pakgae Privacy Policy

This Privacy Policy ("Policy") applies to all personal data processed by pakgae in connection with your access to and use of the pakgae platform at pakgae.net, including all associated mobile-optimised pages, account dashboards, and support channels.

This Policy should be read alongside our Terms & Conditions and any product-specific or promotion-specific terms, all of which together form the complete agreement governing your relationship with pakgae. In the event of a conflict between this Policy and any other document, this Policy shall prevail with respect to data protection matters.

pakgae is committed to handling all personal data responsibly, lawfully, and transparently. We do not use personal data in any manner that is incompatible with the purposes stated in this Policy. This commitment extends across every team, system, and third-party relationship involved in delivering the pakgae platform to Pakistani players.

For the purposes of applicable data protection law, pakgae is the data controller in respect of all personal data collected from players who register, deposit, play, and interact with the platform at pakgae.net. As data controller, pakgae determines the purposes for which personal data is processed and the means by which that processing is carried out.

pakgae operates under an international gaming licence. Data protection obligations are incorporated directly into the conditions of that licence, which requires that all player data is handled in accordance with recognised international data protection standards.

If you have any questions about how your data is controlled or processed, or if you wish to exercise any of your data subject rights described in Section 11, please contact our Data Protection team at [email protected], clearly marking your message with the subject line "Data Protection Request".

pakgae collects personal data across several categories depending on the nature of your interaction with the platform. The table below summarises the categories of data we collect and typical examples within each category:

pakgae does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where health-related information is voluntarily provided by a player in the context of a responsible gaming self-exclusion request, in which case it is processed solely for the purpose of facilitating that request.

pakgae collects personal data through the following channels and methods:

• Direct submission: Data you provide when completing the registration form, submitting KYC documentation, making deposits or withdrawals, contacting support, or responding to promotional surveys.
• Automated collection: Technical data collected automatically when you access the platform, including IP address, device fingerprint, browser type, and session metadata gathered via server logs and first-party cookies.
• Payment processors: Financial transaction data shared with pakgae by JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, Visa, and Mastercard in the course of processing your deposits and withdrawals.
• KYC and identity verification partners: Confirmation or rejection signals returned by our third-party CNIC verification partner following document submission. Raw document images are never stored longer than necessary for verification.
• Responsible gaming tools: Data generated when you interact with deposit limit settings, session timers, self-exclusion requests, or reality check notifications within your account dashboard.
• Publicly available sources: In limited AML-related circumstances, pakgae may cross-reference data against publicly available watchlists or sanctions databases to fulfil our regulatory obligations.

pakgae does not purchase personal data from data brokers or any third-party data aggregator for use in player profiling or targeted advertising.

Every instance of personal data processing at pakgae is carried out on one of the following lawful bases recognised under applicable data protection frameworks:

• Contract performance: Processing necessary to open your account, verify your identity, process deposits and withdrawals, resolve disputes, and deliver the gaming services you have contracted with pakgae to receive.
• Legal obligation: Processing required by our international gaming licence, including KYC verification, AML screening, transaction monitoring, and record-keeping obligations mandated by our licensing authority.
• Legitimate interests: Processing carried out in pakgae's legitimate interest of maintaining platform security, preventing fraud, conducting internal analytics to improve service quality, and communicating material service updates to players — balanced against and not overriding your fundamental rights and freedoms.
• Consent: Processing for non-essential purposes — such as the delivery of personalised promotional offers and marketing communications — where you have given a clear, informed, and freely given opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

pakgae uses the personal data we collect for the following specific purposes:

• To create, verify, maintain, and close your pakgae player account in accordance with our Terms & Conditions.
• To process deposits, withdrawals, and all financial transactions on your account in PKR through your chosen payment method.
• To conduct mandatory KYC identity verification and ongoing AML transaction monitoring as required by our licensing obligations.
• To verify that you meet the 21+ age requirement and are not subject to a self-exclusion order before granting access to gambling products.
• To provide customer support, investigate complaints, and resolve disputes fairly and promptly.
• To deliver responsible gaming tools, including session time reminders, deposit limit confirmations, reality check notifications, and self-exclusion enforcement.
• To detect, investigate, and prevent fraudulent transactions, collusion, bonus abuse, multi-accounting, and other prohibited conduct outlined in our Terms & Conditions.
• To personalise your platform experience, including recommending games or promotions that align with your demonstrated preferences — only where you have consented to this personalisation.
• To send you service communications that are strictly necessary — such as account security alerts, deposit confirmations, withdrawal notifications, and material policy updates.
• To send marketing communications about pakgae promotions, bonuses, and new products — only where you have opted in and only through your preferred channel.
• To conduct internal analytics that help us improve platform performance, game selection, payment processing speed, and responsible gaming tool effectiveness.
• To fulfil any legal, regulatory, or licensing obligation to which pakgae is subject, including responding to lawful requests from regulatory or law enforcement authorities.

