pakgem Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") applies to all personal data collected and processed by pakgem ("pakgem", "we", "us", "our") in connection with your use of the pakgem website, mobile browser interface, casino and sports betting services, and all associated features and communications (collectively the "Services").

1.2 By registering a pakgem account, making a deposit, or otherwise using the Services, you acknowledge that you have read this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you should not use the pakgem platform.

1.3 This Policy should be read alongside the pakgem Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference.

1.4 pakgem is committed to handling personal data in a manner consistent with applicable data protection principles including lawfulness, fairness, transparency, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

2. Personal Data We Collect

2.1 pakgem collects personal data in the following categories depending on how you interact with the platform:

2.2 Where pakgem asks you to provide personal data that is mandatory (such as CNIC for KYC), failure to provide that data will prevent you from accessing certain features such as withdrawals.

2.3 pakgem does not collect or store full payment card numbers. Card transactions are processed through PCI DSS-compliant payment processors who handle card data independently of pakgem's systems.

3. How We Use Your Personal Data

3.1 pakgem uses the personal data collected for the following purposes:

• Account creation and management: To register your pakgem account, verify your identity via CNIC, maintain your account settings and PKR balance, and process your login credentials securely.
• Payment processing: To process deposits and withdrawals via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Visa/Mastercard, and USDT TRC20. Your financial data is shared with payment processors only to the extent necessary to complete the transaction.
• KYC and fraud prevention: To verify that all users are aged 18 or over, to detect and prevent fraudulent activity, money laundering, and any other prohibited conduct as described in the pakgem Terms & Conditions.
• Service delivery: To provide access to casino games, sports betting markets, live dealer tables, and all other features of the pakgem platform.
• Responsible gaming: To monitor usage patterns that may indicate problematic gambling behaviour and to enable the delivery of responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods.
• Customer support: To respond to support requests submitted by Pakistani users via email or live chat.
• Marketing: To send promotional emails regarding pakgem bonuses, new games, and platform updates, where you have consented to receive such communications. You may withdraw consent at any time.
• Legal obligations: To comply with applicable legal, regulatory, and law enforcement requirements.

4. Legal Basis for Processing

4.1 pakgem processes personal data on the following legal bases:

• Contract performance: Processing necessary to provide the Services under the pakgem Terms & Conditions, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws including anti-money laundering (AML) obligations, age verification requirements, and law enforcement requests.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of the Services, where our interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications, where you have provided explicit consent. You may withdraw consent at any time by contacting [email protected].

5. Data Sharing & Third Parties

5.1 pakgem does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

5.2 We may share personal data with the following categories of third-party service providers engaged to support our Services:

• Payment processors: JazzCash, Easypaisa, and banking partners (HBL, UBL, Meezan Bank, Bank Alfalah) receive transaction data necessary to process PKR deposits and withdrawals.
• KYC/identity verification providers: Third-party identity verification services receive CNIC data for the purpose of age and identity verification.
• Game software providers: Casino game providers may receive anonymised usage data for game performance monitoring purposes.
• Fraud prevention services: Anti-fraud providers receive technical and behavioural data to detect prohibited activity.
• Customer support platforms: Support ticket and chat data is processed by our support infrastructure providers.

5.3 All third-party processors engaged by pakgem are contractually required to process personal data only in accordance with pakgem's instructions and to maintain appropriate security measures.

5.4 pakgem may disclose personal data to regulatory authorities, law enforcement bodies, or courts where required to do so by applicable law or valid legal process.

6. Cookies & Tracking Technologies

6.1 pakgem uses cookies and similar tracking technologies on its platform for the following purposes:

• Essential cookies: Required for the platform to function, including maintaining your login session and remembering your currency preference (PKR).
• Analytics cookies: Used to understand how Pakistani users navigate the platform so that we can improve the user experience. Analytics data is aggregated and anonymised where possible.
• Security cookies: Used to detect and prevent fraudulent login attempts and other security threats.

6.2 You can manage cookie preferences through your browser settings. Disabling essential cookies will prevent you from using core platform features including the pakgem login and cashier functions.

7. Data Retention

7.1 pakgem retains personal data for as long as your account remains active and for a period after closure as required by our legal and regulatory obligations. Specific retention periods are as follows:

• Account and identity data (including CNIC records): Retained for the duration of account activity and for a minimum of 5 years following account closure, in accordance with AML record-keeping requirements.
• Transaction data (PKR deposits, withdrawals, bet history): Retained for 5 years from the date of each transaction.
• Customer support records: Retained for 3 years from the date of the last support interaction.
• Marketing consent records: Retained until you withdraw consent and for 1 year thereafter.

7.2 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised.

8. Data Security

8.1 pakgem implements industry-standard technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the pakgem platform;
• Encrypted storage of sensitive account data including CNIC information and financial records;
• Access controls ensuring that personal data is accessible only to authorised pakgem personnel who require it to perform their role;
• Regular security assessments and penetration testing of platform infrastructure;
• Two-factor authentication support for all pakgem user accounts.

8.2 Despite these measures, no internet transmission or electronic storage system is completely secure. In the event of a data breach that poses a significant risk to your rights and interests, pakgem will notify affected users and relevant authorities as required by applicable law.

9. Your Data Rights

9.1 Subject to applicable law, you have the following rights in relation to the personal data that pakgem holds about you:

• Right of access: You may request a copy of the personal data pakgem holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data in certain circumstances, subject to our legal retention obligations.
• Right to restriction: You may request that pakgem restrict processing of your data in certain circumstances.
• Right to object: You may object to processing based on legitimate interests, including profiling for marketing purposes.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.

9.2 To exercise any of these rights, please submit a written request to [email protected] including your full name, registered email address, and a description of the right you wish to exercise. pakgem will respond within 30 days.

10. Children's Privacy

11. Changes to This Privacy Policy

11.1 pakgem may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. The date of the most recent revision is displayed at the top of this page.

11.2 Where changes are material, pakgem will notify registered users via email to their registered address or by displaying a prominent notice on the platform. Continued use of the Services following the effective date of revised Terms constitutes acceptance of the updated Policy.

11.3 We encourage you to review this Policy periodically. The current version will always be published at pakgem.net/privacy-policy.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the manner in which pakgem processes your personal data, please contact the pakgem Data Team at: