Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is issued by PKR123 ("we", "us", "our", "Operator"), the entity responsible for operating the online gaming and sports betting platform accessible at pkr123.cam ("Platform"). It applies to all individuals who visit, register on or interact with the Platform in any capacity.

PKR123 is committed to processing personal data responsibly, transparently and in accordance with applicable data protection legislation, including the data protection framework applicable in the Operator's licensing jurisdiction. This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed.

This Policy should be read alongside our Terms & Conditions, available at /terms-conditions, and our Responsible Gambling Policy, available at /responsible-gambling, both of which are incorporated by reference.

If you are accessing the Platform from Pakistan, please note that PKR123 does not claim to be registered under or compliant with the Personal Data Protection Bill (Pakistan) in its current form, as that legislation has not yet been fully enacted and enforced at the time of this Policy's effective date. Users should satisfy themselves as to any local data protection obligations applicable to their use of the Platform.

2 Definitions

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, including name, email address, phone number, date of birth, payment details and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer or deletion.
• "Data Controller" means the Operator, who determines the purposes and means by which Personal Data is processed.
• "Data Processor" means a third party who processes Personal Data on behalf of the Operator under a written data processing agreement.
• "KYC" means Know Your Customer — the identity and address verification process required to comply with anti-money-laundering and responsible gambling obligations.
• "Cookies" means small text files placed on your device by the Platform to store session, preference and tracking information.
• "User", "You" means any individual who accesses, registers on or uses the PKR123 Platform.
• "Account" means the registered user account you hold on the PKR123 Platform.

3 Data We Collect

We collect Personal Data in several ways, depending on how you interact with the Platform. The categories of Personal Data we collect are as follows:

3.1 Registration Data

When you create a PKR123 Account, we collect: full legal name, date of birth, country and city of residence, email address, chosen username and password (stored in encrypted form). This information is required to open and maintain your Account.

3.2 Identity Verification (KYC) Data

To meet anti-money-laundering obligations and verify your eligibility to use the Platform, we collect copies of government-issued identity documents (such as your Computerised National Identity Card (CNIC) or passport), proof of address documents, and where required, source-of-funds documentation. This data is collected when you request a withdrawal or when our compliance processes require verification.

3.3 Financial Data

When you make deposits or withdrawal requests, we collect payment method details sufficient to process the transaction, including account numbers, mobile wallet references (where applicable) and transaction identifiers. PKR123 acknowledges familiar Pakistani payment references including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah as context references only; these providers operate their own privacy practices independently. We do not permanently store complete card numbers or banking credentials — payment data is handled via the relevant payment processor's secure infrastructure.

3.4 Transactional and Gaming Data

We collect records of all deposits, withdrawals, bets placed, games played, bonuses claimed and account activity on the Platform. This data is used for account management, dispute resolution, compliance reporting and responsible gambling monitoring.

3.5 Technical and Device Data

We automatically collect information about the device and connection you use to access the Platform, including: IP address, browser type and version, operating system, device identifiers, session timestamps and pages visited. This data is used for security monitoring, fraud prevention and Platform performance optimisation.

3.6 Communications Data

When you contact our support team by email or live chat, we retain records of that correspondence, including the content of messages and any attachments provided, for quality assurance, compliance and dispute resolution purposes.

4 Lawful Basis for Processing

PKR123 processes your Personal Data only where a lawful basis exists for doing so. The primary bases on which we rely are:

• Contractual Necessity: Processing required to perform the contract we hold with you as a registered Account holder — including operating your Account, processing deposits and withdrawals and providing access to games and markets.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including KYC identity verification, anti-money-laundering reporting, responsible gambling obligations and responses to lawful authority requests.
• Legitimate Interests: Processing for our legitimate business interests where those interests are not overridden by your data protection rights — including fraud prevention, Platform security, improving services and internal analytics.
• Consent: Where we rely on your consent — for example, to send marketing communications — you may withdraw that consent at any time by contacting our support team or using in-account preference settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5 How We Use Your Data

We use the Personal Data we collect for the following purposes:

• To create, manage and maintain your PKR123 Account;
• To process deposits, wagers and withdrawal requests in PKR and other supported currencies;
• To verify your identity and eligibility to use the Platform through KYC processes;
• To detect, prevent and investigate fraud, money laundering, account abuse and security threats;
• To deliver responsible gambling tools, including monitoring for indicators of problem gambling behaviour and enforcing self-exclusion requests;
• To administer bonuses, promotions and loyalty programme benefits;
• To respond to your support queries and resolve disputes;
• To comply with legal obligations, including regulatory reporting and responses to lawful requests from courts or public authorities;
• To send you service-related communications, including account notifications, security alerts and policy updates;
• To send marketing communications where you have provided consent or where permitted by applicable law — you may opt out at any time;
• To improve and optimise the performance, security and usability of the Platform.

6 Data Sharing & Disclosure

PKR123 does not sell, rent or trade your Personal Data to third parties for commercial purposes. We share your data only in the following limited circumstances:

6.1 Service Providers (Data Processors)

We engage third-party service providers to assist us in operating the Platform — including payment processors, identity verification providers, cloud hosting services, customer support platforms and security monitoring services. These providers process your data only on our documented instructions and are bound by contractual data processing obligations.

6.2 Regulatory and Legal Obligations

We may disclose your Personal Data to regulatory authorities, licensing bodies, law enforcement agencies or courts where required by applicable law, court order or regulatory requirement. PKR123 will comply with all lawful data requests and will endeavour to notify affected users where legally permitted to do so.

