pk91 Privacy Policy
At pk91, we take the privacy of every registered player seriously. This Privacy Policy explains in plain terms what personal data we collect, why we collect it, how it is stored and protected, and what rights you have over your information as a player based in Pakistan.
Our Privacy Principles
Six core principles guide how pk91 handles the personal data of every player across Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and beyond.
Purpose Limitation
pk91 collects personal data only for specific, clearly stated purposes — account management, identity verification, payment processing, fraud prevention, and regulatory compliance. Your data is never used beyond those stated purposes without your explicit consent.
Data Minimisation
We only collect the data that is strictly necessary for the purpose at hand. pk91 does not collect excessive personal information. If a piece of data is not required to operate your account or meet a regulatory obligation, pk91 does not ask for it.
Security by Design
All data stored by pk91 is protected by 256-bit SSL encryption in transit and AES-256 encryption at rest. Access to personal data is restricted to authorised pk91 staff on a strict need-to-know basis. Payment credentials are never stored on pk91 servers.
Your Rights, Always
pk91 recognises and upholds your data rights: the right to access, correct, delete, or restrict processing of your personal data. Requests are handled within 30 calendar days and can be submitted at any time by contacting pk91 support.
No Data Selling
pk91 does not sell, rent, or trade your personal data to third-party marketers under any circumstances. Data shared with third parties is limited to what is necessary for payment processing, KYC verification, and licensing compliance — and is covered by strict data processing agreements.
Transparency & Updates
When this Privacy Policy is updated in any material way, pk91 notifies registered players via email or in-platform notification before the changes take effect. The current version is always available on the pk91 website. Continued use of pk91 after notification constitutes acceptance.
Table of Contents
1 Introduction & Scope
This Privacy Policy ("Policy") is issued by pk91 ("pk91", "we", "us", "our") and applies to all personal data collected, processed, stored, or transmitted in connection with your use of the pk91 online gaming platform accessible at pk91.club, including all associated gaming products, payment services, promotional communications, customer support interactions, and account management functions.
By registering a pk91 account, depositing funds, placing a bet or wager, or otherwise using any feature of the pk91 platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.
This Policy should be read alongside pk91's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and another document, this Policy shall govern in respect of personal data matters.
This Policy applies to all players registered on pk91, regardless of their location within Pakistan — including players from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Peshawar, Multan, Quetta, and all other cities and regions.
2 Data Controller
For the purposes of applicable data protection law, pk91 is the data controller in respect of personal data collected from players using the pk91 platform. As data controller, pk91 determines the purposes for which and the means by which your personal data is processed.
pk91 operates under an internationally recognised gaming licence. Our data protection practices are designed to meet the standards required under our licensing obligations and applicable privacy regulations. If you have any questions about how pk91 acts as data controller in relation to your personal data, you may contact our support team at the details provided in Section 14 of this Policy.
3 Data We Collect
3.1 Registration Data
When you create a pk91 account, we collect the personal information you provide during the registration process, including your full legal name, date of birth, gender, residential address, mobile phone number, and email address. This information is required to create and administer your account.
3.2 Identity Verification (KYC) Data
As part of our Know Your Customer (KYC) obligations under our gaming licence, we may collect copies of identity documents including your Computerised National Identity Card (CNIC), proof of address documents, and proof of payment method ownership. These documents are processed solely for the purpose of verifying your identity and are handled with the highest level of security.
3.3 Financial & Transaction Data
We collect transaction data relating to deposits, withdrawals, and gaming activity on your pk91 account. This includes deposit amounts, withdrawal requests, transaction timestamps, and the payment methods used (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank). We do not store full payment account credentials on our servers.
3.4 Gaming & Betting Activity Data
We collect records of your gaming and betting activity on the pk91 platform, including games played, bets placed, wager amounts, outcomes, session durations, and responsible gaming tool usage. This data is used for account management, dispute resolution, fraud detection, and regulatory reporting.
3.5 Technical & Device Data
When you access pk91, we automatically collect certain technical data about your device and connection, including your IP address, browser type and version, operating system, device identifiers, referring URLs, and pages visited on the pk91 platform. This data is used for security monitoring, fraud prevention, and platform optimisation.
3.6 Communications Data
We retain records of communications between you and pk91 support staff, including live chat transcripts, email correspondence, and support ticket histories. These records are maintained for quality assurance, dispute resolution, and regulatory compliance purposes.
