Privacy Policy — pak23
pak23 is committed to protecting the personal data of every user who visits or registers on our platform. This Privacy Policy explains what data we collect, why we collect it, how it is used and your rights in relation to it.
How pak23 Handles Your Data
These six principles summarise the most important aspects of the pak23 Privacy Policy. Full details follow in the sections below.
Minimal Data Collection
pak23 collects only the personal data that is genuinely necessary to operate your account, comply with legal obligations and deliver the services you have requested. We do not collect data speculatively or for purposes beyond those stated in this Policy.
Secure Data Storage
All personal data held by pak23 is protected using industry-standard encryption both in transit (TLS) and at rest. Access to personal data is restricted to authorised personnel who require it to perform their specific job function.
No Data Sales
pak23 does not sell, rent or trade your personal data to third parties for marketing or commercial purposes. Data is shared only where strictly necessary for service delivery, legal compliance or fraud prevention, as described in this Policy.
Your Rights Are Respected
You have the right to access, correct, export or request deletion of your personal data at any time. Requests are handled promptly and without charge, subject to applicable legal obligations that may require us to retain certain data.
Breach Notification
In the event of a personal data breach that poses a risk to your rights and freedoms, pak23 will notify affected users without undue delay and in accordance with applicable data protection obligations.
Defined Retention Periods
pak23 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, to comply with legal or regulatory obligations, or to resolve disputes. Data is securely deleted or anonymised when retention is no longer required.
The Journey of Your Data at pak23
Understanding how your data flows through the pak23 platform from collection to deletion helps you make informed decisions about the information you share with us. The diagram opposite illustrates each stage of the data lifecycle under this Policy.
Collection
Data is collected when you register, complete KYC verification, make transactions, interact with support, or browse the platform. We also collect technical data automatically through cookies and server logs.
Processing & Use
Collected data is processed only for the specific purposes described in this Policy — account management, regulatory compliance, fraud prevention, customer support and service improvement. No automated decision-making with significant legal effect is applied without human review.
Storage & Security
Data is stored on secure, encrypted servers. Access controls, audit logs and regular security reviews are applied. Where data is transferred internationally, appropriate safeguards are maintained in accordance with applicable data protection standards.
Sharing
Data is shared only with trusted third-party processors — such as KYC verification providers, payment processors and regulatory bodies — under strict data processing agreements. Data is never sold to third parties for commercial or marketing purposes.
Retention & Deletion
Data is retained for the periods set out in Section 8 of this Policy. When the retention period expires, data is securely deleted or irreversibly anonymised. You may request earlier deletion subject to our legal obligations.
01 Introduction
This Privacy Policy ("Policy") is issued by pak23 ("pak23", "we", "us" or "our") and applies to all personal data collected through the pak23 platform accessible at pak23.cam (the "Platform"), including any associated mobile applications and related services.
pak23 is committed to protecting the privacy and security of the personal data of all users ("you" or "your") who interact with the Platform. This Policy describes:
- The categories of personal data we collect and the sources from which we collect it;
- The purposes for which that data is processed and the legal basis for each purpose;
- The circumstances in which data may be shared with third parties;
- The periods for which data is retained; and
- Your rights in relation to your personal data and how to exercise them.
By using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree to the terms of this Policy, you must cease using the Platform immediately.
02 Definitions
In this Policy, the following terms have the meanings specified below:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person, including name, email address, IP address, device identifiers and financial data. |
| "Processing" | Any operation performed on personal data, whether automated or manual, including collection, storage, use, disclosure, erasure and destruction. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data. In the context of the Platform, pak23 acts as the Data Controller. |
| "Data Processor" | A third party that processes personal data on behalf of pak23, under a binding data processing agreement, and only on pak23's documented instructions. |
| "Consent" | A freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their personal data for a stated purpose. |
| "KYC" | Know Your Customer — the identity verification process by which pak23 confirms a User's identity and address, typically by requesting documentary evidence. |
| "Cookie" | A small text file stored on a User's device by a web browser, used to remember preferences, session state and to support analytics and security functions. |
03 Data Controller Details
pak23 is the Data Controller in respect of all personal data collected through the Platform. As Data Controller, pak23 determines the purposes for which personal data is processed and the means by which that processing is carried out.
For queries relating to this Policy or the exercise of data subject rights, please contact pak23 using the details set out in Section 15 of this Policy. We aim to acknowledge all data-related enquiries within five (5) business days and to resolve them within thirty (30) calendar days, unless the complexity of the request requires additional time, in which case we will advise you accordingly.
