Privacy Policy — Pakgem Data Practices
Pakgem is committed to protecting your personal information. This Privacy Policy explains what data we collect, why we collect it, how we use and protect it, and what rights you have over your own information as a user of pakgem.cam.
All data transmitted between your device and pakgem is encrypted via HTTPS/TLS. We apply industry-standard technical and organisational security measures to protect your personal information at rest and in transit.
Pakgem does not sell, rent or otherwise commercially transfer your personal data to third parties. Your information is used only for purposes outlined in this Policy and is shared with third parties only where strictly necessary.
You have the right to access, correct, restrict and request deletion of your personal data at any time, subject to legal retention obligations. Requests can be made through the support team using the contact details in Section 15.
We are mindful of the data environment for Pakistani users. Where personal data is processed in connection with payment references such as Easypaisa, JazzCash, HBL or Raast, we process only the minimum data required to fulfil the service.
This Policy clearly states the legal basis for each category of data processing, the retention periods that apply and the third parties who may receive your data. There are no hidden data uses or undisclosed transfers in pakgem's data practices.
This Privacy Policy is reviewed and updated as required to reflect changes in our services, technology and applicable privacy law. The date of the most recent revision is always displayed at the top of this page.
Table of Contents
Introduction
Pakgem ("we", "us", "our"), accessible at pakgem.cam, operates as an English-language online gaming information and entertainment platform principally serving users in Pakistan. We are committed to handling all personal data entrusted to us with care, transparency and respect for individual privacy rights.
This Privacy Policy ("Policy") describes in detail: (a) the categories of personal data we collect from users; (b) the lawful basis on which that data is processed; (c) the purposes for which it is used; (d) how long we retain it; (e) with whom it may be shared; and (f) the rights available to you as a data subject. This Policy applies to all users who register an account on, access, browse or otherwise interact with the pakgem Platform.
By registering an account, accepting our Terms & Conditions or by continuing to use the Platform after this Policy has been brought to your attention, you acknowledge that you have read, understood and consented to the practices described herein. If you do not agree with any part of this Policy, please cease using the Platform and contact support to arrange account closure.
This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference into the overall user agreement governing your use of pakgem.
Definitions
For the purposes of this Privacy Policy, the following terms carry the meanings defined below:
| Term | Meaning |
|---|---|
| Personal Data | Any information that identifies or can reasonably be used to identify a living individual, directly or indirectly — including name, email address, IP address, device identifiers, account credentials and financial transaction data. |
| Data Controller | Pakgem — the entity that determines the purposes and means of processing personal data collected through the Platform. |
| Data Processor | Any third party that processes personal data on behalf of pakgem, under written instruction, for a specified purpose — such as a KYC verification provider or payment processing intermediary. |
| Data Subject / User | Any identified or identifiable natural person whose personal data is processed by or on behalf of pakgem. |
| Processing | Any operation performed on personal data, including collection, storage, retrieval, use, disclosure, transmission, restriction, erasure or destruction. |
| Consent | A freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of their personal data for a stated purpose. |
| KYC Data | Identity and verification documents submitted by a User in fulfilment of Know Your Customer requirements, including CNIC, passport, proof of address and selfie or liveness check images. |
| Cookies | Small text files placed on a User's device by the Platform for the purpose of session management, analytics, preference retention and marketing — as further described in Section 8. |
Data We Collect
Pakgem collects personal data across several categories, depending on how you interact with the Platform. The categories below are not exhaustive but represent the principal types of data we process:
| Category | Examples | When Collected |
|---|---|---|
| Registration Data | Full name, date of birth, email address, mobile number, residential address, username. | At account creation. |
| Identity & KYC Data | CNIC or passport copy, proof of address, selfie / liveness check image. | During KYC verification, typically before first withdrawal. |
| Financial Data | Deposit amounts, withdrawal requests, payment method identifiers (e.g., wallet reference or bank IBAN — not full card numbers stored on Platform). | When you transact through the cashier. |
| Technical Data | IP address, browser type and version, operating system, device type, session timestamps, referrer URLs. | Automatically on each Platform visit. |
| Behavioural Data | Game play history, bet amounts, win/loss records, session duration, pages visited, feature interactions. | During active sessions on the Platform. |
| Communication Data | Support chat transcripts, email correspondence, complaint records. | When you contact the Platform's support team. |
| Responsible Gambling Data | Self-exclusion requests, deposit limit settings, loss limit configurations, session time limit records. | When you interact with responsible gambling tools. |
| Marketing Preferences | Opt-in or opt-out status for promotional communications, language preference, notification settings. | At registration or subsequently through account settings. |
We collect only the minimum data necessary to operate the Platform and fulfil our legal obligations. We do not collect sensitive categories of data (such as racial origin, health records or biometric data) beyond the liveness check required for KYC, which is processed by our verification provider solely for identity confirmation purposes.
