Privacy Policy — How 98pak Handles Your Personal Information

1Who We Are and What This Policy Covers

98pak (operating at 98pak.click) is an online gaming and sports betting platform built specifically for players in Pakistan. In this Privacy Policy, "98pak," "we," "us," and "our" refer to the platform and its operating entity. "You" and "your" refer to any person who visits, registers on, or uses any part of the 98pak platform.

This Privacy Policy explains what personal information 98pak collects from you, how and why we use it, who we share it with, how we protect it, how long we keep it, and what rights you have in relation to it. It applies to all data collected through the 98pak website, mobile-optimised interface, customer support channels, and any communications between you and 98pak.

This Policy should be read together with our Terms and Conditions and Responsible Gaming Policy. By registering an account on 98pak or using any platform feature, you confirm that you have read and understood this Privacy Policy and consent to the data practices described herein.

2What Personal Data We Collect

98pak collects only the personal data that is necessary to operate your account, process your transactions, and meet our legal obligations. The categories of data we collect are described below.

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, mobile number, email address (if provided), and chosen username and password.
• Identity verification documents: Scanned copy or photograph of your CNIC (Computerised National Identity Card) and, where required, proof of address or proof of payment method ownership.
• Payment data: Mobile wallet account numbers (Easypaisa, JazzCash, NayaPay, SadaPay), bank account details for IBFT transfers, or card details for Visa/Mastercard transactions. Card numbers are never stored on 98pak servers — they are processed through our PCI-DSS-compliant payment gateway.
• Communications: Content of messages you send to 98pak support via live chat, email, or WhatsApp, including any attachments.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type and model, operating system, browser type and version, screen resolution, and connection type.
• Usage data: Pages visited on the 98pak platform, games played, bets placed, session duration, click patterns, and navigation paths.
• Transaction data: Full record of deposits, withdrawals, bet stakes, game outcomes, and bonus claims associated with your account.
• Location data: Approximate geographic location derived from your IP address (city-level). 98pak does not collect precise GPS location data.

3How We Use Your Personal Data

98pak uses the personal data we hold about you for the following clearly defined purposes. We do not use your data for any purpose that is incompatible with what is listed below:

• Account management: Creating, maintaining, and securing your 98pak player account, including password resets and security verification.
• Transaction processing: Processing all PKR deposits and withdrawals through your chosen payment method, and maintaining accurate transaction records.
• Identity verification: Verifying your age, identity, and payment method ownership as required by our compliance obligations and the Terms and Conditions.
• Platform operation: Delivering games, sports betting markets, promotions, and all other 98pak services to your device in a functional and optimised manner.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account abuse, money laundering, and any other prohibited conduct described in our Terms.
• Responsible gaming: Monitoring your gaming patterns to identify potential problem gambling indicators and implementing responsible gaming tools where appropriate under our Responsible Gaming Policy.
• Customer support: Responding to your queries, resolving disputes, and improving our support service quality.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform news — but only where you have opted in to receive such communications. You may opt out at any time via your account settings or by contacting support.
• Platform improvement: Analysing aggregated, anonymised usage data to improve game performance, user experience, and platform reliability.
• Legal compliance: Meeting our obligations under applicable Pakistani law, responding to lawful government or regulatory requests, and maintaining records required by law.

4Legal Basis for Processing

For each use of your personal data, 98pak relies on one or more of the following legal bases:

• Contractual necessity: Processing required to deliver the services you agreed to when registering an account — account management, transaction processing, and game delivery.
• Legal obligation: Processing required to comply with applicable laws — identity verification, transaction record-keeping, and responding to lawful authority requests.
• Legitimate interests: Processing necessary for 98pak's legitimate business interests where these are not overridden by your rights — fraud prevention, platform security, and platform improvement using anonymised analytics.
• Consent: Processing based on your specific, freely given consent — marketing communications and optional personalisation features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5Who We Share Your Data With

98pak does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. We share personal data only in the following limited and clearly defined circumstances:

5.1 Service Providers

We work with trusted third-party providers who process data on our behalf to deliver the 98pak service. These include our payment processing partners (Easypaisa, JazzCash, NayaPay, SadaPay, and card processors), our game content providers, our cloud hosting infrastructure provider, and our customer support platform. All service providers are bound by data processing agreements that restrict them from using your data for any purpose other than providing their contracted service to 98pak.

5.2 Legal and Regulatory Disclosure

98pak may disclose personal data to government authorities, law enforcement agencies, financial intelligence units, or regulatory bodies where required to do so by applicable law, a valid court order, or a lawful investigation. We will inform you of any such disclosure where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of 98pak's business or assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent platform notice before your data becomes subject to a different privacy policy.

5.4 Aggregated Analytics

98pak may share aggregated, fully anonymised statistical data (for example, total bet volumes, game popularity metrics) with business partners or publish such data publicly. This data cannot be used to identify any individual player.

