Privacy Policy — PKR33

01 Introduction

PKR33 ("PKR33", "we", "us", "our") is committed to protecting the personal data of every user who accesses or registers on the PKR33 platform at pkr33.cam and any associated applications (collectively, the "Platform"). This Privacy Policy ("Policy") describes in clear terms how we collect, use, store, share and safeguard your personal information, and it sets out the rights you hold in relation to that information.

This Policy applies to all users of the Platform regardless of their location, though it is written with particular reference to users based in Pakistan. By creating an Account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read alongside the Terms & Conditions and the Responsible Gambling Policy, both of which form part of the overall agreement governing your relationship with PKR33.

02 Definitions

The following terms carry the meanings defined below throughout this Policy:

• "Personal Data" — any information relating to an identified or identifiable natural person ("Data Subject"), including name, email address, phone number, financial details, device identifiers and behavioural data.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Data Controller is the operator of the PKR33 Platform under its applicable licence.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement.
• "Consent" — freely given, specific, informed and unambiguous indication of the Data Subject's agreement to the processing of their Personal Data for a stated purpose.
• "KYC Data" — identity verification documents and information collected as part of Know Your Customer compliance obligations, including CNIC, passport copies, proof of address and source of funds documentation.
• "Cookie" — a small text file placed on your device by the Platform for functional, analytical or marketing purposes.
• "Account" — your registered user account on the PKR33 Platform.

03 Personal Data We Collect

PKR33 collects personal data through several channels — directly from you, automatically through your use of the Platform and from regulated third-party sources where permitted. The categories of data collected include:

3.1 Registration Data

When you create an Account, we collect: full name, date of birth, email address, mobile phone number, residential address (including city — which for Pakistani users may be Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar), nationality and chosen username and password (stored in hashed form).

3.2 KYC and Verification Data

To comply with our AML and KYC obligations, we may collect copies of government-issued identification documents (such as your CNIC or passport), proof of residential address, selfie or biometric verification images, and documentation confirming the source of funds deposited into your Account.

3.3 Financial and Transaction Data

We record details of all deposits, withdrawals, wagers and bonuses associated with your Account. This includes transaction amounts (denominated in PKR or other applicable currencies), timestamps, payment method references and transaction identifiers. Payment method details such as e-wallet account references (for example, associated with Easypaisa or JazzCash — listed as familiar Pakistani payment rails, not endorsed providers) are recorded to the extent necessary for transaction processing and AML compliance.

3.4 Behavioural and Usage Data

We automatically collect data about how you interact with the Platform, including: pages visited, games played, session duration, bet history, search queries within the Platform, click-stream data and feature usage patterns. This data is used to improve Platform functionality and personalise your experience.

3.5 Technical and Device Data

We collect device information including: IP address, device type and model, operating system version, browser type and version, unique device identifiers, mobile network information and time-zone settings. This data is used for fraud prevention, security monitoring and technical troubleshooting.

3.6 Communications Data

Records of your communications with PKR33 support — including live chat transcripts, email exchanges and any complaint correspondence — are retained for service quality, dispute resolution and compliance purposes.

3.7 Responsible Gambling Data

If you use responsible gambling tools — including deposit limits, self-exclusion requests, cool-down periods or reality check settings — the details of those requests and settings are recorded and maintained as part of your Account profile.

04 How We Process Your Data

The table below summarises the primary purposes for which PKR33 processes your personal data:

05 Legal Basis for Processing

PKR33 processes your personal data under one or more of the following legal bases, depending on the purpose of the processing:

• Contract Performance: Processing necessary to provide the services described in the Terms & Conditions, including account management, transaction processing and customer support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML legislation, KYC requirements and responsible gambling obligations imposed by the operator's licence jurisdiction.
• Legitimate Interests: Processing carried out to pursue the legitimate interests of PKR33, such as fraud prevention, platform security, service improvement and internal analytics, where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your explicit and freely given consent, principally for marketing communications and certain non-essential cookie usage. You may withdraw consent at any time without affecting the lawfulness of processing based on consent prior to withdrawal.

06 Data Sharing & Third-Party Disclosure

PKR33 does not sell, rent or trade your personal data to third parties for commercial purposes. We may, however, share your data with the following categories of recipients where necessary and lawful:

• Licensed Service Providers: Third-party vendors engaged to provide services on our behalf — including payment processors, identity verification services, cloud hosting providers, analytics platforms, live chat software providers and email delivery services. All such providers operate under data processing agreements that restrict their use of your data to the contracted service only.
• Game Software Providers: Casino game studios and sports data feed providers may receive limited transactional or session data necessary for the operation of their games within the Platform. This does not include full KYC documentation.
• Regulatory and Law Enforcement Authorities: We are required to disclose personal data to regulatory bodies, financial intelligence units or law enforcement agencies where mandated by applicable law, court order or regulatory direction. We will notify you of such disclosures where legally permitted to do so.
• Responsible Gambling Schemes: Where you have enrolled in a self-exclusion programme or where we are obliged to do so under the operator's licence conditions, limited data may be shared with recognised responsible gambling databases to enforce exclusion orders.
• Corporate Transactions: In the event of a merger, acquisition, restructuring or sale of assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

07 Data Retention

PKR33 retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your active Account relationship with PKR33, plus any mandatory post-closure retention period required by the operator's licence jurisdiction.
• KYC and AML Records: Identity verification documents and AML transaction records are typically retained for a minimum of five (5) years from the date of account closure or the last transaction — whichever is later — in accordance with standard AML legislative requirements. Local regulatory requirements in the operator's licence jurisdiction may mandate longer retention periods.
• Communications Records: Support correspondence and dispute records are retained for a minimum period sufficient to resolve any outstanding claims or regulatory inquiries, generally not less than three (3) years.
• Marketing Data: Where you have provided consent for marketing communications, associated data is retained until you withdraw consent. Withdrawal of consent does not affect the validity of previous processing.
• Technical Logs: Server logs, security event records and device data are retained for fraud prevention and security audit purposes, typically for a period of twelve (12) to twenty-four (24) months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that renders re-identification impossible.

