Privacy Policy — 92pak5

Introduction

92pak5 (hereinafter referred to as "92pak5", "we", "us" or "our") is committed to protecting the privacy and personal data of all individuals who access or use the 92pak5 platform at https://92pak5.cam ("Platform"). This Privacy Policy ("Policy") describes how we collect, use, store, share and protect your personal data, and explains your rights in relation to that data.

This Policy applies to all users of the Platform regardless of location, including users accessing the Platform from Pakistan. It forms part of our Terms and Conditions and should be read alongside them. By registering an account, depositing funds, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing activities described herein.

Definitions

In this Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, date of birth, IP address, and financial information.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 92pak5.
• "Data Processor" means any third party that processes Personal Data on behalf of 92pak5 under a data processing agreement.
• "KYC" means Know Your Customer — the identity 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 collect and store information about your visit.
• "User" or "you" means any individual who registers, accesses or uses the 92pak5 Platform.

Data Controller

92pak5, operating the Platform at https://92pak5.cam, acts as the Data Controller in respect of Personal Data processed in connection with the Platform and Services. 92pak5 is responsible for determining the purposes and means of processing your Personal Data as described in this Policy.

For all data-related enquiries, requests to exercise your rights, or complaints regarding how your Personal Data is handled, please contact us using the details provided in Section 15 of this Policy.

Personal Data We Collect

4.1 Data You Provide Directly

We collect Personal Data that you provide directly when interacting with the Platform, including during account registration, KYC verification, payment processing and customer support interactions:

4.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically by our systems or third-party analytics tools:

• IP address and approximate geolocation;
• Device type, operating system and browser version;
• Pages visited, time spent on page and navigation patterns;
• Session duration and login timestamps;
• Referring URL or source of traffic;
• Cookie identifiers and similar tracking data (see Section 10).

4.3 Data from Third Parties

We may receive Personal Data about you from third-party sources, including KYC verification partners, fraud detection services, and payment processors (such as those facilitating transactions via methods familiar to Pakistani users — though we note that no payment provider endorses or facilitates gambling on our Platform). Data received from third parties is handled in accordance with this Policy and the terms under which it was obtained.

Purposes of Processing & Legal Basis

We process your Personal Data only for specified, explicit and legitimate purposes. The table below outlines the primary purposes for which we process Personal Data and the legal basis relied upon:

We do not process Personal Data for purposes incompatible with those listed above. If we intend to process your Personal Data for a new purpose, we will provide updated notice before doing so.

Sharing Your Personal Data

6.1 Service Providers

We engage carefully selected third-party service providers who process Personal Data on our behalf as Data Processors. These include: KYC and identity verification partners; payment processing infrastructure providers; cloud hosting and server infrastructure providers; customer support platform providers; and analytics and fraud detection services. All Data Processors are bound by data processing agreements that restrict how they may use your data.

6.2 Legal Authorities

We may disclose Personal Data to law enforcement agencies, regulatory authorities, courts or other governmental bodies where we are legally required to do so, or where we reasonably believe that disclosure is necessary to: comply with a legal obligation; protect the rights, property or safety of 92pak5, our users or third parties; or prevent, detect or prosecute fraud or criminal activity.

6.3 No Sale of Personal Data

We do not sell, rent or trade your Personal Data to third parties for their own marketing or commercial purposes. Any data sharing is strictly limited to the purposes described in this Policy.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the 92pak5 business, Personal Data held by us may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection commitments.

International Data Transfers

Given the global nature of online services, your Personal Data may be transferred to, stored and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where we transfer Personal Data internationally, we take steps to ensure that adequate safeguards are in place — such as standard contractual clauses or equivalent mechanisms — to protect your data in accordance with applicable data protection standards. By using the Platform, you acknowledge and consent to such transfers where necessary for the delivery of our Services.

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. The specific retention period for each category of data depends on the legal basis for processing and any applicable statutory retention obligations.

In general, account and transactional records — including KYC documents and PKR financial transaction histories — are retained for a minimum period to comply with applicable anti-money laundering and financial record-keeping requirements, even after account closure. Marketing preferences and communication data are retained for shorter periods or until consent is withdrawn, whichever is earlier.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised. Anonymised data (from which you cannot be identified) may be retained indefinitely for statistical and analytical purposes.

Security Measures

92pak5 implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, loss, alteration, disclosure or destruction. Our security measures include, but are not limited to:

• Encryption of data in transit using TLS/SSL protocols;
• Encryption of sensitive data at rest where applicable;
• Role-based access controls limiting data access to authorised personnel only;
• Secure and regularly audited server infrastructure;
• Internal data handling procedures and staff training;
• Monitoring for suspicious access patterns and security incidents.

Cookies & Similar Technologies

10.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They allow the website to remember your actions and preferences over time, and to collect information about how the site is used.

10.2 Types of Cookies We Use

10.3 Managing Cookies

You can manage or disable cookies through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the Platform, including account login. Disabling performance or marketing cookies will not prevent you from using the Platform but may limit personalisation.

Minors

The 92pak5 Platform is strictly for adults aged 18 years or older — or the higher minimum age required by the operator/license jurisdiction. We do not knowingly collect Personal Data from minors. Age is verified through our KYC process during account registration.

If we become aware that we have collected Personal Data from a person below the applicable minimum age without parental consent, we will take immediate steps to close the account, delete the data and, where applicable, return any deposited funds to the payment source. If you believe a minor may have registered an account, please contact us immediately at the support address in Section 15.

Your Data Rights

Subject to applicable law and certain legal exceptions, you have the following rights in relation to your Personal Data held by 92pak5:

• Right of Access: Request a copy of the Personal Data we hold about you and information about how it is being processed.
• Right to Rectification: Request correction of inaccurate or incomplete Personal Data.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your Personal Data where it is no longer necessary, subject to legal retention obligations — for example, statutory AML record-keeping periods.
• Right to Restriction of Processing: Request that we limit how we process your data in certain circumstances.
• Right to Data Portability: Receive a structured, machine-readable copy of Personal Data you have provided, where technically feasible.
• Right to Object: Object to processing based on legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, submit your request to our support team using the contact details in Section 15. We will aim to respond within a reasonable timeframe. We may need to verify your identity before processing your request. Some rights may be subject to exemptions or limitations under applicable law.

Marketing Communications

Where you have opted in to receive marketing communications during registration or through your account preferences, we may send you promotional information about 92pak5 services, bonuses and events by email or in-platform notification.

You can withdraw your consent to marketing communications at any time by: updating your communication preferences in your account settings; clicking the unsubscribe link in any marketing email; or contacting our support team directly.

Withdrawing marketing consent does not affect the processing of your Personal Data for other purposes described in this Policy (such as account management, KYC and transaction processing), nor does it affect the lawfulness of any marketing communications sent before the withdrawal.

Updates to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our data processing activities, applicable law, or platform functionality. The effective date at the top of this Policy indicates when it was last reviewed.

Where we make material changes to this Policy, we will provide notice through the Platform or by email to your registered address. We encourage you to review this Policy periodically. Your continued use of the Platform following publication of any updated Policy constitutes your acceptance of the revised terms.

Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data — including requests to exercise your data rights — please contact us using the details below:

This Privacy Policy was last reviewed for the 2026 platform version. 92pak5 reserves the right to update this Policy at any time in accordance with Section 14. Continued use of the Platform constitutes acceptance of the current version of this Policy.