Privacy Policy How pk31 Handles Your Personal Data

This Privacy Policy ("Policy") is issued by pk31 ("we", "us", "our"), the operator of the Platform accessible at https://pk31.cam. This Policy applies to all personal data processed in connection with your use of the Platform, whether you access it as a registered user or as a visitor.

pk31 is an English-language online gaming information and guidance platform built for Pakistani players and other international users. We do not process player payments, hold player funds or manage gaming accounts directly. However, we do collect certain personal data in the course of operating this Platform, and this Policy governs how that data is handled.

We are committed to protecting your privacy and handling your personal data with transparency, integrity and care. This Policy is written in plain English to ensure that all users — including those based in Karachi, Lahore, Islamabad, Rawalpindi and across Pakistan — can understand how their information is used.

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

• "Personal Data" — Any information relating to an identified or identifiable natural person. This includes name, email address, IP address, device identifiers, and any other information that can be used directly or indirectly to identify an individual.
• "Processing" — Any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, deletion and all intermediate operations.
• "Data Controller" — The entity that determines the purposes and means of Processing Personal Data. For this Platform, the Data Controller is pk31.
• "Data Processor" — A third party that processes Personal Data on behalf of and under the instructions of the Data Controller.
• "User" / "You" — Any individual who accesses or uses the Platform, whether registered or unregistered.
• "KYC Data" — Identity and verification documents submitted as part of a Know Your Customer process, including CNIC, passport copies, proof of address and liveness-check images.
• "Cookies" — Small data files placed on your device by the Platform to enable certain functionality, track usage and support analytics.
• "Consent" — A freely given, specific, informed and unambiguous indication of agreement to the Processing of Personal Data for a stated purpose.
• "Platform" / "Site" — The pk31 website at https://pk31.cam, including all pages and associated services.

Depending on how you interact with the Platform, we may collect and process the following categories of Personal Data:

We collect Personal Data through the following means:

4.1 Direct Collection

Data you provide directly when you: register an account on the Platform; complete identity verification (KYC); contact our support team via email or live chat; complete any form on the Platform; or correspond with us by any other means.

4.2 Automated Collection

Certain technical and usage data is collected automatically when you access the Platform, through cookies, server logs, pixel tags and similar tracking technologies. This includes your IP address, device identifiers, browser type, session data and navigation behaviour on the Site. See Section 7 (Cookies & Tracking) for full details.

4.3 Third-Party Sources

We may receive data about you from third-party sources, including: identity verification service providers used during the KYC process; fraud prevention and AML screening databases; and analytics service providers that aggregate non-identifiable usage data to help us understand how the Platform is used. In each case, we handle such data in accordance with this Policy.

We process your Personal Data only where we have a valid legal basis to do so. The purposes for which we process your data, together with the corresponding legal basis, are set out below:

5.1 Account Management

Purpose: To create, maintain and administer your registered account on the Platform, including authentication, communication and account recovery.
Legal Basis: Performance of a contract (account agreement) and our legitimate interests in operating a secure, functional Platform.

5.2 Identity Verification (KYC)

Purpose: To verify your identity, confirm that you meet age requirements, and comply with applicable anti-money laundering (AML) and Know Your Customer obligations.
Legal Basis: Legal obligation (applicable regulatory and AML requirements) and legitimate interests in fraud prevention.

5.3 Platform Operation & Security

Purpose: To operate, maintain and improve the Platform; to detect, investigate and prevent fraud, security incidents and policy violations; to monitor for suspicious activity.
Legal Basis: Legitimate interests in maintaining a secure and functional Platform; legal obligations where applicable.

5.4 Customer Support

Purpose: To respond to your enquiries, complaints and support requests; to maintain records of communications for quality and accountability purposes.
Legal Basis: Performance of contract and legitimate interests in providing effective support.

5.5 Analytics & Improvement

Purpose: To understand how users interact with the Platform; to identify areas for improvement; to measure the effectiveness of content and features.
Legal Basis: Legitimate interests in improving Platform performance and user experience.

5.6 Marketing Communications

Purpose: To send you promotional communications about Platform updates, features and offers where you have opted in.
Legal Basis: Consent. You may withdraw consent at any time by contacting us or using the unsubscribe option in any marketing communication.