pakgae does not sell, rent, or trade your personal data to any third party. We share your data only in the following circumstances and only to the minimum extent necessary:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, Visa, and Mastercard receive the transaction data necessary to process your deposits and withdrawals. Each processor is contractually bound to process this data solely for payment facilitation.
• KYC and identity verification providers: Our licensed KYC partner receives your CNIC documentation and returns a verification result. This provider operates under a formal data processing agreement and is prohibited from using your data for any purpose other than the verification service.
• Game software providers: Game providers whose titles are hosted on the pakgae platform may receive anonymised session data for game integrity and RNG certification purposes. No directly identifiable personal data is shared with game providers.
• Licensing authority: pakgae's international gaming licensing authority may require access to player data, transaction records, or audit logs as part of its regulatory oversight function. Compliance with such requests is a mandatory obligation under our licence.
• Fraud prevention and AML databases: We may cross-reference account data against industry-shared fraud prevention registers and sanctions screening services to comply with anti-money laundering obligations.
• Legal and law enforcement authorities: Where we receive a lawful order, court instruction, or legally mandated request from a competent authority in the relevant jurisdiction, we are required to disclose the specified data. We will notify you of such a disclosure where we are legally permitted to do so.
• Business transfers: In the event that pakgae undergoes a merger, acquisition, or asset sale, player data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection obligations being assumed by the new controller.

Given that pakgae operates under an international gaming licence and uses globally distributed technology infrastructure, your personal data may be transferred to and processed in countries outside Pakistan. Such transfers occur when:

• Data is processed on cloud infrastructure hosted in data centres located outside Pakistan.
• Data is shared with our KYC provider, game software partners, or payment network processors whose systems are operated internationally.
• Data is transmitted to our licensing authority, which operates in a jurisdiction outside Pakistan.

Where personal data is transferred internationally, pakgae ensures that appropriate safeguards are in place. These safeguards include contractual data processing agreements incorporating standard data protection clauses, technical security measures including encryption in transit and at rest, and contractual restrictions on onward transfer and secondary use of the transferred data.

By using the pakgae platform and accepting these terms, you acknowledge and consent to the international transfer of your personal data in the circumstances and under the safeguards described in this section.

pakgae retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods imposed by our regulatory and licensing obligations:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that makes re-identification impossible. Anonymised data may be retained indefinitely for aggregate analytics purposes.

pakgae uses cookies and similar tracking technologies on the pakgae.net platform. A cookie is a small text file placed on your device by our web server. Cookies allow us to recognise your device, maintain your session, and remember your preferences between visits.

We use the following categories of cookies:

• Strictly necessary cookies: These are essential for the platform to function. They maintain your login session, remember your language preference, and prevent cross-site request forgery. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies: These remember your non-essential preferences — such as your preferred game view, last visited lobby section, or responsible gaming reminder settings — to provide a more personalised experience.
• Analytics cookies: These collect anonymised data about how players navigate the platform, which pages are visited most frequently, and where errors occur. This data is used to improve platform performance and user experience. No individually identifiable information is collected through analytics cookies.
• Security cookies: These help detect unusual login patterns, prevent session hijacking, and support fraud detection systems.

pakgae does not use third-party advertising cookies or any cookies that track your activity outside of the pakgae.net domain. You can control and delete cookies through your browser settings at any time. Disabling strictly necessary cookies will affect your ability to use the platform.

As a data subject, you hold the following rights in relation to your personal data processed by pakgae. To exercise any of these rights, contact our Data Protection team at [email protected] with the subject line "Data Subject Rights Request". We will respond within 30 calendar days.

