Privacy Policy — pk35

This Privacy Policy ("Policy") describes how pk35 ("pk35", "we", "us", "our") collects, uses, stores, discloses and otherwise processes personal data relating to users ("you", "your") of the pk35 platform located at https://pk35.cam (the "Platform"). This Policy applies to all users, whether registered account-holders or unregistered visitors.

pk35 is committed to handling personal data responsibly, transparently and in accordance with applicable data-protection principles. By accessing or using the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree to this Policy, please discontinue use of the Platform.

This Policy should be read alongside our Terms & Conditions, which govern the broader use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions on data-processing matters, this Policy prevails.

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person. This includes your name, date of birth, email address, IP address, CNIC number and any other data that could be used, alone or in combination, to identify you.
• "Processing" means any operation performed on personal data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller.
• "KYC" means Know Your Customer — identity verification checks conducted to confirm a user's identity, age and place of residence.
• "Cookies" means small text files placed on your device by the Platform to enable certain functionality and analytics.
• "Operator" means the licensed gaming entity that provides the gaming products and services accessible through the Platform.

For the purposes of this Policy, pk35 acts as the Data Controller in respect of personal data collected through the Platform in connection with your use of pk35's information services. Where personal data is processed by the Operator in connection with licensed gaming activities (account registration, deposits, withdrawals, KYC compliance), the Operator acts as a separate or joint Data Controller, and you should also refer to the Operator's own privacy documentation.

pk35 collects personal data through various channels depending on how you interact with the Platform. The categories of data we collect are described in the table below:

We do not collect special categories of sensitive personal data (such as health data, biometric data or political opinions) except where strictly necessary for compliance purposes and only with your explicit consent or as permitted by applicable law.

pk35 processes your personal data only for specified, explicit and legitimate purposes. The principal purposes for which we process data are as follows:

• Account Management: Creating, maintaining and managing your registered account, including authentication and security.
• KYC & Compliance: Verifying your identity and age as required by the Operator's licensing obligations and applicable anti-money-laundering (AML) regulations.
• Transaction Processing: Facilitating deposits, withdrawals and any other financial transactions through the Platform's cashier, including the recording and reconciliation of transaction histories.
• Customer Support: Responding to your enquiries, resolving complaints and providing technical assistance through live chat, the Help Centre and email.
• Platform Improvement: Analysing usage data on an aggregated and anonymised basis to improve Platform functionality, user experience and content quality.
• Responsible Gambling: Recording and enforcing responsible gambling tool settings (deposit limits, self-exclusion periods, session timers) to protect user welfare.
• Marketing Communications: Where you have opted in, sending information about promotions, bonuses or relevant Platform updates. You may withdraw consent at any time by updating your communication preferences in the account settings.
• Fraud Prevention & Security: Detecting, investigating and preventing fraudulent transactions, account abuse, collusion and other forms of prohibited conduct as described in the Terms & Conditions.
• Legal Obligations: Complying with applicable laws, court orders, regulatory directives and requests from competent authorities.

Where data-protection law requires pk35 to identify a legal basis for each processing activity, we rely on the following:

• Contractual Necessity: Processing required to perform the contract between you and pk35 (or the Operator), including account creation, transaction processing and KYC verification.
• Legal Obligation: Processing necessary to comply with the Operator's licensing requirements, AML legislation and lawful requests from regulatory or law-enforcement authorities.
• Legitimate Interests: Processing carried out in our legitimate interests or those of the Operator — including fraud prevention, platform security and analytics — where these interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific and informed consent — primarily for optional marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

pk35 does not sell, rent or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances:

• Service Providers (Data Processors): Third-party companies engaged by pk35 to provide specific services — such as payment processing, KYC verification, customer-support platform hosting, and analytics — receive only the data necessary to perform those services and are contractually bound to process it only for the specified purpose.
• The Operator: Where you register an account and access gaming services through the Platform, relevant personal and KYC data is shared with the Operator for account-management and licensing-compliance purposes.
• Regulatory and Law-Enforcement Authorities: Where required by applicable law, a court order or a request from a competent regulatory or governmental authority, pk35 will disclose personal data to the relevant body. This may include disclosure in connection with AML investigations or licensing-compliance audits.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of pk35's business, personal data may be transferred to the successor entity, subject to equivalent data-protection obligations.

