pk939 Privacy Policy —
How We Protect Your Personal Data

This Privacy Policy (hereinafter "Policy") is published by pk939 (the "Platform," "Company," "We," "Us," or "Our"), the operator of the online gaming and sports betting platform accessible at pk939.bio and all associated digital interfaces. This Policy describes how pk939 collects, processes, stores, shares, and protects the personal data of individuals (hereinafter "Players," "Users," "Members," or "You") who access or use the pk939 platform in any capacity.

pk939 acts as the Data Controller with respect to the personal data of its members. As Data Controller, pk939 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out in accordance with applicable data protection principles and the data protection obligations imposed by our international gaming licence.

This Policy should be read in conjunction with the pk939 Terms & Conditions and Responsible Gaming Policy, which are incorporated into our broader member agreement framework. By creating a pk939 account or using the platform, you acknowledge that you have read and understood this Privacy Policy in full.

pk939 collects personal data through a number of channels: directly from you when you register, deposit, play, or contact us; automatically when you use the platform through cookies, device identifiers, and usage logs; and from third-party verification providers during the KYC process. The categories of personal data we collect are described in the table below:

Special Categories of Data: pk939 does not intentionally collect any special categories of sensitive personal data, including but not limited to health data, religious beliefs, political opinions, biometric data, or sexual orientation. If you voluntarily disclose such information to our support team in the course of a conversation, it will not be stored beyond the duration of that specific support interaction unless legally required.

pk939 processes your personal data only where a valid legal basis for processing exists. The legal bases we rely upon, and the corresponding processing purposes, are set out below:

• Performance of Contract: Processing necessary to create and manage your pk939 account, process deposits and withdrawals, settle bets and wagers, award and administer bonuses, and deliver all contracted gaming services. This basis applies to the majority of data processing activities on the pk939 platform.
• Legal Obligation: Processing required to comply with our international gaming licence conditions, including KYC identity verification, anti-money laundering (AML) monitoring, responsible gaming obligations, and regulatory reporting duties. This processing cannot be opted out of — it is a legal prerequisite for operating a licensed gaming platform.
• Legitimate Interests: Processing carried out for pk939's legitimate business interests, including fraud prevention, platform security monitoring, abuse detection, product improvement based on aggregated usage analytics, and network and information security. We apply a balancing test to ensure our legitimate interests do not unfairly override your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications including promotional emails and SMS messages about pk939 offers, new games, and events. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

pk939 uses the personal data described in Section 2 for the following specific purposes. We do not use your data for any purpose not listed below without first obtaining your explicit consent or establishing an additional valid legal basis:

• Account creation and management: Registering your pk939 account, verifying your identity and age (21+), maintaining your account records, and enabling you to use all platform features.
• Processing transactions: Handling deposits, withdrawals, and refunds via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, USDT, and BTC. Verifying that payment instruments are registered in your name.
• Game operation and bet settlement: Logging and settling all bets, wagers, casino game sessions, and sportsbook markets — including PSL cricket, ICC events, UFC, and all other markets — accurately and transparently.
• Bonus and promotion administration: Crediting, tracking, and expiring bonus balances; verifying compliance with wagering requirements; and preventing duplicate bonus claims across the same household or device.
• Regulatory compliance: Fulfilling KYC obligations, conducting AML transaction monitoring, maintaining records required under our gaming licence, and responding to regulatory authority requests.
• Fraud prevention and security: Detecting and preventing account fraud, bonus abuse, payment fraud, money laundering, collusion, and other prohibited conduct described in our Terms & Conditions.
• Responsible gaming: Monitoring gaming behaviour for problem gambling indicators; enforcing deposit limits, self-exclusion orders, and cool-off periods; and maintaining records of responsible gaming interactions.
• Customer support: Responding to account, payment, bonus, and gaming queries submitted via live chat, email, or support ticket on the pk939 platform.
• Marketing communications (with consent): Sending promotional emails and SMS messages about pk939 offers, new games, VIP programme updates, and platform news to members who have opted in to marketing communications.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the pk939 platform, user experience, game selection, and payment processes.

pk939 uses cookies and similar tracking technologies (including local storage, session storage, and web beacons) to operate the platform, enhance your experience, and gather analytics data. Cookies are small text files placed on your device by your browser when you visit pk939.bio. They do not contain executable code and cannot access your device's files or data beyond the cookie itself.

