Privacy Policy — pak93

1 Introduction

This Privacy Policy ("Policy") is published by pak93 ("pak93", "we", "us" or "our"), the operator of the website at pak93.cam ("the Site"). pak93 is an English-language information and educational guide platform designed for Pakistani users interested in online sports betting and casino gaming.

This Policy describes: (a) what personal data we may collect from visitors to the Site; (b) how and why that data is collected and processed; (c) with whom, if anyone, data may be shared; (d) how long data is retained; (e) the security measures we apply; and (f) the rights you hold as a data subject.

By using the Site, you acknowledge that you have read and understood this Policy. If you do not agree with our data practices as described herein, you should discontinue use of the Site. For any questions, please see Section 15 (Contact Us).

2 Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including names, email addresses, IP addresses and usage identifiers.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, transmission and deletion.
• "Data Controller" means pak93, the entity that determines the purposes and means of processing Personal Data collected via the Site.
• "Data Subject" means any living individual whose Personal Data is processed by pak93 — in practice, users of the Site.
• "Third Party" means any person or entity other than the Data Subject and pak93.
• "Cookies" means small text files placed on a user's device by the Site to facilitate session management, analytics or personalisation.
• "Site" means pak93.cam and all pages, content and services hosted on that domain.

3 Data We Collect

pak93 is an informational website that does not require user registration. The personal data we may collect falls into two categories:

3.1 Data You Provide Voluntarily

If you use the contact or feedback form available on the Site, you may provide the following information:

• Your name or preferred display name;
• Your email address (so we can respond to your inquiry);
• The subject and content of your message.

Providing this information is entirely voluntary. You are not required to submit a contact form to access any Content on the Site.

3.2 Data Collected Automatically

When you access the Site, certain technical data may be collected automatically by our server infrastructure and any analytics tools in use. This may include:

Automatically collected data is generally aggregated and does not, on its own, identify you as an individual. Where IP addresses are logged, they are treated as personal data and handled accordingly.

4 How Data Is Collected

Personal data is collected through the following channels on the Site:

• Contact or feedback forms: Data you type and submit via any contact or inquiry form on the Site;
• Server logs: Automatically generated records maintained by web hosting infrastructure that capture technical access data such as IP addresses and request timestamps;
• Analytics tools: Where third-party analytics services are integrated (see Section 10), aggregate usage data may be collected via cookies or similar technologies deployed by those services;
• Browser-provided data: Technical metadata transmitted by your browser when loading any web page, including the Site.

pak93 does not collect data through advertising networks, social login integrations, financial transaction systems or player account databases — because the Site does not operate any of these systems.

5 Purpose & Legal Basis for Processing

pak93 processes Personal Data only for specific, legitimate purposes. The table below summarises each processing activity, its purpose and the legal basis we rely on:

pak93 does not process Personal Data for direct marketing, automated profiling or decision-making that produces legal effects on Data Subjects.

6 Data Sharing & Disclosure

pak93 does not sell, rent, trade or otherwise commercially transfer your Personal Data to any Third Party. We do not share your Personal Data with advertising networks, data brokers, affiliate marketing platforms or commercial partners for marketing purposes.

Limited and specific data sharing may occur in the following circumstances:

• Service Providers: We may engage trusted third-party service providers — such as web hosting infrastructure, content delivery networks or analytics platforms — who process data on our behalf. Any such providers are contractually bound to process data only in accordance with our instructions and in a manner consistent with this Policy;
• Legal Requirements: We may disclose Personal Data where required by law, court order or lawful authority — for example, in response to a valid demand from a competent judicial or regulatory body. We will notify affected users where legally permissible to do so;
• Protection of Rights: We may disclose data where necessary to protect the security, integrity or legal rights of pak93, or to prevent harm to a third party;
• Business Transfer: In the event of a merger, acquisition or asset transfer involving pak93, Personal Data held by us may be transferred to the successor entity, subject to the same protections as described in this Policy. Users will be notified of any such transfer via a notice on the Site.

7 Data Retention

pak93 retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law.

• Contact form inquiries: Email correspondence and associated personal data are retained for a period sufficient to resolve your inquiry and maintain a reasonable record, after which they are deleted or anonymised;
• Server logs: Access logs are typically retained for a rolling period of up to 90 days for security and debugging purposes, after which they are purged or anonymised;
• Analytics data: Aggregated and anonymised analytics data may be retained for longer periods for the purpose of understanding Site usage trends. Individually identifiable analytics records, if any, are subject to shorter retention windows;
• Legal compliance records: Where we are required by law to retain records for a specific period, we will do so in accordance with that legal obligation.

