pakrum Privacy Policy

This Privacy Policy ("Policy") sets out how pakrum ("pakrum", "we", "us", "the Platform") collects, processes, stores, and protects personal data belonging to users ("Player", "User", "you") who access or use the pakrum platform at pakrum.app.

pakrum is committed to handling your personal data with the utmost care and in full compliance with applicable data protection laws. We recognise that Pakistani players entrust us with sensitive personal information — including CNIC details, mobile numbers, and payment records — and we take that responsibility seriously.

This Policy applies to all data collected through the pakrum website, any mobile-optimised version of the platform, customer support communications, marketing channels (where applicable), and any other service offered under the pakrum brand. It is incorporated by reference into our Terms & Conditions.

pakrum collects personal data across several categories depending on how you interact with the platform. The following table summarises what we collect and from which source:

We do not collect data that we do not need. Where data collection is optional, we will clearly indicate this at the point of collection. pakrum does not collect biometric data beyond what is required for CNIC-based age and identity verification.

pakrum uses your personal data strictly for the purposes listed below. We do not use your data for any purpose that has not been disclosed in this Policy or separately communicated to you:

• Account Registration & Management: To create, maintain, and administer your pakrum account, verify your identity, and ensure only one account exists per player.
• Age Verification (21+): To verify that you meet the minimum age requirement of 21 years before permitting real-money play. CNIC data is used solely for this purpose and is not retained beyond the regulatory minimum period.
• Payment Processing: To process deposits and withdrawals in PKR via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, Raast, 1LINK, USDT TRC20, and Retail Cash channels.
• Fraud Prevention & AML Compliance: To detect, investigate, and prevent fraudulent activity, money laundering, and other financial crime. Transaction monitoring is a legal obligation for any licensed gaming operator.
• Customer Support: To respond to your queries, resolve disputes, and process complaints in a timely manner.
• Responsible Gaming: To monitor gaming behaviour patterns, enforce deposit and loss limits you have set, and intervene where patterns suggest problematic gambling behaviour.
• Platform Improvement: To analyse aggregate usage data (anonymised where possible) to improve the pakrum platform, fix bugs, and optimise game performance.
• Legal & Regulatory Obligations: To comply with applicable laws, respond to lawful requests from Pakistani regulatory authorities, law enforcement agencies, and courts of competent jurisdiction.
• Communications: To send you transactional messages (deposit confirmations, withdrawal notifications, security alerts) and, where you have opted in, promotional communications about pakrum offers.

pakrum processes your personal data on one or more of the following legal grounds, depending on the specific processing activity:

• Contractual Necessity: Processing that is necessary to perform the contract between you and pakrum — including account creation, payment processing, and game delivery — is carried out on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with our legal obligations — including KYC/AML checks, age verification, tax reporting, and regulatory reporting — is carried out on the basis of legal obligation.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and platform improvement is based on pakrum's legitimate interests, provided those interests are not overridden by your rights and interests.
• Consent: Where you have expressly consented to a specific processing activity — such as receiving promotional emails or SMS — that processing is based on your consent. You may withdraw consent at any time.

pakrum does not engage in automated decision-making that produces legal or similarly significant effects on players without human oversight. Where automated tools assist in fraud detection or responsible gaming monitoring, all consequential decisions are reviewed by a qualified compliance officer before action is taken.

pakrum does not sell, rent, or trade your personal data to third parties for commercial purposes. Your data is shared only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment Processors: Your financial data is shared with payment service providers (such as JazzCash, EasyPaisa, and partner banks) solely to execute the deposit or withdrawal transaction you have requested. These providers are contractually bound to process your data only for that purpose.
• Identity Verification Partners: CNIC and identity document data is shared with certified KYC verification service providers to confirm your age and identity. All such providers are bound by strict data processing agreements.
• Game Software Providers: Certain gameplay data (such as session identifiers) may be shared with our casino game software providers for technical purposes — specifically, to deliver the games and maintain game integrity. These providers do not receive personally identifiable data beyond what is technically required.
• Regulatory & Law Enforcement Authorities: pakrum will disclose personal data to regulatory authorities, law enforcement agencies, or courts when required by applicable law or a valid legal order. We will notify you of any such disclosure where we are legally permitted to do so.
• Fraud Prevention Networks: To protect the platform from fraud and abuse, certain transaction and behavioural data may be shared with industry-standard fraud prevention databases. This processing is based on legitimate interests.

pakrum uses cookies and similar tracking technologies to operate the platform, remember your preferences, and understand how players use the site. The following categories of cookies are used:

You can manage your cookie preferences through your browser settings at any time. Note that disabling strictly necessary cookies will prevent the platform from functioning correctly and may prevent you from accessing your pakrum account.

pakrum retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention schedule applies:

• Account Data (name, contact details, CNIC): Retained for the duration of your active account plus a minimum of five (5) years after account closure, as required by anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with financial record-keeping obligations.
• Gaming History: Retained for a minimum of three (3) years from the date of each session, for dispute resolution and responsible gaming review purposes.
• KYC Documents (CNIC scans, passport copies): Retained for the period required by applicable AML and KYC regulations — typically five (5) years post account closure. Securely destroyed thereafter.
• Support Communications: Retained for three (3) years from the date of the last communication, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for as long as you remain opted in, plus two (2) years after you withdraw consent, for compliance evidence purposes.

