1. Introduction and Scope
This Privacy Policy ("Policy") is published by pakgem ("pakgem", "we", "us", or "the Company") and applies to all personal data processed in connection with the operation of the pakgem Platform, accessible at pakgem.app. The Policy covers all users of the Platform, including registered account holders, visitors who browse without registering, and any individual whose personal data is submitted to us in the course of using our sports betting, casino, live dealer, slots, or customer support services.
pakgem is committed to handling your personal information with care, transparency, and full respect for your privacy rights. This Policy is designed to give you a clear and honest account of our data practices so you can make informed decisions about your engagement with the Platform. We do not sell your personal data to third parties, and we do not use your information for purposes beyond those described in this Policy without your explicit consent.
This Policy should be read alongside the pakgem Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and pakgem. By using the Platform, you acknowledge that you have read and understood this Privacy Policy.
2. Personal Data We Collect
pakgem collects several categories of personal data depending on how you interact with the Platform. The table below summarises the main data categories, specific data points within each category, and the primary purpose for which each category is collected.
| Data Category | Specific Data Points | Primary Purpose |
|---|---|---|
| Identity Data | Full legal name, CNIC number, date of birth, photograph, gender | KYC verification, age confirmation, fraud prevention |
| Contact Data | Email address, Pakistani mobile number, city of residence (e.g. Karachi, Lahore, Islamabad) | Account communication, support, promotional messaging (where consented) |
| Financial Data | JazzCash/EasyPaisa account numbers, bank account details (HBL, UBL, Meezan Bank), USDT wallet address, transaction history | Payment processing, withdrawal verification, AML compliance |
| Technical Data | IP address, device type, browser, operating system, session tokens, login timestamps | Security, fraud detection, Platform optimisation |
| Usage Data | Games played, bet history, deposit/withdrawal patterns, session duration, feature interactions | Responsible gaming monitoring, product improvement, personalisation |
| Communications Data | Live chat transcripts, email correspondence, support ticket contents | Dispute resolution, quality assurance, compliance records |
| Preferences Data | Language settings, notification preferences, responsible gaming tool settings | Platform personalisation, responsible gaming compliance |
3. How We Collect Your Personal Data
pakgem collects personal data through a variety of channels and interactions. Understanding where your data comes from is an important part of our commitment to transparency.
- 3.1Direct Submission: The majority of your personal data is provided directly by you during account registration, KYC verification, deposit and withdrawal requests, contact form submissions, live chat interactions, and when you update your account profile or preferences.
- 3.2Automated Collection: When you access and use the pakgem Platform, we automatically collect technical data including your IP address, device identifiers, browser type and version, pages visited, session duration, and interaction logs. This data is collected via server logs, analytics tools, and session tracking technologies.
- 3.3Cookies and Similar Technologies: pakgem uses cookies, web beacons, and similar tracking technologies to collect data about your browsing behaviour on the Platform. See Section 9 of this Policy for full details of our cookie practices and how to manage your preferences.
- 3.4Third-Party Sources: We may receive personal data about you from identity verification partners (for CNIC validation), payment processors (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank), fraud detection services, and public registers where permitted by applicable law.
- 3.5Game Providers: Where you play games hosted by third-party providers integrated into the pakgem Platform, those providers may share technical and gameplay data with us for the purposes of dispute resolution, RTP verification, and responsible gaming monitoring.
4. Purposes for Which We Use Your Data
pakgem processes your personal data only for clearly defined, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The following are the specific purposes for which pakgem processes personal data.
- 4.1Account Registration and Management: To create and maintain your pakgem account, verify your identity (including age verification to confirm you are 21 or over), manage your account settings, and communicate essential service information to you.
- 4.2Payment Processing: To process deposits made via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT; to verify and execute withdrawal requests to your registered payment method; and to maintain accurate financial records in compliance with anti-money laundering requirements.
- 4.3Regulatory Compliance: To fulfil our obligations under applicable gaming regulations, including KYC/AML requirements, responsible gaming monitoring, and reporting obligations to our licensing authority. Compliance processing is mandatory and cannot be opted out of.
- 4.4Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeovers, and other security threats to the Platform and to individual players.
- 4.5Responsible Gaming: To monitor your betting patterns and identify indicators of problem gambling behaviour; to apply deposit limits, cool-off periods, or self-exclusion measures you have requested; and to fulfil our duty of care to all players under our responsible gaming framework.
- 4.6Customer Support: To respond to your enquiries, resolve disputes, process complaints, and provide technical assistance via live chat, email, and other support channels.
- 4.7Marketing Communications: To send you promotional offers, bonus notifications, and Platform updates — but only where you have given your explicit consent to receive such communications. You may withdraw consent at any time via your account settings.
- 4.8Platform Improvement: To analyse aggregated usage data in order to improve Platform performance, game selection, user experience, and feature development. Analytics used for this purpose are based on anonymised or pseudonymised data wherever possible.
