pakaka Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how pakaka ("the Company", "pakaka", "we", "us", "our") collects, uses, stores, discloses, and protects the personal data of individuals ("Player", "User", "you") who access or use the pakaka website, mobile platform, casino services, sports betting services, and associated features (collectively "the Platform").

pakaka is committed to handling your personal information with transparency, respect, and security. This Policy is designed to help you understand exactly what data we hold about you, why we hold it, and what choices you have. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside pakaka's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated herein by reference and available on the Platform.

2. Data We Collect

2.1 Registration Data

When you create a pakaka account, we collect: your full legal name, email address, Pakistani mobile number, date of birth, and your confirmation of eligibility (age 18+, jurisdictional compliance). This data is mandatory for account creation and cannot be omitted.

2.2 Identity Verification Data (KYC)

To comply with anti-money laundering (AML) regulations and verify your identity before processing withdrawals, we collect copies or photographs of government-issued identity documents. For Pakistani players, this is primarily the Computerised National Identity Card (CNIC) — front and back. In certain circumstances, we may also request proof of address or source of funds documentation.

2.3 Financial Transaction Data

We collect records of all deposits and withdrawals processed through your pakaka account, including: transaction amounts in PKR or cryptocurrency, payment method identifiers (e.g., JazzCash mobile number, Easypaisa account reference, bank account last four digits, USDT wallet address), timestamps, and transaction status. Full payment credentials (card numbers, bank PINs) are never stored by pakaka.

2.4 Gaming Activity Data

We record your gaming and betting activity on the Platform, including: games played, wager amounts, win/loss records, session duration, active bonuses, and sports betting selections. This data is used for account management, responsible gaming monitoring, bonus administration, and regulatory reporting where required.

2.5 Technical and Device Data

We automatically collect technical data when you access the Platform, including: IP address, device type and operating system, browser type and version, session timestamps, pages visited, and referring URL. This data is used for security, fraud prevention, and platform optimisation.

2.6 Communications Data

When you contact pakaka's customer support via live chat or email, we retain records of those communications including the content of messages, timestamps, and the resolution outcome. This data is used to provide support, improve service quality, and maintain audit records.

3. How We Use Your Data

pakaka uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your pakaka account, processing logins, and managing account settings.
• Payment Processing: Facilitating deposits via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, USDT TRC20, and other supported methods, and processing withdrawal requests.
• KYC & AML Compliance: Verifying your identity, preventing fraud, and meeting regulatory obligations related to anti-money laundering and counter-terrorism financing.
• Responsible Gaming: Monitoring gaming patterns to identify signs of problem gambling, enforcing self-exclusion requests, and ensuring compliance with age restrictions.
• Customer Support: Responding to your queries, resolving disputes, and maintaining service quality records.
• Security: Detecting and preventing fraudulent activity, unauthorised account access, and abuse of Platform services.
• Legal Compliance: Meeting applicable legal, regulatory, and tax reporting obligations.
• Marketing (with consent): Sending promotional communications about bonuses, new games, and Platform updates — only where you have provided explicit consent and may be withdrawn at any time.

4. Legal Basis for Processing

pakaka processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil the pakaka service agreement with you, including account management, payment processing, and game provision.
• Legal Obligation: Processing required to comply with applicable AML, KYC, and regulatory reporting requirements.
• Legitimate Interests: Processing for fraud prevention, security monitoring, and platform improvement where these interests are not overridden by your rights.
• Consent: Marketing communications and non-essential analytics cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. KYC & Identity Document Handling

Identity documents submitted for KYC verification at pakaka are treated with the highest level of security and confidentiality. Submitted documents are:

• Transmitted to our secure servers via SSL-encrypted connection
• Stored in access-controlled, encrypted document storage systems
• Accessible only to authorised verification personnel and compliance officers
• Never shared with third parties for marketing, profiling, or commercial purposes
• Retained for the minimum period required by applicable AML regulations (typically five years from account closure)

CNIC and other identity documents are used exclusively for identity verification, fraud prevention, and regulatory compliance. They are not used for any form of automated decision-making that produces legal or similarly significant effects on you without human review.

6. Payment Data

pakaka does not store full payment credentials. When you deposit via JazzCash, Easypaisa, or bank transfer, the transaction is processed through the relevant payment network and we receive only a transaction reference and confirmation. For USDT TRC20 transactions, wallet addresses used for deposits are recorded for AML traceability. Skrill and Neteller transactions are processed directly through those platforms' APIs — their respective privacy policies also apply to those transactions.

Payment data is retained for the duration required by financial regulatory obligations and used solely for transaction record-keeping, dispute resolution, and withdrawal processing.

7. Cookies & Tracking Technologies

7.1 Essential Cookies

Essential cookies are required for the Platform to function. They maintain your login session, remember your language preference, and support security features including CSRF protection. These cookies cannot be disabled without breaking core Platform functionality.