• Strictly necessary cookies: Essential for the platform to function. These include session management cookies that keep you logged in to your pk939 account, security tokens, and load-balancing cookies. These cookies cannot be disabled without preventing core platform functionality.
• Functional cookies: Remember your preferences, such as language settings, display preferences, and game history within a session. Disabling these cookies may reduce your platform experience but will not prevent access.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the pk939 platform — pages visited, features used, and session duration. This data helps pk939 understand usage patterns and improve the platform.
• Marketing cookies: Used to deliver relevant promotional content and to track the effectiveness of pk939's marketing campaigns. These cookies are only placed with your consent and can be withdrawn at any time via your browser settings or account preferences.

You can control cookie placement through your browser settings. However, please note that disabling strictly necessary cookies will prevent you from accessing your pk939 account. For detailed instructions on managing cookies in your specific browser, please consult your browser's help documentation.

pk939 does not sell, rent, or commercially transfer your personal data to third parties. We share personal data only in the limited circumstances described below, and only where necessary for the stated purpose:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency processing partners receive transaction data necessary to process your deposits and withdrawals. These providers are bound by their own regulatory obligations and data protection requirements.
• KYC and identity verification providers: Specialist identity verification and AML screening services receive your identity documents and personal identifiers for the purpose of completing regulatory verification requirements. All such providers are contractually bound to process data solely for the specified verification purpose.
• Gaming software providers: Game content providers whose titles are hosted on pk939 may receive limited session data (game type, stakes, outcomes) necessary to operate and certify their games. They do not receive your name, CNIC, or payment information.
• Regulatory and law enforcement authorities: pk939 is required to disclose personal data and transaction records to our gaming licence regulatory authority, financial intelligence units, and law enforcement agencies where legally compelled to do so. Such disclosures are made only to the extent required by law.
• Professional advisers: Legal counsel, accountants, auditors, and insurance providers may access personal data on a strictly need-to-know basis in connection with their professional engagements with pk939.
• Business transfers: In the event that pk939 undergoes a merger, acquisition, or sale of assets, personal data of members may be transferred to the successor entity, subject to the acquiring entity providing equivalent data protection standards. You will be notified of any such transfer.

pk939 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law and our gaming licence conditions. The retention periods applicable to the main categories of personal data we hold are as follows:

• Account and identity data: Retained for the duration of your active pk939 account plus a minimum of five (5) years following account closure, in compliance with AML and gaming licence record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with financial record-keeping obligations under our gaming licence.
• KYC verification documents: Retained for the duration of your account plus five (5) years following account closure. Originals of verification documents are stored in encrypted form.
• Gaming and betting history: Retained for five (5) years from the date of each gaming session or wager, to support dispute resolution, regulatory reporting, and responsible gaming monitoring.
• Customer support communications: Retained for two (2) years from the date of the interaction, or longer where the communication relates to an ongoing dispute or regulatory matter.
• Marketing consent records: Retained for the duration of your account. If you withdraw marketing consent, a record of the withdrawal is retained to ensure future marketing is suppressed.
• Technical and device data (logs): Retained for up to twelve (12) months in rotating log files, used for security monitoring and fraud detection purposes.

Upon expiry of the applicable retention period, pk939 will securely delete or anonymise the relevant personal data. Where full deletion is not immediately possible due to backup system architecture, the data will be isolated from active processing and securely deleted at the next scheduled backup cycle.

Subject to applicable law and the conditions of our gaming licence, you have the following rights with respect to your personal data held by pk939. To exercise any of these rights, please submit a written request to [email protected] from the email address registered to your pk939 account. We will respond within thirty (30) calendar days of receipt of a verified request.

