pakgam Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to all users ("you", "Player") of the pakgam platform operated at pakgam.vip ("Platform", "we", "us", "pakgam"). It describes how we collect, use, process, store, and protect your personal information in connection with your use of the Platform.

By registering an account or using any service on pakgam, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not create an account or use the Platform.

This Policy should be read in conjunction with pakgam's Terms & Conditions. In the event of any conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail.

2. Personal Data We Collect

pakgam collects the following categories of personal data:

We do not collect sensitive personal data such as biometric data beyond liveness check images used solely for KYC verification, or data revealing racial or ethnic origin, religious beliefs, or political opinions.

3. How We Collect Your Data

pakgam collects personal data through the following means:

• Direct collection: Information you provide during registration, KYC submission, deposit/withdrawal requests, and support interactions.
• Automated collection: Technical and usage data collected automatically via server logs, cookies, and session tracking when you access the Platform.
• Third-party sources: KYC verification partners who confirm identity document authenticity; payment processors (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah) who confirm transaction execution; fraud detection services.

4. Purposes of Processing

pakgam processes your personal data for the following purposes:

• Account creation and management: To register your account, maintain it, and provide access to all Platform features.
• Identity verification (KYC): To verify that you are who you say you are, that you are aged 18 or over, and that your account complies with anti-money laundering requirements.
• Payment processing: To execute PKR deposits and withdrawals via JazzCash, Easypaisa, and bank transfer; to maintain transaction records.
• Fraud and security: To detect, investigate, and prevent fraudulent transactions, bonus abuse, money laundering, and other prohibited conduct.
• Regulatory compliance: To comply with applicable anti-money laundering, counter-terrorism financing, and responsible gaming obligations.
• Responsible gaming: To monitor betting patterns, enforce self-exclusions, and apply deposit or session limits requested by Players.
• Customer support: To respond to queries, resolve disputes, and maintain records of communications.
• Platform improvement: To analyse usage patterns and improve the quality, security, and relevance of the Platform's features and content.
• Marketing communications: To send promotional offers and updates to Players who have consented to receive them. You may opt out at any time.

5. Legal Basis for Processing

pakgam processes personal data on the following legal grounds:

• Contractual necessity: Processing required to perform the contract between you and pakgam (i.e., the Terms & Conditions), including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws including anti-money laundering regulations, age verification requirements, and data retention obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring where such interests are not overridden by your privacy rights.
• Consent: Processing for optional purposes such as marketing communications, for which you have given clear, informed, and freely withdrawable consent.

6. Data Sharing & Third Parties

pakgam does not sell your personal data to third parties. We share data only in the following circumstances:

• KYC verification partners: Identity document data and liveness check images are shared with accredited third-party KYC service providers for the sole purpose of identity verification.
• Payment processors: Necessary transaction data is shared with JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and crypto payment processors to execute your deposits and withdrawals.
• Game providers: Aggregated or pseudonymised game session data may be shared with third-party game studios as required for game operation, RNG certification, and dispute resolution.
• Regulatory and law enforcement authorities: We will disclose personal data to competent authorities where required to do so by law, court order, or to prevent fraud or financial crime.
• Corporate transactions: In the event of a merger, acquisition, or asset sale, user data may be transferred to the acquiring entity under equivalent privacy protections.

All third-party data processors engaged by pakgam are subject to contractual obligations requiring them to process data only for specified purposes and to maintain appropriate security standards.

7. KYC & Identity Document Data

7.1 Identity documents (CNIC front/back, passport, NICOP) and liveness check images submitted for KYC verification are processed exclusively for the purpose of confirming your identity and age before withdrawals are permitted.

7.2 Document images are stored using AES-256 encryption at rest. Access is restricted to authorised KYC review personnel and the accredited third-party verification partner only. They are not accessible to general Platform staff.

7.3 Once KYC verification is completed, document images are retained for a minimum of 5 years post-account closure for anti-money laundering compliance. Upon expiry of the mandatory retention period, they are securely deleted.

7.4 The name on your identity document must match the name on your pakgam account. Any discrepancy will result in your KYC submission being flagged for manual review.