• Right of Access: You may request a copy of all personal data pakgae holds about you, along with information about how it is being used and with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected or updated. Note that changes to KYC data will require re-submission of supporting documentation.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where there is no longer a lawful basis for its retention. Note that this right is subject to our regulatory and licensing retention obligations, which in most cases require us to retain core account and transaction data for a minimum of five to seven years after account closure.
• Right to Restrict Processing: You may request that we limit the processing of your data to storage only, pending the resolution of a dispute about its accuracy or the lawful basis for its processing.
• Right to Data Portability: Where processing is based on contract or consent and is carried out by automated means, you may request that your personal data be provided to you in a structured, commonly used, and machine-readable format.
• Right to Object: Where processing is based on legitimate interests, you have the right to object to that processing. pakgae will cease the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on your consent — for example, marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

The pakgae platform is strictly intended for adults aged 21 and over. pakgae does not knowingly collect, process, or store personal data from any person under the age of 21. Age verification is a mandatory step in the registration process, and all accounts are subject to KYC verification that confirms the player's age using CNIC documentation.

If pakgae becomes aware that personal data has been collected from a person under the age of 21 — whether through registration fraud, misrepresentation of age, or any other means — the following steps will be taken immediately:

• The account will be suspended and access to the platform blocked without delay.
• All real-money balance in the account will be returned to the originating payment method, less any promotional bonuses.
• All personal data associated with the account will be deleted as soon as legally permissible.
• The incident will be logged and, where appropriate, reported to relevant safeguarding or regulatory authorities.

Parents and guardians who believe a minor may have accessed the pakgae platform using false information are urged to contact our support team immediately at [email protected]. We treat all such reports with the highest priority.

pakgae implements a layered approach to data security, combining technical controls, organisational policies, and contractual obligations on all third parties who process player data on our behalf. Our security framework includes:

• TLS encryption: All data in transit between your device and pakgae's servers is protected by TLS 1.2 or higher. Connections using outdated or insecure protocols are rejected.
• AES-256 encryption at rest: Sensitive personal and financial data stored in our databases is encrypted at rest using AES-256 block cipher encryption.
• Access controls: Internal access to player data is restricted to authorised personnel on a strict need-to-know basis. All internal access is logged and subject to periodic review.
• Two-factor authentication: Players are encouraged to enable SMS-based two-factor authentication on their accounts. All internal staff accounts require multi-factor authentication.
• Penetration testing: pakgae's platform undergoes regular penetration testing by independent security professionals to identify and remediate vulnerabilities before they can be exploited.
• Incident response: pakgae maintains a documented data breach response procedure. In the event of a breach affecting player data, affected players will be notified within 72 hours of our becoming aware of the breach, consistent with applicable notification obligations.

Despite our best efforts, no online platform can guarantee absolute security against all possible threats. You are responsible for maintaining the security of your own device, keeping your account credentials confidential, and notifying us immediately of any suspected unauthorised access to your account.

pakgae will only send you promotional and marketing communications — including emails, SMS messages, and in-platform notifications about bonuses, new games, and special offers — where you have given your explicit consent to receive such communications during registration or at a later point through your account settings.

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

• Clicking the "Unsubscribe" link included at the bottom of every marketing email we send.
• Updating your communication preferences within the notification settings section of your pakgae account dashboard.
• Contacting our support team at [email protected] and requesting removal from all marketing lists.

Withdrawal of marketing consent will be processed within five (5) business days. Please note that even after opting out of marketing communications, you will continue to receive transactional communications that are necessary for the operation of your account — such as deposit confirmations, withdrawal notifications, security alerts, and responsible gaming tool updates. These communications are not optional as they relate directly to the management of your account and your safety as a player.

pakgae reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing practices, or the technology we use to operate the platform.

When material changes are made to this Policy — changes that significantly affect how your personal data is collected, used, or shared — pakgae will notify registered players by email to their registered address and by displaying a prominent notice on the platform for a minimum of seven (7) days before the changes take effect.

Minor or non-material changes — such as clarifications of existing practices, corrections of typographical errors, or restructuring of the document for improved readability — will be made without separate notification, though the "Last Updated" date at the top of this page will always reflect the most recent revision.

Continued use of the pakgae platform following the effective date of any amendment to this Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you should cease using the platform and contact our support team to request account closure.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which pakgae handles your personal data, please contact our Data Protection team using the details below. All contact must be treated as plain-text reference only — none of the following are clickable links.

• Email: [email protected]
• Subject Line: Please use "Privacy Policy Query" or "Data Subject Rights Request" as appropriate
• Response Target: Within 5 business days for general privacy queries; within 30 calendar days for formal data subject rights requests
• Languages: English and Urdu
• Support Hours: 24 hours a day, 7 days a week

If you are not satisfied with our response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority or the dispute resolution body designated by pakgae's licensing authority. Details of this escalation route are available upon request.