08 Data Security

PKR33 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• Encryption in Transit: All data transmitted between your device and the PKR33 Platform is encrypted using TLS (Transport Layer Security) protocols.
• Encryption at Rest: Sensitive data stored in our databases — including financial records and KYC documents — is encrypted using industry-standard algorithms.
• Password Hashing: Account passwords are never stored in plain text. They are processed using a cryptographic hashing algorithm with salting.
• Access Controls: Access to personal data within PKR33's operational environment is restricted to authorised personnel on a strict need-to-know basis, enforced through role-based access controls.
• Security Monitoring: Continuous monitoring systems are in place to detect and respond to anomalous activity, intrusion attempts and potential data breaches.
• Penetration Testing: The Platform undergoes regular security assessments and penetration testing to identify and remediate vulnerabilities.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, PKR33 will notify affected users without undue delay in accordance with the notification obligations under the operator's applicable licence jurisdiction.

09 Cookies & Tracking Technologies

PKR33 uses cookies and similar tracking technologies (including pixels, web beacons and local storage objects) to operate, secure and improve the Platform. The categories of cookies used are as follows:

You can manage your cookie preferences through the cookie consent banner displayed on your first visit to the Platform, or at any time through your browser settings. Please note that disabling strictly necessary cookies will impair core Platform functionality. Disabling analytical or marketing cookies will not affect your ability to use the Platform.

10 Marketing Communications

Where you have provided explicit consent, PKR33 may send you promotional communications relating to bonuses, new game releases, PSL match specials, ICC tournament promotions, live casino events and other offers relevant to your interests as a Pakistani user of the Platform. These communications may be sent via email, SMS or push notification depending on your Account settings and the contact preferences you have registered.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in the Account settings section of the Platform.
• Clicking the unsubscribe link included in any marketing email sent by PKR33.
• Contacting PKR33 support at [email protected] with a clear request to opt out.

Withdrawal of marketing consent will not affect your receipt of transactional communications (such as deposit confirmations, withdrawal notifications, KYC requests or security alerts), which are sent on the basis of contract performance or legal obligation and cannot be opted out of while your Account remains active.

11 Your Data Rights

Subject to applicable law and the operator's regulatory obligations, you hold the following rights in relation to your personal data held by PKR33:

• Right of Access: You may request a copy of the personal data PKR33 holds about you, along with information about how it is processed. We will respond to verified access requests within 30 days.
• Right to Rectification: If any personal data we hold is inaccurate or incomplete, you have the right to request correction. You may update basic Account details directly in your Account settings; for KYC document corrections, please contact support.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose it was collected. This right is subject to overriding legal obligations, particularly AML retention requirements, which may prevent full deletion.
• Right to Restriction of Processing: You may request that PKR33 restrict the processing of your personal data in specific circumstances — for example, while a dispute regarding the accuracy of the data is pending resolution.
• Right to Data Portability: Where processing is based on consent or contract performance, you may request that your personal data be provided to you in a structured, commonly used and machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including direct marketing. Where you object to direct marketing, processing for that purpose will cease immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of prior processing.

To exercise any of the above rights, please contact PKR33 support at the address set out in Section 15. We may require you to verify your identity before processing a rights request. We will respond within the timeframes required by the applicable law of the operator's licence jurisdiction.

12 Minors & Age Protection

The PKR33 Platform is strictly intended for adults. We do not knowingly collect personal data from individuals under the age of 18, or under the higher minimum age required by the operator's licence jurisdiction. Age verification is conducted as part of the KYC process for all registering users.

If PKR33 becomes aware that personal data has been collected from a minor without verifiable parental or guardian consent, that data will be deleted and the associated Account will be closed immediately. Any balance in the Account will be handled in accordance with applicable regulatory requirements.

13 International Data Transfers

PKR33 operates internationally and your personal data may be transferred to, and processed in, countries other than the country in which you are located. In particular, data may be processed in the operator's licence jurisdiction and in the jurisdictions where our licensed service providers are based.

Where personal data is transferred outside your home jurisdiction, PKR33 ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required by the applicable data protection framework of the operator's licence jurisdiction. These safeguards may include:

• Adequacy decisions recognising the receiving country's data protection standards.
• Standard contractual clauses or equivalent contractual protections with data processors.
• Binding corporate rules applicable to intra-group transfers.

You may request further information about international transfer safeguards by contacting PKR33 support.

14 Amendments to This Policy

PKR33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory requirements or Platform functionality. The "Last Updated" date at the head of this document will be revised each time a material change is made.

Where changes are material — meaning they significantly affect how we collect, use or share your data — we will provide advance notice via email to your registered address or through an in-Platform notification prior to the change taking effect. For non-material changes (such as clarifications of existing practices or corrections of typographical errors), the updated Policy will be published without individual notification.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with an amendment, you should cease using the Platform and may close your Account in accordance with the Terms & Conditions.

15 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or to the processing of your personal data, please contact the PKR33 Data Protection team using the details below. All privacy-related enquiries are handled with priority and in strict confidence.

To help us process your request efficiently, please include your registered username, a clear description of your request (e.g., data access, deletion, correction), and confirmation of the email address on your Account. We may require identity verification before actioning any data rights request.