5.7 Legal & Compliance

Purpose: To comply with applicable law, respond to lawful requests from public authorities, enforce our Terms & Conditions, and protect the rights, property or safety of pk31 or its users.
Legal Basis: Legal obligation and legitimate interests in legal compliance and enforcement.

pk31 does not sell your Personal Data to third parties. We do not share your Personal Data with unaffiliated third parties for their own direct marketing purposes. We may share your Personal Data only in the following circumstances:

6.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process Personal Data on our behalf, including: hosting and infrastructure providers; identity verification and KYC service providers; fraud and AML screening services; analytics providers; and customer support tools. All Data Processors are subject to contractual data-protection obligations and may not use your data for any purpose beyond the specific service they provide to pk31.

6.2 Legal & Regulatory Disclosure

We may disclose Personal Data where required to do so by applicable law, court order, regulatory authority, or governmental directive — including any lawful request by Pakistani authorities or the regulatory bodies of any jurisdiction in which pk31 operates. We will notify you of such disclosure where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale or corporate restructuring involving pk31, Personal Data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any resulting change to this Policy in advance where reasonably practicable.

6.4 Fraud Prevention & Safety

We may share data with fraud-prevention agencies, law enforcement bodies or other third parties where we reasonably believe disclosure is necessary to prevent, investigate or prosecute fraudulent activity, money laundering, illegal use of the Platform, or where there is a risk to the safety of any individual.

pk31 uses cookies and similar tracking technologies to operate and improve the Platform. This section explains what cookies we use and how you can manage your preferences.

7.1 Types of Cookies

• Strictly Necessary Cookies: Essential for the Platform to function correctly — for example, to maintain your session, authenticate your login, and remember your cookie preferences. These cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Collect anonymised or pseudonymised data about how visitors use the Platform — pages visited, session duration, error messages. Used to improve Platform performance and content.
• Functional Cookies: Remember your preferences and settings — for example, language, region and display options — to provide a more personalised experience.
• Marketing & Targeting Cookies: Used where you have opted in to track interactions with promotional content and to measure the effectiveness of marketing campaigns. These cookies may be set by trusted third-party advertising partners.

7.2 Managing Cookies

You may manage your cookie preferences at any time through your browser settings. Most modern browsers allow you to block or delete cookies, and to receive notifications before a cookie is placed. Please note that disabling certain cookies may affect Platform functionality. Instructions for managing cookies in major browsers are available through the browser's own help documentation.

Where required by applicable law, we will seek your consent before placing non-essential cookies on your device. Consent can be withdrawn at any time by updating your browser settings or contacting us.

pk31 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The specific retention period for each category of data depends on its nature and the purpose for which it was collected.

• Account Data: Retained for the duration of your active account plus a reasonable period thereafter to handle any post-closure enquiries or legal claims.
• KYC / Identity Documents: Retained for the period required by applicable AML and identity-verification regulations, which may extend beyond account closure. This period is determined by the applicable regulatory framework of the relevant licensing jurisdiction.
• Support Communications: Typically retained for a period sufficient to resolve disputes and handle follow-up enquiries — generally up to 3 years unless longer retention is required by law.
• Technical & Usage Logs: Retained in pseudonymised or aggregated form for analytics purposes for up to 24 months, after which they are deleted or permanently anonymised.
• Marketing Data: Retained until you withdraw consent or are removed from the relevant mailing list, whichever occurs first.

When Personal Data is no longer required, it is securely deleted or permanently anonymised in accordance with our internal data-disposal procedures. Where deletion is not immediately possible (e.g., because the data exists in backup archives), we will ensure that it is isolated from active processing and deleted at the earliest practicable opportunity.

pk31 operates internationally, and your Personal Data may be transferred to, stored in, and processed in countries other than Pakistan. Some of these countries may have data-protection laws that differ from those applicable in Pakistan or in your country of residence.

Where we transfer Personal Data internationally, we take steps to ensure that appropriate safeguards are in place to protect that data, including: contractual data-protection clauses with our service providers; adherence to applicable data-protection frameworks; and implementation of appropriate technical and organisational security measures.

