pak399 Privacy Policy — Your Data, Your Rights, Our Responsibility

1. Data Controller

pak399 (referred to in this Policy as "pak399", "we", "us", or "our") is the data controller responsible for the personal information collected through the website located at pak399.vip and any related mobile-optimised interfaces. pak399 is operated under an international gaming license and is committed to processing personal data lawfully, fairly, and transparently in accordance with applicable data protection law and the requirements of our licensing jurisdiction .

For all data protection enquiries, you may contact pak399 via live chat on the website or by emailing the support team at [email protected]. We will acknowledge your enquiry promptly and respond in full within 30 calendar days.

2. Data We Collect

pak399 collects personal data through several channels: directly from you when you register or use the platform, automatically through your use of the website, and from third-party service providers such as KYC verification agencies and payment processors. The categories of data we collect include:

2.1 Registration & Account Data

• Full legal name as it appears on your CNIC or valid government-issued identity document
• Date of birth (used to verify that you meet the 21+ age requirement)
• Email address and mobile phone number
• Residential address (city, province, postal code)
• Username and encrypted account password
• Preferred language and communication preferences

2.2 Identity Verification (KYC) Data

• Pakistani CNIC number and a scan or photograph of the CNIC document
• Proof of address documentation where required by our compliance team
• Selfie or live photograph submitted for facial verification purposes
• Source of funds declarations where required under AML procedures

2.3 Financial & Transaction Data

• JazzCash or EasyPaisa mobile wallet numbers associated with deposits and withdrawals
• Bank account details (account title, IBAN) for bank transfer transactions with HBL, UBL, Meezan Bank, or other supported institutions
• Deposit amounts, withdrawal amounts, and transaction timestamps in PKR
• USDT TRC20 wallet addresses where cryptocurrency deposits or withdrawals are used
• Transaction reference numbers and payment processor confirmation codes

2.4 Gaming & Activity Data

• Game session histories including game title, stake, outcome, and session duration
• Sports betting records including markets selected, odds accepted, and settlement outcomes
• Bonus claims, wagering progress, and promotional participation history
• Responsible gaming tool settings including deposit limits, session limits, and self-exclusion status

2.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system version, and browser type
• Pages visited, time spent on each page, and navigation paths within pak399.vip
• Session identifiers and authentication tokens
• Cookie data as described in Section 8 of this Policy

2.6 Communications Data

• Live chat transcripts and support ticket correspondence
• Email correspondence with the pak399 support team
• Responses to surveys, feedback forms, or promotional communications where you voluntarily participate

3. Purpose & Legal Basis for Processing

pak399 processes your personal data only where a valid legal basis exists. The primary purposes and their corresponding legal bases are set out below:

• Account registration and operation: Processing is necessary for the performance of the contract between you and pak399 — specifically, to create and maintain your gaming account and deliver the services you have signed up for.
• KYC identity verification and age checking: Processing is required to comply with our legal obligations under the terms of our international gaming license, including mandatory verification that all players are aged 21 or over.
• Payment processing and financial record-keeping: Processing is necessary both for contractual performance (to execute deposits and withdrawals in PKR) and for compliance with applicable AML and financial record-keeping obligations.
• Fraud prevention and security: Processing is carried out in the legitimate interests of pak399 and its players to detect, investigate, and prevent fraudulent activity, money laundering, and unauthorised account access.
• Responsible gaming monitoring: Processing is required under our licensing obligations to monitor player behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be exhibiting signs of problem gambling.
• Customer support: Processing is necessary for the performance of our service obligations and in our legitimate interest to resolve player queries and complaints efficiently.
• Marketing communications: Where you have given explicit consent, pak399 may send you promotional emails or messages regarding bonuses, new games, and platform updates. You may withdraw this consent at any time by contacting support.
• Platform improvement and analytics: Processing is carried out in pak399's legitimate interest to understand how the platform is used, improve user experience, and optimise performance on mobile devices commonly used across Pakistan.

4. Data Sharing & Disclosure

pak399 does not sell or rent your personal data to any third party. We share personal data only in the following limited circumstances, and only to the extent strictly necessary:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and other payment service providers receive the transaction data required to process your deposits and withdrawals. These providers operate under their own privacy policies and regulatory obligations.
• KYC and identity verification providers: Third-party identity verification services receive your CNIC details and verification documents solely for the purpose of confirming your identity and age in compliance with our licensing requirements.
• Game providers: Licensed game software providers (such as Pragmatic Play and PG Soft) may receive session and wagering data necessary to deliver game content, settle bets, and calculate progressive jackpot contributions. No personally identifiable registration data is shared beyond what is required for game delivery.
• Regulatory and licensing authorities: pak399 may be required to disclose account and transaction data to our licensing authority or to competent regulatory bodies in connection with audits, investigations, or compliance reviews.
• Law enforcement and legal process: pak399 will disclose personal data to law enforcement agencies, courts, or other public authorities where required to do so by applicable law, court order, or in connection with the investigation of fraud, money laundering, or other criminal activity.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or substantially all of the assets of pak399, your personal data may be transferred to the acquiring entity, subject to the same data protection obligations described in this Policy.

