pak65 Privacy Policy

pak65 ("pak65", "we", "us" or "our") operates the website at https://pak65.cam — an English-language online betting information platform targeting Pakistani users across cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar, as well as users throughout Pakistan.

This Privacy Policy describes how pak65 collects, uses, discloses, stores and protects personal information obtained through your interaction with the Platform. It also sets out your rights with respect to that data and explains how to exercise those rights.

This Policy should be read alongside our Terms & Conditions, which govern the overall terms of your use of the Platform. By accessing or using pak65, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices it describes.

The following defined terms are used throughout this Privacy Policy:

For the purposes of this Privacy Policy, pak65 acts as the Data Controller in respect of Personal Data collected through the Platform. As Data Controller, pak65 determines the purposes for which your data is processed and the means by which it is handled.

Where pak65 engages third-party service providers (for example, analytics platforms or hosting infrastructure) to process data on our behalf, those providers act as Data Processors and are bound by contractual obligations to handle data only in accordance with our instructions.

If you have any questions about how pak65 handles data, or wish to exercise your rights described in Section 11, please contact us using the details in Section 16.

pak65 collects data through the following channels:

• Contact Enquiries: If you contact pak65 by email, we collect your email address, name (if provided) and the content of your message.
• Support Requests: Any information you provide when submitting a support query, including your registered username (where applicable) and the nature of your request.

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution and referring URL.
• Usage Data: Pages visited, time spent on pages, links clicked, scroll depth and navigation path through the Platform.
• Cookie Data: Session identifiers, preference flags and analytics identifiers stored in cookies or similar technologies (see Section 8).

pak65 does not collect or process gambling transaction data, financial account details, payment instrument data (card numbers, bank account numbers, Easypaisa wallet credentials, JazzCash PINs) or government-issued identity documents. Such data is processed exclusively by the relevant Operator or payment provider, subject to their own privacy policies.

pak65 processes Personal Data only where a valid legal basis exists. The applicable bases are as follows:

Where pak65 relies on legitimate interests as a legal basis, we have conducted and documented a balancing test confirming that our interests do not override your fundamental privacy rights.

pak65 uses Personal Data for the following purposes:

• Platform Operation: To deliver, maintain and improve the content and functionality of the Platform, including ensuring pages load correctly for users in Karachi, Lahore and other Pakistani cities.
• Analytics: To understand how users navigate the Platform — which pages receive the most traffic, where users drop off and which content is most useful — so we can improve the user experience.
• Security: To detect, prevent and investigate fraud, abuse, unauthorised access and other security incidents.
• Support: To respond to enquiries, resolve technical issues and process responsible gambling support requests.
• Legal Compliance: To fulfil obligations under applicable law, including responding to lawful requests from courts, law enforcement or regulatory authorities.
• Policy Enforcement: To enforce our Terms & Conditions and other policies applicable to Platform use.

pak65 does not use Personal Data for the following purposes:

• Selling data to third-party advertisers or data brokers;
• Behavioural advertising or cross-site tracking;
• Automated decision-making or profiling that produces legal or similarly significant effects on users;
• Training or selling data to artificial intelligence systems or large language model operators.

pak65 does not sell, rent or trade Personal Data. We may share Personal Data in the following limited circumstances:

• Service Providers: We engage trusted third-party Data Processors — such as web hosting providers, content delivery network operators and analytics services — who process data strictly under our instruction and subject to data-processing agreements that prohibit independent use of the data.
• Legal Obligations: We may disclose Personal Data when required to do so by applicable law, court order, regulatory directive or lawful government request. We will notify you of any such disclosure where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of pak65's assets, Personal Data may be transferred to the successor entity. Users will be notified prior to any such transfer and given an opportunity to request deletion.
• Safety: Where we have a good-faith belief that disclosure is necessary to protect the vital interests of a person, we may share relevant data with law enforcement or emergency services.

pak65 does not share Personal Data with Operators referenced on the Platform. Any data relationship you have with an Operator arises exclusively from your direct registration with that Operator and is governed by their privacy policy.

pak65 uses cookies and similar technologies to support essential Platform functions and gather anonymous usage analytics. The following categories of cookies may be present on the Platform:

You may control cookie preferences through your browser settings. Most modern browsers allow you to block, delete or receive notifications when cookies are set. Note that disabling strictly necessary cookies may impair Platform functionality.