8. Payment & Financial Data

8.1 pakgam does not store full bank account credentials, JazzCash PINs, Easypaisa PINs, or card numbers. Payment authorisation is handled directly through the respective payment processor's secure gateway.

8.2 pakgam retains transaction records — including deposit amounts, withdrawal amounts, timestamps, and payment method references (e.g., last 4 digits of account, masked IBAN) — as required for financial record-keeping and AML compliance.

8.3 All financial transactions on pakgam are denominated in Pakistani Rupees (PKR). Transaction records reflect PKR amounts and are maintained in accordance with applicable financial record-keeping requirements.

9. Cookies & Tracking Technologies

pakgam uses the following categories of cookies and similar tracking technologies:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens, load balancing cookies, and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and session continuation. Disabling these may affect Platform functionality.
• Analytics cookies: Used to collect aggregated, anonymised data on how users interact with the Platform — which pages are visited, which games are most played, and error occurrences — to improve Platform quality.
• Responsible gaming cookies: Used to enforce session time limits and reality check notifications where these have been set by the Player.

You may manage non-essential cookies through your browser settings. Note that disabling cookies may limit certain Platform functions. We do not use third-party advertising tracking cookies.

10. Data Retention

10.1 Active account data is retained for the duration of your account and for a minimum of 5 years following account closure, in compliance with applicable anti-money laundering and financial record-keeping regulations.

10.2 KYC documentation is retained for a minimum of 5 years post-account closure. After this period, documents are permanently deleted from our systems.

10.3 Support communications are retained for 2 years from the date of the last interaction in the relevant ticket thread.

10.4 Analytics data collected via cookies is retained in aggregated, anonymised form and is not subject to the same retention limits as personal data.

10.5 Where you submit a data deletion request and we are not subject to a legal obligation to retain the relevant data, we will process the deletion within 30 calendar days.

11. Data Security

11.1 pakgam employs industry-standard security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS 1.2/1.3 encryption for all data in transit between your device and pakgam servers.
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records.
• Role-based access control (RBAC) ensuring staff access only the data necessary for their role.
• Multi-factor authentication for all internal staff accounts with access to user data.
• Regular penetration testing and vulnerability assessments by qualified security professionals.
• Automated monitoring and alerting for unusual access patterns or potential data breaches.

11.2 In the event of a data breach that is likely to result in a risk to your rights and freedoms, pakgam will notify affected users without undue delay and in accordance with applicable notification obligations.

12. Your Privacy Rights

Subject to applicable law and regulatory retention obligations, you have the following rights regarding your personal data held by pakgam:

• Right of access: Request a copy of the personal data pakgam holds about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data where pakgam is no longer required to retain it by law.
• Right to restrict processing: Request that pakgam restrict processing of your data in certain circumstances.
• Right to data portability: Request your data in a structured, machine-readable format where technically feasible.
• Right to withdraw consent: Withdraw consent for any processing based on consent (e.g., marketing emails) at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to object: Object to processing based on legitimate interests where your rights and freedoms override those interests.

To exercise any of the above rights, submit a written request to [email protected]. We will respond within 30 calendar days. We may require identity verification before processing requests to protect against fraudulent access.

13. Children's Privacy

pakgam is strictly an 18+ platform. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that a user is under 18, we will immediately close the account, delete all associated personal data, and report the matter in accordance with our responsible gaming obligations.

If you believe a minor has created an account on pakgam, please report this to [email protected] immediately. We treat all such reports as a priority.

14. Changes to This Privacy Policy

14.1 pakgam reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered Players via email or a prominent notice on the Platform at least 7 days before taking effect.

14.2 The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of pakgam following the effective date of any revision constitutes your acceptance of the updated Policy.

14.3 If you do not accept the updated Policy, you must cease using the Platform and may request account closure by contacting support.

15. Contact & Data Enquiries

For all privacy-related enquiries, data subject access requests, or to report a privacy concern, please contact pakgam's data team:

• Email: [email protected]
• Subject Line: Use "Privacy Request – [Your Full Name]" for data subject requests.
• Response Time: We aim to respond to all privacy requests within 30 calendar days.

This Privacy Policy was last reviewed and updated on 7 June 2026.