7.2 Analytics Cookies

With your consent, pakaka uses analytics cookies to understand how the Platform is used — which pages are visited, where users navigate from, and how features are engaged with. This data is aggregated and anonymised. You may decline analytics cookies at any time via the cookie preference centre without affecting your ability to use the Platform.

7.3 Security Cookies

Security cookies support fraud detection and bot prevention. They collect technical signals about your browsing environment to distinguish legitimate players from automated systems. These are classified as essential and cannot be disabled.

8. Data Sharing & Third Parties

pakaka does not sell, rent, or trade your personal data to third parties. We share your data only in the following limited circumstances:

• Payment Processors: JazzCash, Easypaisa, Skrill, Neteller, and banking partners receive transaction data necessary to process your deposits and withdrawals.
• KYC Service Providers: Identity document verification may be assisted by certified third-party KYC platforms. These providers operate under strict data processing agreements and may not use your data for their own purposes.
• Game Content Providers: Game studios such as PG Soft, Pragmatic Play, and live dealer providers receive anonymised session data required for game delivery and RNG certification audits. They do not receive your personally identifiable information.
• Legal & Regulatory Authorities: We will disclose personal data to competent authorities where required by law, court order, or regulatory obligation.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom pakaka shares data are bound by contractual data processing agreements prohibiting use of your data beyond the stated purpose.

9. Data Retention

pakaka retains your personal data for as long as your account is active and for the following periods thereafter:

• Account and registration data: Retained for five (5) years following account closure, as required for AML regulatory compliance.
• Transaction records: Retained for five (5) years from the date of each transaction.
• KYC documents: Retained for five (5) years from account closure or the date of last transaction, whichever is later.
• Customer support records: Retained for two (2) years from the date of the interaction.
• Analytics data: Anonymised after ninety (90) days and deleted after one (1) year.

Upon expiry of applicable retention periods, and in the absence of any ongoing legal obligation, data is securely and irreversibly deleted from pakaka's systems.

10. Data Security

pakaka implements appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. Security measures include:

• SSL/TLS encryption for all data in transit between your device and pakaka servers
• Encryption at rest for sensitive data including identity documents and payment references
• Role-based access controls ensuring only authorised personnel access personal data
• Regular security audits and penetration testing of Platform infrastructure
• Two-factor authentication available and strongly recommended for all player accounts
• Continuous monitoring for suspicious access patterns and data breach indicators

In the event of a personal data breach that poses a risk to your rights and freedoms, pakaka will notify affected individuals without undue delay and in accordance with applicable regulatory requirements.

11. Your Rights

You have the following rights with respect to your personal data held by pakaka:

• Right of Access: You may request a copy of all personal data pakaka holds about you.
• Right of Rectification: You may request correction of inaccurate or incomplete personal data.
• Right of Erasure: You may request deletion of your personal data where there is no overriding legal obligation to retain it. Note that AML and regulatory retention requirements may limit the scope of erasure requests.
• Right to Restriction: You may request that processing of your data be restricted in certain circumstances while a dispute or complaint is being resolved.
• Right to Data Portability: You may request your personal data in a structured, machine-readable format where technically feasible.
• Right to Object: You may object to processing of your data for direct marketing purposes at any time. Objections to processing based on legitimate interests will be considered on a case-by-case basis.
• Right to Withdraw Consent: Where processing is based on your 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, contact pakaka's data protection team at the email address provided in Section 15. Requests will be acknowledged within 5 business days and substantively responded to within 30 calendar days.

12. Children's Privacy

The pakaka Platform is strictly for persons aged 18 years and older. pakaka does not knowingly collect personal data from persons under the age of 18. If you believe a minor has accessed or registered on the Platform, please contact support immediately at the address in Section 15. Any account found to belong to a person under 18 will be closed immediately, all data will be deleted except where retention is required by law, and deposits will be returned to the original payment method.

13. Third-Party Links & External Services

The pakaka Platform may contain references to third-party payment services (JazzCash, Easypaisa, Skrill, Neteller) and game providers. When you interact with third-party services — for example, completing a JazzCash payment flow — you are subject to that third party's own privacy policy. pakaka is not responsible for the privacy practices of third-party services and encourages you to review their policies independently.

14. Changes to This Privacy Policy

pakaka may update this Privacy Policy from time to time to reflect changes in legal requirements, business practices, or Platform features. Material changes will be communicated to registered players via email to their registered address or via an on-platform notification at least seven (7) days before taking effect. The "Last updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the Platform following any changes constitutes your acceptance of the revised Policy.

15. Contact & Data Requests

For all privacy-related enquiries, data subject rights requests, or concerns regarding this Policy, please contact pakaka's data protection team:

• Email: [email protected] (plain text — not a clickable link; subject line: "Privacy Request")
• Live Chat: Available 24/7 on the Platform — ask to be connected to the data protection team
• Response Time: Acknowledgement within 5 business days; full response within 30 calendar days

Please include your registered email address or mobile number and a description of your request. For access or deletion requests, identity verification may be required before your request can be processed.