The table below summarises the main categories of personal data collected by pk91:
| Data Category | Examples | Primary Purpose |
|---|---|---|
| Registration Data | Name, DOB, mobile number, email, address | Account creation & management |
| KYC / Identity Data | CNIC copy, address proof, payment proof | Identity verification & regulatory compliance |
| Financial Data | Deposit/withdrawal amounts, payment method used | Payment processing & fraud prevention |
| Gaming Activity | Bets placed, games played, session length | Account records, dispute resolution, RG monitoring |
| Technical Data | IP address, browser, device type | Security, fraud detection, platform performance |
| Communications | Support chat logs, emails | Quality assurance & dispute resolution |
4 How We Use Your Data
pk91 uses the personal data we collect for the following purposes:
- Account Registration & Management: To create, verify, maintain, and administer your pk91 player account, including processing login requests and account settings changes.
- Identity Verification: To verify your identity and age in compliance with our licensing obligations and to prevent underage gambling. pk91 requires all players to be 21 years of age or older.
- Payment Processing: To process deposits and withdrawal requests via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and any other supported payment methods.
- Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other forms of platform abuse.
- Regulatory Compliance: To meet our obligations under applicable gaming licence conditions, anti-money laundering (AML) requirements, and data protection regulations.
- Customer Support: To respond to your queries, process complaints, and resolve disputes in a timely and effective manner.
- Responsible Gaming: To monitor gaming patterns and, where appropriate, reach out proactively to players who may be displaying signs of problem gambling behaviour.
- Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may withdraw consent at any time.
- Platform Improvement: To analyse aggregate usage data and improve the pk91 platform, including game performance, payment flow, and user interface enhancements.
pk91 does not use your personal data to make fully automated decisions that produce legal or similarly significant effects on you without human review. Where automated processes are used in fraud detection, a human reviewer is involved before any account action is taken.
5 Legal Basis for Processing
pk91 processes your personal data on one or more of the following legal bases, depending on the purpose of the processing:
- Contractual Necessity: Processing required to perform the contract between you and pk91, including account management, payment processing, and game delivery.
- Legal Obligation: Processing required to comply with our gaming licence conditions, AML regulations, and other applicable legal requirements.
- Legitimate Interests: Processing carried out in pursuit of pk91's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your data protection rights.
- Consent: Processing based on your freely given, specific, and informed consent — in particular, the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
6 Data Sharing & Third Parties
6.1 Who We Share Data With
pk91 does not sell, rent, or trade your personal data to third-party marketers. We share your personal data only with the following categories of third parties, and only to the extent necessary for the stated purpose:
- Payment Processors: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank receive transaction data necessary to process your deposits and withdrawals in PKR.
- KYC & Identity Verification Providers: Third-party identity verification services that assist pk91 in verifying player identity and age as required by our licensing obligations.
- Gaming Software Providers: Third-party game studios and RNG certification bodies that supply games available on the pk91 platform may receive anonymised or pseudonymised gaming session data for performance and auditing purposes.
- Fraud Prevention Services: Specialist fraud detection and anti-money laundering service providers who assist pk91 in identifying and preventing fraudulent activity on the platform.
- Regulatory & Licensing Authorities: Our gaming licensing authority and, where legally required, law enforcement bodies or financial intelligence units may receive player data in connection with regulatory reporting or lawful investigations.
- IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers that support the operation of the pk91 platform under strict data processing agreements.
6.2 Third-Party Data Processing Agreements
All third parties with whom pk91 shares personal data are required to enter into data processing agreements that obligate them to process your data only in accordance with pk91's instructions, to implement appropriate technical and organisational security measures, and to refrain from using your data for their own purposes.
pk91 has no control over the privacy practices of third-party payment processors such as JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank in respect of their own data processing activities. We recommend reviewing the privacy policies of these services directly.
7 Cookies & Tracking
pk91 uses cookies and similar tracking technologies on the pk91 platform to enable essential platform functionality, maintain your login session, remember your preferences, and analyse platform usage patterns.
7.1 Types of Cookies Used
- Essential Cookies: Required for the pk91 platform to function correctly, including maintaining your logged-in session and enabling the game loading process. These cookies cannot be disabled without affecting platform functionality.
- Analytical Cookies: Used to collect aggregated, anonymised data about how players use the pk91 platform, which pages are visited most frequently, and where technical errors occur. This data is used to improve the pk91 experience.
- Security Cookies: Used to detect and prevent fraudulent access to player accounts, including session hijacking and cross-site request forgery attempts.
- Preference Cookies: Used to remember your language preferences, display settings, and other personalisation choices so you do not need to re-enter them on each visit.
7.2 Managing Cookies
You may control cookie settings through your browser's privacy settings. Disabling non-essential cookies will not prevent you from accessing pk91, but may affect certain platform features. Note that disabling essential cookies may prevent you from logging in or completing payment transactions.
8 Data Retention
pk91 retains your personal data for as long as your account remains active and for such period thereafter as is required by our licensing obligations, applicable law, or legitimate business necessity.