How We Collect Data
4.1 Directly from You
The majority of personal data we hold is provided directly by you during the course of using the Platform — at registration, during KYC verification, when you contact support or when you configure account preferences such as responsible gambling limits.
4.2 Automatically
Technical data — including IP address, device identifiers, session information and behavioural interactions — is collected automatically as you browse and use the Platform. This is achieved through server logs, cookies and similar tracking technologies described in Section 8.
4.3 From Third Parties
In certain circumstances, we may receive personal data about you from third parties, including:
- Identity verification providers conducting KYC checks on our behalf.
- Payment intermediaries confirming transaction status or flagging suspicious activity.
- Fraud detection and AML (Anti-Money Laundering) compliance services.
- Regulatory or law enforcement authorities where we are required by law to accept such data.
Where data is received from third parties, we ensure that the relevant third party has a lawful basis for sharing it with us and that the data is handled in accordance with this Policy.
Data Processing Purposes
Pakgem processes personal data for the following purposes:
- Account Management: Creating, operating, maintaining and securing your registered account on the Platform.
- Identity Verification (KYC): Confirming your identity, age and eligibility to use the Platform, as required by applicable compliance obligations.
- Transaction Processing: Facilitating deposits and withdrawal requests, verifying payment method ownership and maintaining transaction records.
- Game Delivery and Personalisation: Operating game sessions, recording outcomes, personalising your experience based on usage patterns and preferences.
- Responsible Gambling: Monitoring activity for indicators of problem gambling, administering self-exclusion requests and enforcing limit settings at your request.
- Fraud Prevention and AML: Detecting, investigating and preventing fraudulent activity, money laundering and other prohibited conduct as described in our Terms & Conditions.
- Customer Support: Responding to enquiries, resolving complaints and maintaining records of support interactions.
- Legal and Regulatory Compliance: Meeting obligations imposed by applicable licensing authorities, financial regulators or law enforcement agencies.
- Marketing Communications: Sending promotional offers, bonus notifications and platform updates to users who have opted in to receive such communications.
- Analytics and Improvement: Analysing usage patterns, identifying technical issues and improving the Platform's design, performance and content offerings.
Legal Basis for Processing
Each processing activity described in Section 5 is carried out on one or more of the following lawful bases:
- Contractual Necessity: Processing necessary to perform the contract between you and pakgem — i.e., to operate your account, process transactions and deliver gaming services.
- Legal Obligation: Processing required to comply with applicable law — including KYC/AML obligations, responsible gambling record-keeping and regulatory reporting.
- Legitimate Interests: Processing necessary for pakgem's legitimate business interests, including fraud prevention, platform security, analytics and service improvement, where those interests are not overridden by your rights.
- Consent: Processing based on your freely given, specific and informed consent — primarily for marketing communications. You may withdraw consent at any time by contacting support or adjusting your account notification settings.
Where processing is based on consent, withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. For processing based on contractual necessity or legal obligation, withdrawal of consent does not override those grounds.
Data Sharing & Disclosure
7.1 Authorised Third Parties
Pakgem does not sell personal data. We share personal data only with the following categories of authorised recipients, and only to the extent necessary for the stated purpose:
- KYC Verification Providers: Identity verification companies engaged to confirm your identity, age and document authenticity as part of the KYC process.