6Cookies and Tracking Technologies

98pak uses cookies and similar tracking technologies to operate the platform, remember your session, and understand how players use our services. This section explains what cookies we use and how you can control them.

6.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They allow the website to remember certain information about your visit — such as whether you are logged in, your language preference, or what items are in a shopping cart. On 98pak, cookies are used to keep you logged in during a gaming session and to track certain usage patterns for security and platform improvement.

6.2 Cookies We Use

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in. You cannot opt out of essential cookies while using 98pak.
• Analytics cookies: Collect anonymised data about how players navigate the platform. This helps us identify areas for improvement. You can opt out of analytics cookies via your browser settings.
• Security cookies: Help detect and prevent fraudulent activity, bot traffic, and unusual session behaviour. These are essential and cannot be disabled.
• Preference cookies: Remember your platform preferences such as display settings. These are optional and can be cleared via your browser.

6.3 Managing Cookies

Most modern browsers allow you to view, manage, and delete cookies from the browser's settings menu. Disabling essential cookies will prevent you from logging in to your 98pak account. Disabling analytics or preference cookies will not affect your ability to play games or make transactions. For specific browser instructions, refer to your browser's help documentation.

7How We Protect Your Data

98pak implements multiple layers of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction.

• Encryption at rest: All personal and financial data stored on 98pak servers is encrypted using AES-256.
• Encryption in transit: All data transmitted between your device and the 98pak platform is protected by HTTPS with TLS encryption.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff access is logged and regularly reviewed.
• Payment security: Credit and debit card transactions are processed through a PCI-DSS Level 1 compliant gateway. Card numbers are never stored on 98pak servers.
• Fraud monitoring: Automated systems monitor transaction patterns and login behaviour in real time to detect unusual activity.
• Penetration testing: 98pak conducts regular third-party security assessments of the platform infrastructure.

While we take every reasonable precaution, no online system can guarantee absolute security. If you believe your 98pak account has been compromised, change your password immediately and contact our support team.

8How Long We Keep Your Data

98pak retains personal data only for as long as necessary to fulfil the purposes for which it was collected or to comply with applicable legal retention requirements. The following retention periods apply:

• Active account data: Retained for the lifetime of your account plus 5 years after account closure to comply with financial record-keeping requirements.
• Transaction records: Retained for a minimum of 5 years after the transaction date in accordance with anti-money laundering regulations applicable to financial services platforms.
• Identity verification documents: Retained for 5 years after account closure.
• Support communications: Retained for 2 years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing consent records: Retained until you withdraw consent, plus 12 months to handle any related queries or complaints.
• Technical logs (IP, device): Retained for 12 months for security and fraud investigation purposes.

After the applicable retention period, data is securely deleted or anonymised so that it can no longer be associated with any individual. If you request account deletion, we will process the deletion of non-legally-required data within 30 days of your request, and delete all remaining data as soon as the applicable retention period expires.

9Your Data Rights

As a player on 98pak, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at support@98pak.click with your registered mobile number and a description of your request. We will respond within 30 days.

Identity verification may be required before we can fulfil a data rights request to ensure we release or delete data only to the account holder. We will not charge a fee for responding to reasonable requests. For complex or repeated requests, we reserve the right to charge a reasonable administrative fee.

10Children and Underage Users

98pak does not knowingly collect personal data from individuals under the age of 18. Our platform is strictly intended for adult players aged 18 and above. If you believe a minor has registered on 98pak or has accessed the platform using someone else's account, please contact us immediately at support@98pak.click so we can investigate and close the relevant account.

98pak employs age verification as part of the registration process and during KYC review. Accounts where a player is found to be under 18 will be suspended immediately, all bonuses and winnings will be forfeited, and any deposits will be returned to the original payment method.

Parents and guardians who are concerned about a minor's access to online gaming content are encouraged to use parental control tools available through their mobile operator or device settings. Details of these resources are available through our Responsible Gaming page.

11Changes to This Privacy Policy

98pak may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will notify you by sending a message to your registered mobile number or email, or by posting a prominent notice on the 98pak platform, at least 7 days before the changes take effect.

The "last updated" date at the top of this page reflects the most recent revision. We recommend reviewing this Policy periodically to stay informed about how 98pak protects your data.

Continued use of the 98pak platform after any updated Privacy Policy comes into effect constitutes your acceptance of the revised Policy. If you do not accept the changes, you may close your account before the effective date.

12How to Contact Us About Privacy

For any questions, concerns, or requests relating to this Privacy Policy or the way 98pak handles your personal data, please use the following contact options. We will acknowledge all privacy enquiries within 24 hours and provide a full response within 30 days.

When contacting us about a data rights request, please include your registered mobile number, the nature of your request, and any relevant account details. This helps us locate your records and process your request as quickly as possible.