In practice, this means that following the closure of your pk91 account — whether initiated by you or by pk91 — your personal data, transaction records, and KYC documentation are retained for a minimum period of five (5) years. This retention period reflects our obligations under anti-money laundering regulations and gaming licence conditions, which require us to be able to respond to regulatory enquiries relating to historical account activity.
Communications data, including live chat transcripts and email correspondence with pk91 support, is retained for a period of three (3) years from the date of each communication. Technical and device data logs are retained for twelve (12) months.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of your identity from the retained data.
9 Data Security
pk91 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and pk91 servers.
- AES-256 encryption for personal data stored at rest on pk91 infrastructure.
- Role-based access controls ensuring that only authorised pk91 personnel with a verified need to access personal data are able to do so.
- Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
- Comprehensive employee training on data protection obligations and security practices.
- Incident response procedures enabling rapid detection, containment, and notification in the event of a personal data breach.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pk91 will notify you and the relevant regulatory authority without undue delay in accordance with applicable notification requirements.
While pk91 takes all reasonable technical precautions, no method of internet transmission or electronic storage is 100% secure. You play an important role in protecting your account by keeping your login credentials confidential and reporting any suspected unauthorised access promptly.
10 Your Rights
Subject to applicable law and our licensing obligations, you have the following rights in respect of your personal data held by pk91:
- Right of Access: You may request a copy of the personal data pk91 holds about you at any time. We will provide this within 30 calendar days of receiving a valid request.
- Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account information directly through your account settings, or contact support for assistance.
- Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis applies. Note that this right is subject to our legal retention obligations — data required to be retained under anti-money laundering law or licensing conditions cannot be deleted on request.
- Right to Restriction of Processing: You may request that pk91 restrict the processing of your personal data in certain circumstances, for example while a dispute regarding data accuracy is being resolved.
- Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
- Right to Object: You may object to the processing of your personal data where pk91 relies on legitimate interests as the legal basis for processing. pk91 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests.
- Right to Withdraw Consent: Where processing is based on your consent — in particular, marketing communications — you may withdraw consent at any time by contacting pk91 support or updating your communication preferences in your account settings.
To exercise any of the rights listed above, please contact pk91 support at [email protected] with the subject line "Data Rights Request". We will acknowledge receipt within 48 hours and respond substantively within 30 calendar days.
11 Children & Minors
pk91 is strictly an adults-only platform. The pk91 platform is not intended for, directed at, or designed for use by individuals under the age of 21. pk91 does not knowingly collect personal data from individuals under 21 years of age.
If pk91 discovers or is notified that an account has been registered by a person under the age of 21, that account will be immediately suspended, all associated transactions will be reviewed, and the account will be permanently closed. Any deposits made by an underage player will be returned to the originating payment method after verification, and any winnings will be forfeited in their entirety.
If you are a parent or guardian and believe that a minor in your care has registered on pk91, please contact us immediately at [email protected]. We will investigate and act without delay.
12 Cross-Border Data Transfers
pk91 may transfer your personal data to third-party service providers located outside Pakistan, including cloud infrastructure providers and game software studios, where this is necessary to operate the pk91 platform and deliver the services described in these Terms.
Where personal data is transferred internationally, pk91 ensures that appropriate safeguards are in place, including contractual protections, to maintain a standard of data protection equivalent to that described in this Policy. Such safeguards may include standard contractual clauses or equivalent legally recognised transfer mechanisms.
By using pk91, you acknowledge and consent to the transfer of your personal data to service providers in other jurisdictions as described in this section, subject to the protections described herein.
13 Amendments to This Policy
pk91 reserves the right to update or amend this Privacy Policy at any time. Where an amendment is material — meaning it significantly affects how we collect, use, or share your personal data — pk91 will notify registered players via email to the address registered on their account, or via an in-platform notification, no less than 14 days before the change takes effect.
Non-material amendments, such as clarifications of existing language or corrections of typographical errors, may be made without advance notice. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision.
Continued use of the pk91 platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. If you do not accept a material amendment, you should cease using pk91 and contact support to arrange account closure and withdrawal of any remaining balance.
14 Contact & Complaints
If you have any questions, concerns, or complaints about this Privacy Policy or about how pk91 processes your personal data, please contact our support team using the details below. All privacy-related queries are treated with priority.
- Email: [email protected]
- Subject Line: Privacy Enquiry / Data Rights Request
- Response Time: Acknowledgement within 48 hours; substantive response within 30 calendar days
- Support Hours: 24/7, including all Pakistani public holidays
If you are not satisfied with pk91's response to a privacy complaint, you have the right to escalate the matter to our licensing authority's dispute resolution mechanism, details of which are available on the pk91 Terms & Conditions page.
For concerns specifically relating to responsible gaming data or self-exclusion records, please also refer to the pk91 Responsible Gaming page.
Your Data is Safe. Your Game Awaits.
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