04 Data We Collect
pak23 collects personal data in the following categories:
4.1 Data You Provide Directly
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, CNIC number or passport number | Registration and KYC verification |
| Contact Data | Email address, phone number, residential address (city, district, province) | Registration and profile updates |
| Financial Data | Payment method details (masked card numbers, mobile wallet identifiers such as Easypaisa or JazzCash), transaction amounts in PKR, withdrawal account details | Deposit and withdrawal transactions |
| KYC Documents | Copies of government-issued ID (e.g., National Identity Card), proof of address, proof of payment method ownership | KYC verification process |
| Support Data | Contents of support chat transcripts, emails and any documents submitted in connection with a support request | Customer support interactions |
4.2 Data Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device type and screen resolution;
- Usage Data: Pages viewed, features used, session duration, links clicked and referring URLs;
- Location Data: Approximate geolocation derived from IP address (country and city level only — not precise GPS location); and
- Cookie Data: Session identifiers, preference settings and analytics identifiers as described in Section 9.
4.3 Data from Third Parties
pak23 may receive personal data from third-party sources in limited circumstances, including from KYC and identity verification service providers engaged to confirm the accuracy of information you have provided, and from fraud prevention and anti-money laundering databases as part of our regulatory compliance obligations.
05 Data Processing — Purposes & Use
pak23 processes your personal data for the following specific purposes:
- Account Creation and Management: To register your account, verify your identity and manage your ongoing relationship with pak23;
- KYC and Regulatory Compliance: To satisfy our obligations under applicable anti-money laundering (AML), counter-terrorism financing (CTF) and responsible gambling regulations;
- Transaction Processing: To process deposits and withdrawals, verify payment method ownership and maintain accurate financial records;
- Customer Support: To respond to your queries, complaints and support requests, and to maintain records of those interactions;
- Fraud Prevention and Security: To detect, investigate and prevent fraudulent activity, account abuse, money laundering and other prohibited conduct;
- Responsible Gambling: To monitor gambling behaviour patterns for indicators of problem gambling, to enforce self-exclusion requests and to apply deposit, loss and time limits as requested by you or as required by our responsible gambling obligations;
- Platform Improvement: To analyse aggregated usage data in order to improve the functionality, performance and content of the Platform; and
- Legal Obligations: To comply with any applicable legal, regulatory or court-ordered obligations to retain, disclose or report personal data.
06 Legal Basis for Processing
pak23 processes personal data only where a lawful basis exists for doing so. The applicable legal bases are:
- Contractual Necessity: Processing required to perform our contractual obligations to you, including account management, transaction processing and customer support;
- Legal Obligation: Processing required to comply with applicable laws and regulations, including AML, CTF and responsible gambling obligations;
- Legitimate Interests: Processing that is necessary for pak23's legitimate business interests — such as fraud prevention, platform security and service improvement — where those interests are not overridden by your fundamental rights and freedoms; and
- Consent: Where processing is based on consent (for example, in relation to non-essential cookies or direct marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
07 Data Sharing
pak23 does not sell or rent your personal data to third parties. We may share personal data with the following categories of recipients, strictly on a need-to-know basis and under appropriate contractual safeguards:
- KYC and Identity Verification Providers: Third-party services used to verify the accuracy of identity and address documents submitted during the KYC process;
- Payment Processors: Third-party payment service providers through which deposits and withdrawals are routed, including where relevant those connected to mobile wallet and bank transfer infrastructure in Pakistan. Data shared is limited to what is technically required to complete the transaction;
- Fraud and AML Services: External databases and screening tools used to detect fraud, money laundering and other prohibited activity;
- Customer Support Platforms: Third-party helpdesk or live-chat technology providers who process support interaction data on our behalf under binding data processing agreements;
- Regulatory and Legal Authorities: Competent regulatory bodies, law enforcement agencies or courts where pak23 is required or permitted by law to disclose personal data; and
- Corporate Transactions: In the event of a merger, acquisition, sale of assets or other corporate restructuring, personal data may be transferred to a successor entity, subject to equivalent privacy protections.
All third-party Data Processors engaged by pak23 are required to process personal data only on pak23's documented instructions, to maintain appropriate security measures and to comply with applicable data protection obligations.
08 Data Retention Periods
pak23 retains personal data for the following periods, after which data is securely deleted or irreversibly anonymised:
| Data Category | Retention Period | Reason |
|---|---|---|
| Account and Identity Data | 5 years after account closure | AML/CTF regulatory requirements |
| Transaction Records | 5 years after each transaction | Financial record-keeping and AML obligations |
| KYC Documents | 5 years after account closure | Regulatory compliance and dispute resolution |
| Support Interaction Records | 3 years after resolution | Quality assurance and dispute resolution |
| Self-Exclusion Records | Indefinitely (or as required by operator licence) | Prevention of responsible gambling obligations being circumvented |
| Technical and Usage Logs | 12 months | Platform security and fraud prevention |
| Cookie Data | Per cookie type (session to 12 months) | See Section 9 |
Where a legal claim is brought or reasonably anticipated, pak23 may retain relevant personal data beyond the periods above until the claim is resolved or the applicable limitation period expires.