pak65 retains Personal Data only for as long as necessary to fulfil the stated purpose or comply with legal obligations. The following retention schedules apply:

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. You may also request earlier deletion under your rights in Section 11.

pak65 implements a range of technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• HTTPS / TLS encryption for all data transmitted between your browser and the Platform;
• Access controls limiting internal data access to authorised personnel with a documented business need;
• Regular security reviews and vulnerability assessments of Platform infrastructure;
• Contractual security obligations imposed on all third-party Data Processors;
• Incident response procedures for detecting, containing and notifying affected users of data breaches.

While pak65 takes data security seriously and implements reasonable measures, no internet transmission or electronic storage system is entirely secure. We cannot guarantee absolute security of data transmitted over public networks. Users are responsible for keeping their own device and browser software up to date.

Subject to applicable law, you have the following rights with respect to Personal Data that pak65 holds about you. Rights may vary depending on the applicable data protection framework in your jurisdiction.

To exercise any of the rights above, please contact pak65 using the details in Section 16. We will acknowledge your request within 5 business days and respond substantively within 30 calendar days. Complex or multiple requests may take up to 90 days — you will be notified if an extension is required.

We do not charge a fee for rights requests unless they are manifestly unfounded, repetitive or excessive, in which case a reasonable administrative fee may apply.

The pak65 Platform is intended exclusively for adults. Gambling-related content is strictly for individuals aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. Local Pakistani law may impose stricter requirements — the higher applicable standard governs.

pak65 does not knowingly collect Personal Data from individuals under the age of 18. If we become aware that we have inadvertently collected data from a minor, we will delete that data promptly and without undue delay.

Parents and guardians who believe their child has provided Personal Data to pak65 are encouraged to contact us immediately using the details in Section 16 so that we can take appropriate corrective action.

The Platform is accessible to users throughout Pakistan, including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. Infrastructure supporting the Platform may be hosted in data centres outside Pakistan.

Where Personal Data is transferred to servers or processors located in other countries, pak65 ensures that appropriate safeguards are in place, which may include:

• Data processing agreements incorporating standard contractual clauses;
• Transfers to jurisdictions that offer an adequate level of data protection;
• Binding corporate rules where applicable to group processing activities.

Pakistan does not currently have a comprehensive data protection law equivalent to the EU GDPR. Where users are located in Pakistan, pak65 applies its own internal data protection standards as set out in this Policy, designed to be consistent with internationally recognised best practices.

The Platform may reference or describe third-party services — including Operators, payment providers and game studios — for informational and educational purposes. Such references do not constitute endorsements, partnerships or affiliations.

pak65 is not responsible for the privacy practices of any third-party website, service or platform. When you navigate from pak65 to a third-party Operator's website, you are subject to that Operator's privacy policy from the moment you land on their platform. We strongly encourage you to read the privacy policy of any service before providing personal information.

Third-party services referenced on pak65 that may process user data independently include:

• Analytics providers: Anonymous usage analytics may be processed by a third-party analytics service under our instruction.
• Content delivery networks (CDNs): CSS frameworks, JavaScript libraries and fonts served from CDNs (e.g., Bootstrap, Google Fonts, Bootstrap Icons CDN) may log technical request data for delivery optimisation. These are standard industry tools used for page performance.
• Hosting infrastructure: The Platform's web hosting provider processes server log data as a Data Processor under our instruction.

pak65 may update this Privacy Policy periodically to reflect changes in our data practices, applicable law or Platform functionality. The most current version will always be published at https://pak65.cam/privacy-policy with an updated "Last Updated" date at the top of the page.

Where changes are material — for example, a new category of data being collected, a new purpose for processing, or a change in how data is shared — pak65 will provide prominent notice on the Platform for a minimum of 30 days prior to the changes taking effect.

Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised terms, you must cease using the Platform and may request deletion of your data under Section 11.

For all privacy-related enquiries, rights requests, data breach reports or complaints regarding this Privacy Policy, please contact pak65 using the details below. All communications should be in English. Response times are as stated — actual times may vary during periods of high demand.

If you are not satisfied with our response to a data protection concern, you may have the right to escalate your complaint to a competent data protection supervisory authority in your jurisdiction.