When data is no longer required to be retained, it is securely deleted or anonymised so that it can no longer be associated with you as an individual. Anonymised aggregate data may be retained indefinitely for statistical analysis.

As a pakrum player, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with your registered username or mobile number and a clear description of your request:

• Right of Access: You have the right to request a copy of all personal data pakrum holds about you. We will respond to verified access requests within 30 days.
• 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. Identity changes (e.g. legal name change) require supporting documentation.
• Right to Erasure ("Right to be Forgotten"): You may request that we delete your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent (and no other legal basis applies), or where you object to processing based on legitimate interests and your interests override ours. Note that this right is subject to our legal retention obligations — we cannot erase data we are legally required to retain.
• Right to Restriction: You may request that we restrict processing of your data in certain circumstances, for example while the accuracy of data is being contested or while an objection is being assessed.
• Right to Data Portability: Where processing is based on your consent or a contract, and is carried out by automated means, you have the right to receive a structured, machine-readable copy of your personal data.
• Right to Object: You have the right to object to processing based on legitimate interests. We will cease that processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

pakrum implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. Our security framework includes:

• Transport Layer Security: All data exchanged between your browser or device and the pakrum platform is encrypted using TLS 1.2 or higher, with 256-bit AES encryption.
• Data-at-Rest Encryption: Sensitive personal data stored in pakrum's databases — including CNIC numbers and financial account details — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to systems containing personal data is restricted on a strict need-to-know basis. All staff with data access are subject to confidentiality obligations and undergo regular data protection training.
• Intrusion Detection & Monitoring: pakrum's infrastructure is monitored 24/7 for suspicious activity, unauthorised access attempts, and anomalous data access patterns.
• Penetration Testing: Regular independent security audits and penetration tests are conducted to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a confirmed data breach that poses a risk to your rights and freedoms, pakrum will notify affected players and relevant authorities within the timeframes required by applicable data protection law.

pakrum operates an absolute minimum age requirement of 21 years. The platform is not intended for, and does not knowingly collect personal data from, any individual under the age of 21. This requirement is enforced through mandatory CNIC-based age verification before any real-money activity is permitted on the platform.

Where pakrum discovers that personal data has been collected from a person under 21 — whether through fraudulent document submission or any other means — that data will be permanently deleted from all systems as soon as the minor status is confirmed, and the account will be terminated. No winnings or bonuses associated with the account will be paid out.

Parents and guardians of children who may have accessed the internet using shared devices are encouraged to use parental control software to restrict access to gambling platforms. pakrum supports the use of such tools as part of its broader responsible gaming commitment.

pakrum's primary operations and data storage infrastructure is designed to keep Pakistani player data within secure, regulated environments. In certain cases, it may be technically necessary to transfer personal data to servers or third-party service providers located outside Pakistan — for example, to cloud infrastructure providers or game software vendors operating internationally.

Where such transfers occur, pakrum ensures that appropriate safeguards are in place, including:

• Data processing agreements with all third-party processors that include binding obligations regarding data protection standards equivalent to those described in this Policy.
• Transfers only to jurisdictions or processors that provide an adequate level of data protection as assessed by pakrum's compliance team.
• No transfer of Pakistani player CNIC data to any third country except where strictly required for identity verification purposes and subject to the safeguards described above.

If you have questions about specific international transfers involving your personal data, please contact [email protected] and we will provide details relevant to your account.

pakrum reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will notify registered players by email at the address associated with their account and/or display a prominent notice on the pakrum platform prior to the changes taking effect.

The "Last Reviewed" date displayed at the top of this Policy will be updated with each revision. We encourage you to review this Policy periodically so that you remain informed about how your personal data is being handled. The most current version of this Policy is always available at pakrum.app/privacy-policy.

Your continued use of the pakrum platform following the effective date of any amendment to this Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must stop using the platform and request account closure by contacting [email protected].

If you have any questions, concerns, or requests relating to this Privacy Policy or pakrum's data protection practices, please contact our dedicated privacy team through the following channel:

When contacting us about a data rights request, please include:

• Your full name as registered on your pakrum account
• Your registered mobile number (do not include your password or PIN)
• A clear description of your request (access, rectification, erasure, etc.)
• Any relevant supporting documentation where applicable

pakrum aims to acknowledge all privacy-related enquiries within five (5) business days. Response times may be slightly extended during Pakistani national holidays including Eid ul-Fitr, Eid ul-Adha, Pakistan Independence Day (14 August), and other gazetted public holidays. We appreciate your patience during these periods.