- Payment Processors: Intermediaries that facilitate deposit and withdrawal transactions. Payment provider names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced for contextual reference only — these providers operate under their own privacy policies and do not endorse gambling activities.
- Fraud and AML Service Providers: Third-party compliance tools used to screen for suspicious activity, politically exposed persons (PEPs) and sanctions list entries.
- Technology and Hosting Providers: Cloud hosting, database and infrastructure providers that store or process data on our behalf under data processing agreements.
- Analytics Providers: Services used to measure platform performance and user engagement, operating under data minimisation and anonymisation principles where possible.
7.2 Legal Disclosures
Pakgem may disclose personal data to regulatory authorities, law enforcement agencies or courts where required to do so by applicable law, a valid legal order, or where we have a good-faith belief that disclosure is necessary to protect the rights, property or safety of the Platform, its users or the public.
7.3 Business Transfers
In the event of a merger, acquisition, restructuring, sale of assets or other corporate transaction, personal data held by pakgem may form part of the transferred assets, subject to the acquiring entity honouring the data protection commitments in this Policy or providing you with a revised privacy notice prior to any material change in processing.
Cookies & Tracking Technologies
Pakgem uses cookies and similar tracking technologies to ensure the Platform functions correctly, to analyse usage and to support certain features. The following categories of cookies may be in use:
You can manage cookie preferences through your browser's settings at any time. Disabling certain cookies may affect the functionality of the Platform. Our cookie management tool, where available, provides granular controls over non-essential cookie categories.
Data Retention
Pakgem retains personal data for as long as is necessary to fulfil the purpose for which it was collected, to comply with legal obligations or to resolve disputes. The following indicative retention principles apply:
- Account Data: Retained for the duration of your active account plus a minimum post-closure period required by the Platform's applicable licensing or regulatory framework (typically 5 years following account closure).
- KYC and Identity Documents: Retained for the period required by AML regulations applicable to the Platform's license jurisdiction. These requirements typically mandate retention for a minimum of 5 years from the date of the relevant transaction or account closure, whichever is later.
- Financial and Transaction Records: Retained as required by applicable financial record-keeping obligations, typically for a minimum of 5–7 years.
- Support Communications: Retained for up to 3 years following resolution of the relevant support matter, or longer where the communication relates to an open complaint or legal proceeding.
- Marketing Data: Retained until you withdraw consent or opt out of marketing communications, at which point your data is removed from active marketing lists (though a suppression record may be retained to honour your opt-out).
- Technical / Log Data: Typically retained for 6–18 months for operational and security monitoring purposes.
Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where anonymisation is applied, the resulting data is no longer considered personal data and may be retained for statistical or analytical purposes.
Data Security
Pakgem implements a layered approach to data security designed to protect personal information against unauthorised access, accidental loss, alteration or disclosure. Key measures in place include:
- All data in transit between your device and the Platform is encrypted using TLS (Transport Layer Security) via HTTPS. Always verify the padlock icon in your browser when accessing the Platform.
- Sensitive data at rest — including financial records and KYC documents — is encrypted using industry-standard encryption protocols.
- Access to personal data within the Platform's infrastructure is restricted to authorised personnel on a strict need-to-know basis, enforced through role-based access controls.
- Multi-factor authentication is applied to internal administrative access systems.
- Regular security assessments, penetration testing and vulnerability scanning are conducted on Platform infrastructure.
- Third-party service providers with access to personal data are subject to data processing agreements and assessed for compliance with applicable security standards.
No digital platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own account credentials and for logging out of your account after each session, particularly on shared or public devices. If you believe your account has been compromised, contact support immediately.
Your Rights
As a data subject, you have a number of rights in relation to your personal data. The exercise of these rights is subject to applicable law and, in certain cases, to pakgem's legal retention obligations. The rights available to you include:
Right of Access
You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
Right to Rectification
You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose collected, where consent is withdrawn, or where processing is unlawful — subject to legal retention requirements that override erasure.
Right to Restrict Processing
You may request that we limit processing of your data in certain circumstances — for example, while accuracy is contested or an objection is pending.
Right to Data Portability
Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used and machine-readable format.