• Right of Access: You have the right to request a copy of all personal data pk939 holds about you, together with information about how it is used, who it has been shared with, and how long it will be retained. This is sometimes called a Subject Access Request (SAR).
• Right to Rectification: If any personal data pk939 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Many details — such as your contact email and city of residence — can be updated directly in your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request that pk939 delete your personal data. This right is not absolute — where we are legally required to retain data under AML or gaming licence obligations, we will retain it for the mandatory period even following an erasure request. We will notify you of any limitations on erasure and the legal basis for retention.
• Right to Restriction of Processing: You may request that pk939 restrict the processing of your personal data while a dispute is being resolved or while you exercise another data rights request. During restriction, we will continue to store your data but will not process it beyond what is strictly necessary.
• Right to Data Portability: You may request a copy of the personal data you provided to pk939 in a structured, machine-readable format (such as JSON or CSV), which you may then transfer to another service provider.
• Right to Object: You have the right to object to pk939's processing of your personal data where that processing is based on Legitimate Interests. You may also object unconditionally to the use of your personal data for direct marketing purposes at any time.
• Rights Related to Automated Decision-Making: Where pk939 uses automated tools to make decisions that significantly affect you — such as automated fraud detection resulting in account restriction — you have the right to request human review of that decision.

pk939 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures are reviewed and updated regularly in line with evolving security standards and threats.

• Encryption at rest: All personal data stored in pk939 databases is encrypted using AES-256 encryption. This means that even in the unlikely event of unauthorised database access, your personal data cannot be read without the encryption keys.
• Encryption in transit: All data transmitted between your device and pk939 servers — including login credentials, payment details, and personal information — is protected by 256-bit SSL/TLS encryption. Always verify the padlock icon in your browser address bar when accessing pk939.bio.
• Access controls: Access to personal data within pk939 is restricted to employees and contractors who require it to perform their specific job functions. Access is granted on a least-privilege basis and is subject to regular audit and review.
• Two-factor authentication: pk939 offers two-factor authentication (2FA) for player accounts, adding an additional layer of protection against unauthorised access. We strongly recommend that all pk939 members enable 2FA in their account security settings.
• Intrusion detection and monitoring: pk939 operates 24/7 security monitoring systems that detect and respond to unusual access patterns, potential intrusions, and suspicious activity in real time.
• Data breach response: pk939 maintains a documented data breach response plan. In the event of a personal data breach, we will notify affected members and the relevant regulatory authority within the timeframes required by our licensing obligations, and will take immediate steps to contain and remediate the breach.

While pk939 takes all reasonable technical and organisational precautions to protect your personal data, no data transmission over the internet can be guaranteed to be 100% secure. You are responsible for maintaining the security of your own pk939 account credentials and for ensuring that you access the platform from trusted, secure devices and networks.

The pk939 platform is strictly intended for adults aged 21 years and above. pk939 does not knowingly collect, process, or retain the personal data of individuals under the age of 21. If you are under 21 years of age, you must not create a pk939 account, access the platform, or provide any personal data to pk939 in any form.

If pk939 discovers or has reasonable grounds to believe that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete the relevant personal data to the extent permitted by law, and notify the relevant regulatory authority where required. Any funds held in a confirmed underage account will be returned to the payment source.

Parents and guardians who believe their child may have accessed pk939 or created an account using false age information are encouraged to contact us immediately at [email protected] so that we can take prompt action to close the account and delete the associated data.

11.1 Policy Amendments. pk939 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or gaming licence requirements. The most current version of this Policy will always be published at pk939.bio/privacy-policy. The date of the most recent revision is displayed at the top of this document. Your continued use of the pk939 platform following the publication of any revised Policy constitutes your acknowledgement of the revised terms. Where changes are material, pk939 will make reasonable efforts to notify registered members in advance via the contact details held on their account.

11.2 Contact for Privacy Matters. For all privacy-related enquiries, Subject Access Requests, data rights requests, complaints, or concerns regarding pk939's processing of your personal data, please contact us using the following details:

11.3 Complaints. If you are not satisfied with how pk939 has handled a privacy concern or data rights request, you have the right to escalate your complaint to the data protection supervisory authority designated under our gaming licence jurisdiction. pk939 will cooperate fully with any supervisory authority investigation and will implement any required corrective actions promptly.