5. International Data Transfers

As pak399 operates under an international gaming license and uses globally distributed technology infrastructure, your personal data may be processed in countries outside Pakistan. Where such transfers occur, pak399 ensures that appropriate safeguards are in place — including data processing agreements with contractual clauses that require overseas recipients to protect personal data to the same standard as required under our licensing jurisdiction.

Specifically, your data may be processed in the jurisdiction in which our licensing authority is located, as well as in the data centres and processing facilities of our game providers and payment technology partners. pak399 does not transfer personal data to any jurisdiction without first confirming that adequate protections are in place.

6. Data Retention

pak399 retains personal data for the following periods:

• Active account data: Retained for the full duration of your account relationship with pak399.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure, in compliance with our gaming license AML obligations.
• Financial transaction records: Retained for a minimum of five (5) years following the date of each transaction, as required for financial audit and AML compliance.
• Gaming session records: Retained for a minimum of three (3) years for responsible gaming monitoring, dispute resolution, and license audit purposes.
• Support correspondence: Retained for two (2) years following the resolution of each support interaction.
• Marketing consent records: Retained for the period during which consent is active, plus one (1) year following withdrawal of consent for audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual. Where deletion is technically complex, pak399 ensures the data is quarantined and inaccessible pending scheduled deletion.

7. Your Data Rights

Subject to applicable law and the requirements of our gaming license, you hold the following rights with respect to your personal data held by pak399:

To exercise any of the above rights, contact the pak399 support team via live chat or at [email protected]. We will verify your identity before processing any request and will respond within 30 calendar days. Please note that certain rights may be limited where pak399 is required to retain data to comply with gaming license obligations or applicable law.

8. Cookies & Tracking Technologies

pak399 uses cookies and similar tracking technologies to operate the website, maintain your login session, remember your preferences, and analyse how players use the platform. The types of cookies we use are:

• Strictly necessary cookies: Required for the website to function. These include session cookies that keep you logged in and security tokens that protect your account. These cannot be disabled without impairing core website functionality.
• Functional cookies: Used to remember your preferences such as language settings, preferred payment method display, and responsible gaming tool configurations.
• Analytical cookies: Used to collect aggregated, anonymised data about how players navigate pak399.vip — which pages are most visited, where users exit the funnel, and how mobile performance compares across device types. This data is used solely to improve the platform.
• Session authentication tokens: Short-lived tokens stored in your browser to maintain a secure, authenticated session between your device and pak399 servers. These expire automatically when you log out or close your browser session.

pak399 does not use third-party advertising cookies or cross-site tracking cookies. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the pak399 platform.

9. Minors & Age Policy

pak399 strictly prohibits the use of its platform by anyone under the age of 21. This is a non-negotiable requirement enforced through mandatory CNIC-based KYC verification during the account registration process. pak399 does not knowingly collect personal data from individuals under 21.

If pak399 becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, all funds will be handled in accordance with our terms and conditions and licensing obligations, and the personal data will be flagged for review and deletion in line with applicable legal requirements.

10. Security Measures

pak399 implements technical and organisational security measures proportionate to the risk associated with processing personal data on a licensed gaming platform. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and pak399 servers
• Bcrypt hashing of all account passwords — plain-text passwords are never stored
• Two-factor authentication (2FA) available to all account holders for additional login security
• Regular penetration testing and security audits of the pak399 platform infrastructure
• Role-based access controls ensuring that pak399 staff access personal data only on a strict need-to-know basis
• Encrypted storage of KYC documents and financial records at rest
• Automated fraud detection and anomaly monitoring on all account activity and transactions

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, pak399 will notify affected users and the relevant regulatory authority in line with our obligations under our gaming license and applicable law.

11. Changes to This Policy

pak399 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, our licensing requirements, or our data processing practices. Where changes are material, pak399 will notify registered account holders by email to the address associated with their account, or via an in-platform notification, at least 14 days before the updated Policy takes effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically. Continued use of pak399.vip following notification of changes constitutes acceptance of the updated Policy.

12. Contact & Data Requests

For all privacy-related enquiries, data access requests, rectification requests, deletion requests, or complaints regarding how pak399 processes your personal data, please contact us through one of the following channels:

• Live Chat: Available 24/7 directly on pak399.vip — the fastest way to reach our support team
• Email: [email protected] — please include "Privacy Request" in the subject line so your enquiry is routed to the appropriate team

pak399 will acknowledge all privacy-related requests within five (5) business days and provide a full response within 30 calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

If you are not satisfied with how pak399 has handled your personal data or responded to a request, you have the right to escalate your complaint to the relevant data protection supervisory authority or to our gaming license regulatory body.