09 Cookies & Tracking Technologies
pak23 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device. The categories of cookies used are as follows:
- Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without impairing basic Platform functionality;
- Performance and Analytics Cookies: Used to collect aggregated, anonymised data about how Users navigate the Platform, which pages are visited most frequently and where errors occur. This data helps us improve the Platform;
- Functionality Cookies: Used to remember your preferences, such as language settings, preferred payment method display and session time-limit preferences; and
- Targeting and Marketing Cookies: Used only where you have given explicit consent. These may be used to present you with relevant promotional content. You may withdraw consent at any time through the cookie preference centre accessible in your Account settings.
You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may limit Platform functionality. For more detailed information on the specific cookies used and their lifespans, please refer to the cookie preference centre on the Platform.
10 Security Measures
pak23 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:
- Transport Layer Security (TLS) encryption for all data in transit between your device and pak23's servers;
- Encryption of sensitive data fields at rest in pak23's databases;
- Role-based access controls ensuring that staff can only access the personal data necessary for their specific job function;
- Regular security assessments, penetration testing and vulnerability scanning;
- Audit logging of access to personal data records, reviewed regularly for anomalous activity; and
- Staff training on data protection obligations and secure data-handling procedures.
Whilst pak23 takes its security obligations seriously, no system is entirely immune to compromise. In the event of a personal data breach that poses a material risk to your rights and freedoms, pak23 will notify affected Users without undue delay.
11 User Rights
Subject to applicable law and certain exemptions, you have the following rights in relation to your personal data held by pak23. To exercise any of these rights, please contact us as described in Section 15.
Right of Access
You may request a copy of the personal data pak23 holds about you, together with information about how it is processed. We will respond within 30 calendar days.
Right to Rectification
You may request correction of any personal data that is inaccurate or incomplete. We encourage you to keep your Account information up to date at all times.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose collected. This right is subject to retention obligations under applicable law.
Right to Restriction
You may request that pak23 restricts the processing of your personal data in certain circumstances, for example while the accuracy of data is being contested.
Right to Portability
Where processing is based on consent or contract and carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
Right to Object
You may object to processing based on legitimate interests. pak23 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
12 Minors & Age Restrictions
The Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. pak23 does not knowingly collect personal data from minors.
Where pak23 becomes aware that personal data has been collected from a person under the applicable minimum age, that data will be deleted as promptly as reasonably practicable and the associated Account will be closed. Any transactions conducted during that period will be reviewed and appropriate action taken in accordance with applicable regulatory requirements.
If you are a parent or guardian and believe that a minor in your care has registered on the Platform, please contact pak23 support immediately using the details in Section 15.
13 International Data Transfers
pak23 may transfer your personal data to countries outside your country of residence where Data Processors or Group companies are located. Where personal data is transferred internationally, pak23 ensures that appropriate safeguards are in place. These safeguards may include:
- Binding data processing agreements that impose equivalent data protection obligations on the recipient;
- Standard contractual clauses approved by a competent data protection authority; or
- Transfers to jurisdictions that provide an adequate level of data protection as determined by applicable law.
You may request further information about the specific safeguards applied to any international transfer of your personal data by contacting us as described in Section 15.
14 Policy Amendments
pak23 reserves the right to update or amend this Privacy Policy at any time. The most current version of the Policy will always be accessible at pak23.cam/privacy-policy. The "Effective Date" at the top of this page will be updated each time a material change is made.
Where changes are material, pak23 will notify registered Users by email or by displaying a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform following the publication of an updated Policy constitutes your acknowledgement of the updated terms.
If you do not accept the updated Policy, you must cease using the Platform and may request account closure in accordance with the Terms and Conditions, accessible at pak23.cam/terms-conditions.
15 Contact Us
For any queries, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the pak23 Data Protection team using the following details:
- Email: [email protected] (plain text — not a clickable link)
- Subject Line: Please include "Privacy Request" in the subject line of your email to ensure it is directed to the appropriate team member without delay;
- Live Chat: Available through the Platform 24/7 — please state at the start of the session that you have a data protection query; and
- Response Time: pak23 acknowledges all data protection enquiries within five (5) business days and aims to resolve them within thirty (30) calendar days. Complex requests may require additional time.
If you are not satisfied with our response to a privacy concern, you may have the right to lodge a complaint with the competent data protection supervisory authority in your jurisdiction.
Have Questions About Your Privacy?
Our support team is here to help. Visit our FAQ for quick answers to common privacy and account questions, or head back to the homepage to explore the full pak23 platform.
18+ only, or the higher minimum required by the operator/license jurisdiction. Local laws may restrict gambling. pak23 does not operate a casino or accept bets or deposits directly. All gambling activity is subject to applicable laws in your jurisdiction.