Right to Object
You have the right to object to processing based on legitimate interests, including direct marketing. Objection to marketing processing will result in immediate cessation of marketing communications.
To exercise any of the above rights, please contact the pakgem support team using the details provided in Section 15. We will respond to verified requests within a reasonable timeframe, typically within 30 days. We may need to verify your identity before processing your request. Where a request is denied, we will provide reasons and inform you of your right to escalate the matter.
Exercising your data rights is free of charge. Requests will not be used as grounds for reducing service quality or restricting your account, except where data deletion or restriction makes it technically impossible to continue providing the service.
Minors & Age Restriction
Pakgem is strictly an adults-only platform. Access to and use of any real-money gambling feature is prohibited for individuals under the age of 18, or the higher minimum age required by the operator's applicable license jurisdiction.
We do not knowingly collect personal data from individuals under the applicable minimum age. Age verification is a mandatory component of the KYC process, and accounts where the user is found to be underage are closed immediately with all associated balances and winnings forfeited. Any personal data collected in connection with an underage account is deleted upon discovery, except where retention is required by law.
If you are a parent or guardian and you believe that a minor in your care has registered an account on the Platform, please contact the support team immediately at the details provided in Section 15 so that the account can be closed and the relevant data reviewed.
18+ only — or the higher minimum age required by the operator/license jurisdiction. This is an adults-only platform. Local laws — including Pakistan's Prevention of Gambling Act 1977 — may restrict gambling. Compliance with applicable local law is the user's responsibility.
Third-Party Services
The Platform may integrate with third-party services — including game studios, live dealer streaming providers, sports data feeds, payment gateway intermediaries and analytics platforms — to deliver its core functionality. Each of these third-party services operates under its own privacy policy and data protection practices, which are independent of pakgem's Policy.
When you interact with a third-party service through the Platform — for example, playing a game delivered by an external studio or completing a payment via a payment intermediary — the relevant third party may process personal data in accordance with their own terms. Pakgem is not responsible for the privacy practices of independent third-party providers.
Where we share personal data with third-party processors, we do so under contractual arrangements that require them to: (a) process data only for specified, documented purposes; (b) apply appropriate technical and organisational security measures; and (c) not sub-process the data without authorisation. References to payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah are for contextual reference only; these entities are not data processors acting under pakgem's instruction and are not affiliated with or endorsing gambling activities on this Platform.
Policy Updates
Pakgem reserves the right to update, amend or replace this Privacy Policy at any time to reflect changes in our services, technology, legal obligations or data protection best practices. Material changes will be communicated to registered users via email notification or an on-platform notice prior to the changes taking effect.
The revised Policy will take effect from the date indicated in the updated "Last updated" field at the top of this page. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy. If you do not agree to the revised terms, please cease using the Platform and contact support to arrange account closure.
The current version of this Privacy Policy is always accessible at pakgem.cam/privacy-policy. We recommend reviewing this page periodically to stay informed of how we handle your data.
Contact Us
If you have any questions, concerns or requests relating to this Privacy Policy or to the personal data we hold about you, please contact the pakgem data protection team through the following channels:
- Email (plain text, not a link): [email protected]
- Subject Line: Please include "Privacy Request" in the subject line of any data-related email enquiry so that it is routed correctly.
- Live Chat: Available 24/7 through the Platform's live chat interface for general privacy questions.
- Supported Languages: English and Urdu.
We will acknowledge receipt of your request promptly and aim to provide a substantive response within 30 days. Where a request is complex or involves a large volume of data, we will notify you within 30 days if an extension is required, explaining the reasons for any delay.
We take data rights requests seriously. All requests are reviewed by trained staff with an understanding of data protection obligations. If you are not satisfied with our response to a privacy concern, you have the right to escalate the matter to the appropriate supervisory authority in the jurisdiction governing the Platform's licence.
Your Privacy, Our Responsibility
Questions about your data? Our support team is available 24/7. Or explore the homepage to discover everything pakgem has to offer Pakistani players.
18+ only. Gambling involves risk. Local laws may restrict gambling. Please read our Responsible Gambling policy.