Privacy Policy
92pak2 Platform

This Privacy Policy ("Policy") describes how 92pak2 ("92pak2", "we", "us", "our"), operator of the online gaming and sports betting information platform at https://92pak2.cam (the "Platform"), collects, uses, stores and protects personal data relating to individuals who access or use the Platform ("User", "you", "your").

This Policy forms part of your agreement with 92pak2 and should be read alongside our Terms & Conditions and Responsible Gambling Policy. By using the Platform, you acknowledge that you have read and understood this Policy.

92pak2 is committed to handling your personal data lawfully, fairly and transparently. We collect only the data we genuinely need, use it for clearly defined purposes, and maintain appropriate safeguards at every stage of processing.

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, date of birth, IP address, device identifiers and financial account information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means 92pak2, the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party engaged by 92pak2 to process Personal Data on its behalf, such as payment processing or analytics providers.
• "KYC" means Know Your Customer — the identity and age verification procedures required under applicable compliance obligations.
• "Cookies" means small text files placed on your device by the Platform to store preferences and session information.
• "Special Category Data" means sensitive Personal Data, including health information, that may be collected in limited circumstances such as responsible gambling self-exclusion requests.

92pak2 collects the following categories of Personal Data, depending on how you interact with the Platform:

• Full legal name and date of birth.
• Email address and mobile phone number.
• Residential address, including city and postal code.
• Username and encrypted account password.
• Account preferences and responsible gambling settings.

• Government-issued photo identification (e.g., Pakistani CNIC, passport, driving licence).
• Proof of address documents (e.g., utility bill or bank statement dated within 3 months).
• Payment method verification documents (e.g., screenshot of registered Easypaisa or JazzCash account, or bank statement from HBL, UBL, Meezan Bank or Bank Alfalah — for payment ownership verification only).

• Deposit and withdrawal amounts, dates and associated payment method identifiers.
• Account balance and transaction history.
• Cryptocurrency wallet addresses where applicable (BTC, USDT).

• IP address, browser type, device type and operating system.
• Session duration, pages visited and navigation paths.
• Geolocation data (country/region level) derived from IP address.
• Log files and error reports.

• Records of support interactions via Live Chat, Help Center and email.
• Feedback, complaints and correspondence submitted to 92pak2.

• Self-exclusion requests and status.
• Deposit, loss and session time limits you have set.
• Responsible gambling assessment responses where applicable.

We collect Personal Data through the following means:

• Directly from you: when you register an account, complete KYC, make a deposit or withdrawal, contact support, or set responsible gambling controls.
• Automatically: through cookies, server logs and analytics tools when you browse or use the Platform.
• From third parties: where permitted by law, we may receive verification data from identity verification providers, fraud prevention databases and payment processors to support KYC and AML compliance.

92pak2 processes Personal Data only where a valid legal basis exists. The following table sets out our primary processing activities and their corresponding legal bases:

92pak2 uses the Personal Data it collects for the following purposes:

• To create, manage and secure your account on the Platform.
• To verify your identity and age in compliance with KYC obligations.
• To process deposits, withdrawals and account transactions accurately.
• To detect, investigate and prevent fraud, money laundering and other financial crimes.
• To administer and enforce responsible gambling controls, including self-exclusion, deposit limits and session time restrictions.
• To provide customer support and respond to your enquiries, complaints or account queries.
• To send you transactional communications relating to your account (e.g., deposit confirmations, withdrawal status updates, security alerts).
• To send promotional communications where you have provided explicit consent — you may opt out at any time.
• To analyse platform usage patterns and improve the features and performance of the Platform.
• To comply with applicable legal, regulatory and contractual obligations.

92pak2 does not sell, rent or trade your Personal Data to third-party marketing organisations. We share data only in the following limited and controlled circumstances:

• Service Providers (Data Processors): Third-party providers engaged to support Platform operations, including payment processors, identity verification services, cloud hosting providers, analytics platforms and customer support tools. All processors are bound by data processing agreements that restrict use of your data to the specific service they provide.
• Compliance and Law Enforcement: Where required by applicable law, court order, regulatory authority or to prevent fraud and financial crime, we may disclose Personal Data to competent authorities.
• Responsible Gambling Databases: Where you have registered a self-exclusion, relevant information may be shared with recognised self-exclusion schemes in the applicable licence jurisdiction, as required by the operator's regulatory obligations.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of the 92pak2 business, Personal Data may be transferred to the successor entity, subject to equivalent privacy protections.