5. Legal Basis for Processing
Every instance of personal data processing carried out by pakgem rests on one or more of the following lawful bases. We have mapped each primary processing activity to its corresponding legal basis in the table below.
| Processing Activity | Legal Basis |
|---|---|
| Account registration and management | Performance of contract |
| KYC and age verification | Legal obligation |
| Payment processing and financial records | Performance of contract / Legal obligation |
| Fraud detection and security monitoring | Legitimate interests |
| Responsible gaming monitoring | Legal obligation / Legitimate interests |
| Customer support communications | Performance of contract |
| Marketing communications | Consent |
| Platform analytics and improvement | Legitimate interests |
7. Data Retention Periods
pakgem retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply to the main categories of personal data we hold.
| Data Category | Retention Period | Reason |
|---|---|---|
| Account and identity data | Duration of account + 5 years after closure | AML regulatory obligation |
| Financial transaction records | 7 years from transaction date | Financial reporting and AML compliance |
| KYC documentation | 5 years after account closure | Regulatory obligation |
| Betting and gameplay history | 5 years from date of wager | Dispute resolution, regulatory audit |
| Customer support communications | 3 years from last interaction | Dispute resolution records |
| Marketing consent records | 3 years from consent or last contact | Demonstrating lawful basis for marketing |
| Technical / server log data | 12 months from collection | Security monitoring and fraud detection |
| Self-exclusion records | Indefinitely (or for the self-exclusion period + 5 years) | Responsible gaming compliance |
Once a retention period has elapsed, personal data is securely deleted or anonymised such that it can no longer be associated with any identifiable individual. Anonymised or aggregated data derived from your personal data may be retained indefinitely for statistical and analytical purposes.
8. Data Security Measures
pakgem employs a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security posture is reviewed and updated on a regular basis to address emerging threats.
All data transmitted between your browser or device and the pakgem Platform is encrypted using TLS 1.3 or higher, preventing interception of your personal and financial information during transmission.
Sensitive personal data — including CNIC details, financial records, and passwords — is encrypted at rest using AES-256 standard encryption. Plain-text storage of sensitive credentials is strictly prohibited in our systems.
Access to personal data within pakgem is restricted on a strict need-to-know basis. All staff members with access to player data are subject to confidentiality obligations and regular security awareness training.
Our Platform is monitored around the clock for security incidents, suspicious login activity, and anomalous data access patterns. Automated alerts trigger immediate investigation when unusual activity is detected.
pakgem offers two-factor authentication (2FA) for your account, adding a second layer of security beyond your password. We strongly recommend all Pakistani players enable 2FA via their account security settings.
The pakgem Platform undergoes regular independent penetration testing and vulnerability assessments. Any identified vulnerabilities are triaged and remediated according to their severity and potential impact on player data.
10. Your Privacy Rights
As a player using the pakgem Platform, you hold a number of rights in relation to your personal data. pakgem is committed to facilitating the exercise of these rights promptly and without unnecessary obstacles. To exercise any of the rights below, contact us via live chat or at [email protected] (plain text — not a clickable link).
pakgem will respond to all valid rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reason for it. There is no charge for exercising your rights unless requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.
11. Minors and Age Verification Policy
The pakgem Platform is strictly intended for adult users aged 21 and over. We do not knowingly collect or process personal data belonging to individuals under the age of 21. Age verification is a mandatory step in the account registration process, and all accounts are subject to CNIC-based age confirmation before full Platform access is granted.
If pakgem becomes aware that personal data has been collected from an individual under the age of 21, we will take the following steps without delay:
- 11.1Immediately suspend the account pending investigation.
- 11.2Permanently close the account and forfeit any balance, as per our Terms and Conditions.
- 11.3Delete all personal data associated with the account to the extent permitted by our regulatory retention obligations.
- 11.4Refer the matter to the relevant authorities where the circumstances warrant it.
12. International Data Transfers
As pakgem operates under an international gaming licence and uses third-party service providers located in various jurisdictions, your personal data may be transferred to and processed in countries outside Pakistan. When such transfers occur, pakgem ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy.
Safeguards used for international transfers include standard contractual clauses approved by relevant data protection authorities, binding corporate rules where applicable, and transfers only to jurisdictions that have been assessed as providing an adequate level of data protection. By using the pakgem Platform, you acknowledge and agree to such transfers taking place where necessary for the delivery of our services.
13. Changes to This Privacy Policy
pakgem reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or operational requirements. Where material changes are made, we will notify registered players via email or a prominent in-Platform notification at least 7 days before the changes take effect.
The current version number and effective date of this Policy are shown at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Platform after any amendments take effect constitutes your acceptance of the updated Policy.
14. Contact Us and How to Complain
If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how pakgem handles your personal data, please get in touch using one of the channels below. All contact details are presented as plain text and are not clickable links.
Available 24 hours a day, 7 days a week. Average response time under 2 minutes. Recommended for general privacy queries and quick data requests from players across Karachi, Lahore, Islamabad, and Faisalabad.
For formal data rights requests and privacy complaints, write to: [email protected] — plain text only, not a clickable link. Include your account ID and the nature of your request in the subject line.
If you are not satisfied with pakgem's response to your privacy concern, you have the right to escalate your complaint to the relevant supervisory authority or the independent dispute resolution body specified by our licensing authority.
Your Privacy Matters to Us
Have questions about how pakgem protects your data? Our support team is available around the clock to assist players across Pakistan — from Karachi to Islamabad — with any privacy-related queries.