The Platform is operated in the context of an international online gaming environment. As a result, personal data collected from you may be transferred to and processed in countries outside Pakistan and, where applicable, outside the European Economic Area (EEA). Where such transfers occur, pk35 and the Operator apply appropriate safeguards to protect the data, which may include:

• Standard contractual clauses approved by relevant data-protection authorities.
• Transfers to countries recognised as providing an adequate level of data protection by applicable regulatory bodies.
• Binding corporate rules where applicable within a group of companies.

You may contact our support team for further information about the specific safeguards applied to any international data transfers affecting your personal data.

pk35 retains personal data for as long as necessary to fulfil the purposes for which it was collected, including the satisfaction of any legal, accounting or regulatory requirements. Specific retention periods are determined by the nature of the data and the purpose of processing:

• Account and Identity Data: Retained for the duration of your account plus such additional period as required by the Operator's licensing obligations — typically five years following account closure, to meet AML record-keeping requirements.
• Transaction Records: Retained in accordance with applicable financial-record-keeping requirements, generally a minimum of five years from the date of the transaction.
• Support Communications: Retained for up to three years from the date of the last communication, unless a longer period is required for complaint-resolution or legal purposes.
• Marketing Consent Records: Retained until you withdraw consent, plus a reasonable period thereafter to evidence that the consent was lawfully obtained.
• Technical and Usage Data: Anonymised aggregated analytics data may be retained indefinitely; individual-level technical data is retained for up to 24 months.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

pk35 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include, without limitation:

• Encryption of data in transit using TLS (Transport Layer Security) protocols.
• Encryption of sensitive data at rest where appropriate.
• Role-based access controls limiting staff access to personal data on a need-to-know basis.
• Regular internal security assessments and penetration testing.
• Incident response procedures designed to detect, contain and report data breaches within applicable regulatory timeframes.

pk35 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session continuity and gather anonymised usage analytics. The cookies we use fall into the following categories:

You can manage or disable cookies through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use core Platform features including login. For analytics and marketing cookies, you may withdraw consent at any time without affecting prior processing.

Subject to applicable law and the Operator's regulatory obligations (which may in certain circumstances require data to be retained regardless of your request), you have the following rights in relation to your personal data:

To exercise any of these rights, please contact the pk35 support team via live chat or the Help Centre. We will acknowledge your request within a reasonable period and respond fully within the timeframe required by applicable law. We may need to verify your identity before actioning any request.

The Platform is intended solely for users who are 18 years of age or above, or the higher minimum age required by the Operator's license jurisdiction. pk35 does not knowingly collect personal data from individuals under the required minimum age. If we become aware that personal data has been collected from a minor — whether through registration, KYC submission or any other means — we will take immediate steps to delete that data and close the associated account.

If you believe that a minor may have submitted personal data to the Platform, please contact our support team immediately via live chat so that the matter can be investigated and the data removed without delay.

pk35 reserves the right to amend this Privacy Policy at any time. Where material changes are made, registered users will be notified by email or through a prominent notice on the Platform prior to the change taking effect. Non-material amendments — such as minor clarifications or corrections — may be made without advance notification, though the "Last Reviewed" date at the top of this page will always be updated.

Your continued use of the Platform following the publication of any amended Policy constitutes your acceptance of the revised terms. If you do not agree to any amendment, you should cease using the Platform and may contact support to request account closure.

For any queries, concerns or requests relating to this Privacy Policy or the handling of your personal data, please contact pk35 through the following channels:

When contacting us about a data request, please provide your registered email address and, where applicable, your account username so that we can locate your records and verify your identity efficiently.