When Personal Data is no longer required and the retention period has expired, we delete or irreversibly anonymise it so that it can no longer be associated with you as an individual.

8 Data Security

pak93 implements appropriate technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include, but are not limited to:

• HTTPS encryption for all data transmitted between your browser and the Site;
• Restriction of access to Personal Data to authorised personnel only, on a need-to-know basis;
• Use of reputable, security-certified hosting infrastructure;
• Regular review of our data handling processes and security controls.

In the event of a data breach that poses a risk to the rights and freedoms of Data Subjects, pak93 will take prompt action to investigate, contain and remediate the breach, and will notify affected individuals and relevant authorities as required by applicable law.

9 Cookies & Tracking Technologies

pak93 uses cookies and similar technologies to support the operation of the Site. This section explains the types of cookies we use and how they function.

9.1 Types of Cookies

9.2 Managing Cookies

You have the right to control which non-essential cookies are set on your device. Most modern web browsers provide settings that allow you to block or delete cookies. Please be aware that disabling certain cookies may affect the functionality or appearance of the Site. Refer to your browser's help documentation for instructions on managing cookie preferences.

pak93 does not deploy cookies for cross-site advertising tracking or for building advertising profiles. We do not use third-party advertising networks that set persistent tracking cookies without disclosure.

10 Third-Party Services

The Site may use certain third-party services to support its operation. Where such services involve the processing of data, they are governed by those providers' own privacy policies and terms. pak93 exercises reasonable care in selecting trusted service providers, but is not responsible for the privacy practices of third-party platforms.

Third-party services that may be integrated with the Site include:

• Web hosting and CDN providers: Infrastructure services that host and deliver the Site's content. These providers may retain access logs that include IP addresses;
• Font and library CDNs: The Site loads publicly available web fonts and front-end libraries (e.g., Bootstrap, Google Fonts) via CDN. These requests may transmit your IP address to the CDN provider as a standard part of delivering the resource;
• Analytics tools: Where a privacy-respecting analytics service is deployed to measure Site traffic and content performance, that service's data processing is governed by its own privacy policy. We endeavour to use analytics configurations that minimise personal data collection, such as IP anonymisation.

The Site does not embed social media widgets, retargeting pixels or cross-site advertising tags that would allow third-party platforms to track your activity across the web via pak93.

11 Your Rights as a Data Subject

Depending on the applicable privacy laws governing your location, you may hold a range of rights in relation to Personal Data that pak93 holds about you. We respect and support the exercise of these rights. The principal rights are summarised below:

To exercise any of the above rights, please contact us using the details in Section 15. We will acknowledge your request promptly and aim to fulfil it within 30 calendar days. Complex or high-volume requests may require an extension of up to a further 60 days, in which case we will notify you of the extension and the reason for it.

pak93 does not charge a fee for processing rights requests unless a request is manifestly unfounded, excessive or repetitive, in which case we reserve the right to charge a reasonable administrative fee or decline to act.

12 Children's Privacy

The Site and its Content are intended exclusively for individuals who are at least 18 years of age, or the higher minimum age required by the operator's license jurisdiction or applicable law. pak93 does not knowingly collect Personal Data from individuals under 18 years of age.

If you are a parent or guardian and believe that a minor has provided Personal Data to pak93 without your consent, please contact us immediately at the email address in Section 15. We will investigate and, where verified, delete the data without undue delay.

13 Jurisdictional Considerations

pak93 is an English-language platform primarily serving users in Pakistan. Pakistan does not currently have a comprehensive data-protection statute directly comparable to the EU General Data Protection Regulation (GDPR). However, pak93 voluntarily adopts privacy principles aligned with internationally recognised best practice, including the principles of data minimisation, purpose limitation, transparency, accuracy, storage limitation and security.

Where users access the Site from jurisdictions with specific data-protection legislation — such as the EU, UK, Canada or others — pak93 endeavours to respect the rights afforded by those laws to the extent reasonably practicable for an information platform of this nature.

Data submitted via contact forms may be processed on servers located outside of Pakistan. Where such cross-border data transfer occurs, pak93 takes reasonable steps to ensure appropriate protections are in place consistent with the terms of this Policy.

14 Policy Amendments

pak93 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal requirements or operational changes to the Site. When we make material changes, the "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of the Site following publication of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you should discontinue use of the Site. Where changes are material and where reasonably practicable, we may display a notice on the Site to alert users to the update.

We encourage you to review this Policy periodically. Archived versions of prior policies are available on request by emailing us at the address provided in Section 15.

15 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy, your Personal Data, or the exercise of your data-subject rights, please contact the pak93 data team using the details below.