6.3 Anti-Money-Laundering Compliance

Where our AML compliance obligations require us to file reports with financial intelligence units or other relevant authorities, we will do so without prior notification to the subject of the report, as required by law.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the Operator's business, your Personal Data may be transferred to the acquiring or successor entity, subject to equivalent data protection obligations being maintained.

7 International Data Transfers

PKR123 and some of our third-party service providers may process your Personal Data in countries outside your country of residence. Where Personal Data is transferred to a country that does not provide an equivalent level of data protection, we ensure that appropriate safeguards are in place — such as standard contractual clauses or equivalent transfer mechanisms — to protect your data during and after the transfer.

By using the PKR123 Platform from Pakistan or any other jurisdiction, you acknowledge that your Personal Data may be transferred to and processed in servers located outside Pakistan.

8 Data Retention

We retain your Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. Specific retention periods include:

• Account Data: Retained for the duration of your Account and for a minimum period of five (5) years following Account closure, to comply with AML and responsible gambling regulatory retention requirements.
• KYC Documents: Retained for the period required by applicable AML legislation in the Operator's licensing jurisdiction, typically five (5) years from the end of the business relationship.
• Transaction Records: Retained for a minimum of five (5) years, or longer where required by applicable law or ongoing compliance review.
• Communications Data: Support correspondence is retained for a minimum of two (2) years for dispute resolution and quality assurance purposes.
• Technical and Log Data: Retained for up to twelve (12) months for security and fraud investigation purposes, after which it is deleted or anonymised.

Where data is no longer required for its original purpose and no legal retention obligation applies, it is securely deleted or irreversibly anonymised.

9 Data Security

PKR123 implements technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest, including Account credentials and KYC document storage;
• Strict access controls, limiting staff access to Personal Data on a need-to-know basis;
• Regular security assessments and vulnerability monitoring of Platform infrastructure;
• Incident response procedures to detect, contain and notify of personal data breaches in a timely manner where required by applicable law.

While we apply robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your Account credentials and for notifying us immediately if you suspect unauthorised access to your Account.

10 Cookies & Tracking Technologies

PKR123 uses cookies and similar tracking technologies to support the operation, security and performance of the Platform. Cookies are small text files stored on your device when you visit the Platform.

We use the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function correctly, including session management, login authentication and security features. These cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Used to remember your preferences and settings to improve your experience on return visits.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform — such as pages visited and time spent — to help us improve performance and usability.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorised access and bot interactions on the Platform.

PKR123 does not currently use third-party advertising or behavioural targeting cookies on the Platform. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality.

11 Your Rights

Depending on the data protection law applicable to your situation, you may hold the following rights in respect of your Personal Data held by PKR123:

• Right of Access: You may request a copy of the Personal Data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data.
• Right to Erasure: In certain circumstances, you may request that we delete your Personal Data — subject to legal retention obligations and our legitimate interests in fraud prevention and regulatory compliance.
• Right to Restriction: You may request that we restrict the processing of your Personal Data in certain defined circumstances.
• Right to Data Portability: Where technically feasible and legally applicable, you may request a copy of your data in a structured, machine-readable format.
• Right to Object: You may object to processing carried out on the basis of legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, 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 using the details in Section 15. We will respond to rights requests within a reasonable period and, in any event, within the timeframe required by applicable law. We may need to verify your identity before processing a rights request.

12 Minors & Age Verification

The PKR123 Platform is strictly intended for adults. We do not knowingly collect Personal Data from individuals under the age of 18, or the higher minimum age required by the Operator's licensing jurisdiction. Registration is prohibited for minors.

As part of our account eligibility and KYC processes, we verify the age of users before processing withdrawal requests. Where we identify or have reasonable grounds to suspect that a user is under the minimum required age, we will:

• Immediately suspend the Account pending investigation;
• Withhold any associated funds pending verification;
• Delete or return personal data to the extent permitted by law;
• Report the matter to relevant authorities where required.

13 Third-Party Services

The PKR123 Platform may reference or integrate with third-party services — including payment processors and identity verification providers — whose privacy practices are independent of this Policy. PKR123 is not responsible for the privacy practices of third-party providers.

Familiar payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are mentioned as context for Pakistani users. Each of these providers operates under its own data protection and privacy policies, which are entirely separate from PKR123's practices. PKR123 does not control how these providers process data in connection with their own services. The mention of these names does not imply endorsement, affiliation or data sharing beyond what is strictly required to process a transaction.

Where you interact with third-party payment or verification services in connection with your PKR123 Account, please review those providers' privacy policies independently.

14 Changes to This Policy

PKR123 reserves the right to update or amend this Privacy Policy at any time. When changes are made, an updated version of the Policy will be published on the Platform with a revised effective date. Where the changes are material, we will provide additional notice — such as a notification to your registered email address or a prominent banner on the Platform.

Your continued use of the Platform following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you should cease using the Platform and may close your Account by contacting our support team.

We encourage you to review this Policy periodically to stay informed about how we handle your Personal Data.

15 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data by PKR123, please contact our Data Protection team using the following details:

When submitting a data subject request, please include your registered email address, a description of your request and, for identity verification purposes, a reference to the Account you hold with us. Do not include your password or full financial account numbers in correspondence.

For urgent security concerns — such as suspected unauthorised access to your Account — please also contact us at the above address and mark your message as urgent. For responsible gambling matters, including self-exclusion requests, please contact the same address and clearly state the nature of your request for prioritised handling.