTC, and to process withdrawal requests to your verified payment method;
• KYC and Regulatory Compliance: To verify your identity and age in compliance with our operating licence obligations and applicable anti-money laundering regulations;
• Responsible Gaming: To monitor betting and gaming patterns that may indicate problematic gambling behaviour, to administer self-exclusion and deposit limit tools, and to communicate responsible gaming information where appropriate;
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, bonus abuse, account takeovers, and other prohibited activities;
• Customer Support: To handle queries, complaints, and disputes raised through our live chat, email, and other support channels;
• Service Improvement: To analyse aggregated usage data to improve Platform performance, game selection, and the overall player experience;
• Marketing Communications: To send you promotional offers, bonus notifications, and tournament invitations — only where you have opted in to receiving such communications. You may withdraw consent for marketing communications at any time.

pakgem processes your personal data under the following legal bases, depending on the specific processing activity:

Contractual Necessity

Processing is necessary to perform the contract between you and pakgem — including account registration, game access, payment processing, and support services. Without this processing, we cannot provide the Platform services you have requested.

Legitimate Interests

pakgem processes certain data categories — including technical data for Platform security and gaming data for responsible gaming monitoring — where we have a legitimate interest in doing so that is not overridden by your fundamental rights and freedoms.

Legal Obligation

Some processing is required by applicable law. This includes identity verification and record-keeping obligations under anti-money laundering regulations, and the retention of transaction records for regulatory audit purposes.

Consent

Where we rely on your consent — principally for direct marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

5.1  pakgem does not sell, rent, or trade your personal data to third parties for their own marketing purposes. Your data is shared only in the circumstances described below.

5.2  Service Providers. pakgem shares personal data with third-party service providers who assist in delivering the Platform's services. These include: payment processors (including JazzCash and EasyPaisa network operators) for transaction processing; KYC and identity verification service providers; casino game software suppliers who host game infrastructure; cloud hosting and data storage providers; fraud detection service providers; and customer support platform operators. All such providers are contractually bound to process your data only for the specified purposes and to maintain appropriate security standards.

5.3  Regulatory and Law Enforcement Authorities. pakgem may be required to disclose personal data to regulatory bodies, licensing authorities, anti-money laundering agencies, or law enforcement authorities where such disclosure is required by law, a court order, or a legitimate regulatory request. We will notify you of such disclosures where we are legally permitted to do so.

5.4  Business Transfers. In the event of a merger, acquisition, or sale of all or part of pakgem's business assets, personal data held by pakgem may be transferred to the acquiring entity. You will be notified of any such transfer and of any change to this Privacy Policy that results from it.

6.1  pakgem uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that enable us to recognise your browser, maintain your session state between pages, and collect usage analytics.

6.2  The cookies used on pakgem can be categorised as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your pakgem account between pages. These cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate the Platform — which pages are visited, how long sessions last, and what causes players to exit. This data is used exclusively to improve Platform design and performance.
• Functional Cookies: Remember your preferences — such as game lobby filters, preferred language, or responsible gaming settings — so you do not need to reconfigure them each session.
• Marketing Cookies (Consent Required): Used only where you have provided explicit consent, to track the effectiveness of promotional campaigns and to ensure you do not receive the same promotional message repeatedly.

6.3  You may manage cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies will affect the functionality of your pakgem account.

pakgem retains personal data for defined periods determined by the nature of the data and the purpose for which it was collected:

• Account and Identity Data: Retained for a period of five (5) years following the closure of your pakgem account, in compliance with our regulatory obligations and to enable the resolution of any post-closure disputes;
• Financial and Transaction Records: Retained for seven (7) years following the relevant transaction date, in compliance with anti-money laundering record-keeping requirements;
• KYC Documentation: Retained for the duration of your account and for five (5) years following account closure;
• Support and Communications Records: Retained for three (3) years following the date of the relevant communication;
• Technical and Session Logs: Retained for twelve (12) months, after which they are deleted or fully anonymised;
• Marketing Preference Data: Retained until you withdraw your consent for marketing communications, at which point your contact details are removed from all active marketing lists within thirty (30) days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

8.1  pakgem implements a layered security framework designed to protect personal data against unauthorised access, accidental loss, destruction, or alteration. Our security measures include:

• TLS encryption for all data in transit between your device and our servers;
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and payment account references;
• Access controls ensuring that personal data is accessible only to pakgem personnel and service providers who require it for a legitimate operational purpose;
• Regular internal and external security assessments of Platform infrastructure;
• Automated monitoring systems that detect and alert on unusual access patterns or potential data breach attempts;
• Incident response procedures that enable us to detect, contain, and notify affected parties of any confirmed data breach within the timeframes required by applicable regulations.

8.2  While pakgem takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials. If you suspect that your account has been compromised, contact pakgem support immediately.

Subject to applicable data protection principles, you hold the following rights in respect of your personal data held by pakgem. To exercise any of these rights, submit a request to our support team. We will verify your identity before processing any data subject request and will respond within thirty (30) calendar days.

10.1  Age verification is a mandatory step in the pakgem registration process. All account holders are required to confirm they are 21 or older at registration, and to provide identity documentation confirming this upon request by our KYC team.

10.2  Where pakgem identifies or receives credible information that a registered account holder is under the age of 21, the account will be immediately suspended and permanently closed. All personal data associated with that account will be deleted from our active systems within thirty (30) days of the closure determination, subject only to the retention of records required for the investigation of the underage access itself.

10.3  If you are a parent or guardian and you believe that a person under 21 in your care has registered an account on pakgem, please contact our support team immediately. We will investigate the matter and take appropriate action without delay.

11.1  The delivery of pakgem's services may involve the transfer of your personal data to third-party service providers located outside Pakistan. Such transfers may include the use of cloud infrastructure, game software hosting services, or KYC verification platforms operated in other jurisdictions.

11.2  Where personal data is transferred internationally, pakgem ensures that appropriate safeguards are in place to protect the transferred data. These safeguards may include: contractual data protection clauses binding the recipient to standards equivalent to those applied by pakgem; the selection of recipients in jurisdictions that provide an adequate level of data protection under applicable standards; and technical measures including encryption of data in transit.

11.3  You may request information about the specific safeguards applied to any international transfer of your personal data by contacting our support team.

12.1  pakgem reserves the right to update this Privacy Policy at any time. When we make changes, the revised policy will be published on this page with an updated effective date. Where changes are material — meaning they affect how we process your data in ways that differ significantly from what this policy currently describes — we will provide advance notice to registered account holders via email or in-platform notification before the changes take effect.

12.2  Your continued use of the pakgem Platform following the publication of a revised Privacy Policy constitutes your acknowledgement of the revised policy. If you do not accept the revised terms, you may close your account as described in our Terms and Conditions.

12.3  We recommend reviewing this page periodically, particularly before making deposits or engaging with new Platform features, to ensure you are comfortable with the current privacy terms applicable to your use.

13.1  All privacy-related enquiries, data subject access requests, and complaints should be addressed to pakgem's support team. Our contact email is [email protected] — displayed here as plain text and not a clickable link. Live chat support is available 24 hours a day, 7 days a week, in both English and Urdu.

13.2  We will acknowledge all privacy-related communications within five (5) business days and provide a substantive written response within thirty (30) calendar days. Where a request is particularly complex or where you have made multiple requests, we may notify you within the initial thirty-day period if additional time is required, in which case our response will follow within sixty (60) days of the original request.

13.3  Where you are not satisfied with pakgem's response to a privacy-related complaint, you may escalate the matter through the complaint procedures established by pakgem's applicable international gaming regulatory authority.