Subject to applicable law and certain limitations, you have the following rights in relation to your Personal Data held by pk31. To exercise any of these rights, please contact us using the details in Section 16.

The pk31 Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction. We do not knowingly collect, solicit or process Personal Data from individuals under the age of 18. If we become aware that Personal Data has been collected from a person under 18 without appropriate parental or guardian consent, we will take immediate steps to delete such data from our records.

If you are a parent or guardian and believe that your child has provided Personal Data to pk31, please contact us immediately at the address set out in Section 16 so that we can take appropriate action.

pk31 implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, disclosure or alteration. These measures are reviewed and updated on a regular basis to reflect evolving security standards.

Specific security controls include, but are not limited to:

• Encryption in Transit: All data transmitted between your browser and the Platform is encrypted using TLS/SSL. Users should verify the padlock icon in their browser's address bar when submitting sensitive information.
• Encryption at Rest: Sensitive Personal Data and KYC documents stored in our systems are encrypted at rest using industry-standard algorithms.
• Access Controls: Access to Personal Data is restricted on a need-to-know basis. Internal systems enforce role-based access controls and comprehensive authentication requirements for staff.
• Security Monitoring: We monitor our systems for suspicious activity, attempted intrusions and anomalous data-access patterns on an ongoing basis.
• Incident Response: We maintain a documented security-incident response process. In the event of a data breach that poses a risk to your rights, we will notify you and any applicable supervisory authority as required by law.

While we take reasonable steps to protect your Personal Data, no data transmission over the internet or data storage system can be guaranteed as 100% secure. You are responsible for maintaining the security of your own account credentials and for notifying us immediately of any suspected unauthorised access to your account.

The Platform may contain references to or descriptions of third-party gaming operators and payment platforms. Please note that pk31 does not control these external platforms and is not responsible for their privacy practices, data-processing activities or security measures.

If you navigate to a third-party Operator's platform as a result of information obtained through pk31, you do so at your own risk. That Operator's own privacy policy — not this one — will govern the handling of any data you provide to them. We strongly recommend that you read the privacy policy of any platform on which you register before providing any personal or financial information.

This includes any payment provider platforms such as Easypaisa, JazzCash, Raast, or banking platforms. Their data-handling practices are governed by their own privacy policies, which pk31 has no authority to bind or represent.

pk31 is designed primarily for Pakistani users and acknowledges the specific legal and regulatory context applicable in Pakistan. The following Pakistan-specific considerations apply:

14.1 Applicable Law

Pakistan's data protection framework is developing. Relevant instruments include the Electronic Crimes Act (PECA) 2016, which governs unauthorised access and electronic data protection, and proposed data protection legislation currently progressing through the legislative process. pk31 monitors applicable Pakistani law and will update data-handling practices accordingly as legislation comes into force.

14.2 Payment Data Context

References to Pakistani payment methods — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — on pk31 are informational and contextual only. pk31 does not process transactions through these providers and does not receive or store payment credentials from users. Any payment data you share with an Operator's platform is governed by that Operator's privacy policy and the relevant payment provider's terms.

14.3 Regulatory Requests

In the event of a lawful, formally issued request for Personal Data by Pakistani regulatory or law enforcement authorities — including PTA, FIA, or provincial authorities — pk31 will respond in accordance with applicable law and applicable legal process, disclosing only the minimum data required by the applicable order or request.

pk31 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data-processing activities, applicable law, or Platform operations. The "Last Reviewed" date displayed at the top of this page will be updated whenever a revision is made.

Where we make material changes to this Policy — changes that significantly affect your rights or how we process your Personal Data — we will make reasonable efforts to notify registered users, either through a prominent notice on the Platform or by direct communication. However, it remains your responsibility to review this Policy periodically to stay informed of any updates.

Continued use of the Platform following publication of an amended Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not agree with any amended terms, please discontinue use of the Platform and contact us to exercise any applicable rights in relation to your data.

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your Personal Data, please contact us using the details below. We take all privacy enquiries seriously and will respond as promptly as practicable.

For requests to exercise your data rights (access, rectification, erasure, etc.), please describe your request clearly, include your registered email address for identification purposes, and indicate which right(s) you wish to exercise. We may request additional identity verification before processing sensitive data requests.