We retain your Personal Data for as long as necessary to fulfil the purposes for which it was collected, subject to the following principles:

• Active Accounts: Personal Data is retained for the duration of your active account relationship with 92pak2.
• Closed Accounts: Following account closure, we retain transaction records, KYC documents and correspondence for a minimum of five years to comply with anti-money laundering and regulatory record-keeping obligations. The exact retention period may be longer depending on applicable law.
• Self-Exclusion Records: Data relating to self-exclusion is retained for the full duration of the exclusion period plus any applicable regulatory retention requirement.
• Marketing Data: Where you have withdrawn consent to marketing communications, your opt-out preference is retained indefinitely to ensure we do not contact you again without fresh consent.
• Technical Logs: Server logs and analytics data are retained for up to 24 months unless longer retention is required for security or fraud investigation purposes.

Once the applicable retention period expires, Personal Data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual.

92pak2 implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, disclosure or destruction, including:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encrypted storage of passwords using industry-standard hashing algorithms. We never store your password in plain text.
• Access controls ensuring that only authorised personnel can access Personal Data, on a strict need-to-know basis.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Secure disposal protocols for physical and digital data that is no longer required.

While we apply robust safeguards, no internet-based platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights, we will notify affected users and relevant authorities in accordance with applicable requirements.

The Platform uses cookies and similar technologies to enhance your experience, keep you signed in, and understand how users interact with our content.

• Strictly Necessary: Required for the Platform to function. Cannot be disabled. Examples include session authentication cookies that keep you logged in.
• Functional: Remember your preferences such as language, currency display (PKR) and responsible gambling settings.
• Analytics: Help us understand how users navigate the Platform so we can improve performance and content. Data is aggregated and anonymised where possible.
• Marketing / Targeting: Used only where you have consented, to measure the effectiveness of our communications. You may withdraw consent at any time.

You can manage or delete cookies at any time through your browser settings. Disabling certain cookies may affect Platform functionality. For detailed guidance on managing cookies in popular browsers, please refer to your browser's help documentation.

Subject to applicable law and certain exceptions, you have the following rights in relation to your Personal Data:

• Right of Access: You may request a copy of the Personal Data we hold about you, together with information about how and why we process it.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You may request that we limit how we use your Personal Data in certain circumstances, for example while a rectification request is being considered.
• Right to Data Portability: Where processing is based on your consent or contract performance, you may request your data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests, including profiling and direct marketing. Marketing opt-outs take effect immediately.
• Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team via the Help Center or email [email protected]. We will acknowledge your request within 2 business days and respond substantively within 30 days. Complex requests may require additional time, in which case we will notify you of the extended timeline.

The Platform is strictly for adults aged 18 and above, or the higher minimum age required by the operator or applicable licence jurisdiction. 92pak2 does not knowingly collect Personal Data from individuals under the minimum required age.

Age verification is a mandatory part of the KYC process. If we become aware that a minor has registered an account or submitted Personal Data, we will promptly suspend the account, delete the associated data and decline any associated transactions.

If you believe that a minor has accessed or registered on the Platform, please notify us immediately at [email protected] so that we can take appropriate action without delay.

92pak2 operates internationally and may transfer Personal Data to servers or service providers located outside Pakistan. Where such transfers occur, we implement appropriate safeguards to ensure that your data receives a level of protection consistent with the standards described in this Policy, including contractual obligations on data processors and, where applicable, standard contractual clauses or equivalent mechanisms.

By using the Platform, you acknowledge that your Personal Data may be transferred to and processed in countries outside Pakistan. This is not legal advice; users should seek independent guidance if they have concerns about cross-border data transfers applicable to their specific situation.

92pak2 reserves the right to update this Privacy Policy at any time. When we make material changes, we will publish a prominent notice on the Platform and, where practicable, notify you by email to your registered address. The date of the most recent update is shown at the top of this page.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the changes. If you do not agree with any update to this Policy, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have concerns about how your Personal Data is being handled, please contact us through any of the following channels:

• Live Chat: Available 24/7 via your account dashboard. The fastest route for urgent data or account queries.
• Help Center: Comprehensive self-service resources accessible from your account settings, including guided data subject request forms.
• Email: [email protected] — please use the subject line "Privacy Request" for data rights enquiries. Do not include passwords or full payment credentials in email communications.

We aim to acknowledge all privacy-related enquiries within 2 business days and to provide a full response within 30 days. English and Urdu support is available.