pk38 Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how pk38 ("pk38", "we", "us", "our") collects, uses, stores, discloses, and protects personal data relating to individuals ("you", "User", "Player") who access or use the pk38 website at pk38.app and all associated services, games, and features (collectively, the "Platform").

By accessing or using the pk38 Platform, you acknowledge that you have read and understood this Policy. If you do not agree with the terms of this Policy, please discontinue your use of the Platform. This Policy should be read alongside the pk38 Terms & Conditions, which governs the overall use of the Platform.

pk38 is committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection principles. We collect only what is necessary, retain it only for as long as required, and do not sell your personal data to third parties.

2. Data Controller

For the purposes of this Policy, pk38 acts as the data controller with respect to personal data collected through the Platform. As data controller, pk38 determines the purposes and means of processing your personal data.

If you have questions about how your personal data is handled, or wish to exercise any of your rights described in Section 11 of this Policy, please contact the pk38 Data Privacy team using the contact details provided in Section 15.

3. Personal Data We Collect

3.1 Account Registration Data

When you create a pk38 account, we collect the following information:

• Full legal name as it appears on your identity document;
• Date of birth (for age verification purposes);
• Email address;
• Pakistani mobile number (for SMS verification, OTP delivery, and 2FA);
• Username and encrypted password;
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad).

3.2 Identity Verification (KYC) Data

To comply with Know Your Customer obligations and to prevent fraud and underage gambling, pk38 may request:

• Copy of a valid government-issued photo identification (National Identity Card / CNIC, Passport);
• Proof of address (utility bill, bank statement);
• Payment method verification documents (e.g., screenshot of JazzCash or Easypaisa account in your name);
• Selfie or liveness check as requested by our verification system.

3.3 Transaction & Financial Data

We collect information relating to your financial transactions on the Platform, including deposit amounts, withdrawal requests, payment methods used (JazzCash wallet ID, Easypaisa number, bank account details, card last four digits), transaction timestamps, and balance history. We do not store full card numbers or banking credentials on our servers – payment processing is handled by certified third-party payment processors.

3.4 Gaming Activity Data

We maintain records of your gaming activity on pk38, including games played, bet amounts, outcomes, session durations, responsible gaming settings, and bonus usage history. This data is used for account management, dispute resolution, responsible gaming monitoring, and fraud prevention.

3.5 Technical & Device Data

When you access the pk38 Platform, we automatically collect certain technical information including: IP address, browser type and version, operating system, device identifiers, screen resolution, referring URL, and pages visited. This data is used for security, fraud prevention, and platform performance optimisation.

3.6 Communications Data

If you contact pk38 customer support, we retain records of that communication including your name, contact details, the nature of your query, and our response. This helps us resolve disputes and improve our service quality.

4. How We Collect Your Data

pk38 collects personal data through the following means:

• Directly from you – when you register an account, complete KYC, make deposits or withdrawals, contact support, or update account preferences;
• Automatically – through cookies, log files, and similar tracking technologies when you use the Platform (see Section 6);
• From third parties – from identity verification service providers, payment processors (JazzCash, Easypaisa, HBL, etc.), fraud prevention agencies, and geolocation services, as necessary for Platform operation and compliance.

5. Purposes & Legal Basis for Processing

pk38 processes your personal data for the following purposes and on the following legal bases:

• Account management and service delivery – to operate your pk38 account, process deposits and withdrawals, provide access to games and betting services, and deliver customer support. Legal basis: performance of contract;
• Identity verification and fraud prevention – to verify your identity, confirm age eligibility (18+), prevent multiple accounts, detect and prevent fraud and money laundering. Legal basis: legal obligation and legitimate interests;
• Responsible gaming – to monitor gaming patterns, enforce deposit and loss limits, administer self-exclusion, and identify potentially problematic gambling behaviour. Legal basis: legal obligation and legitimate interests;
• Regulatory compliance – to maintain records required by applicable law, respond to regulatory requests, and cooperate with law enforcement where lawfully required. Legal basis: legal obligation;
• Marketing communications – to send you promotional offers, bonus notifications, and updates about pk38 services, where you have given explicit consent or where permitted by applicable law. You may opt out of marketing at any time via your account settings;
• Platform improvement – to analyse usage patterns, troubleshoot technical issues, and improve the overall pk38 user experience. Legal basis: legitimate interests.

6. Cookies & Tracking Technologies

The pk38 Platform uses cookies and similar technologies to enhance your experience, maintain session state, and collect analytical data. The types of cookies used include:

• Strictly Necessary Cookies – essential for the Platform to function, including session management and security tokens. These cannot be disabled without impairing platform functionality;
• Functional Cookies – remember your preferences such as language, game filters, and display settings to personalise your pk38 experience;
• Analytical Cookies – collect aggregate, anonymised data about how users interact with the Platform to help pk38 improve navigation and performance;
• Security Cookies – used to detect and prevent fraudulent activity, bot access, and abnormal session behaviour.

You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the pk38 Platform.

7. Sharing Your Personal Data

pk38 does not sell your personal data to third parties. We may share your data only in the following limited circumstances:

• Payment processors – JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Visa, Mastercard, UnionPay, and USDT processing partners, solely to process your financial transactions;
• Identity verification providers – certified KYC service providers for age and identity verification;
• Fraud prevention agencies – to detect, investigate, and prevent fraudulent activity on the Platform;
• Regulatory and law enforcement authorities – where pk38 is under a legal obligation to disclose information;
• Technology service providers – cloud hosting, security, and infrastructure partners bound by strict data processing agreements with pk38;
• Game studios – limited session data may be shared with licensed game providers (Pragmatic Play, PG Soft, etc.) to enable game functionality, but no personally identifiable information beyond session tokens is shared.

All third-party service providers engaged by pk38 are contractually obligated to process your personal data only as instructed by pk38 and to maintain appropriate security measures.

8. International Data Transfers

Some of pk38's service providers and technology infrastructure may be located outside Pakistan. Where personal data is transferred internationally, pk38 ensures that appropriate safeguards are in place – including contractual data processing agreements and security standards equivalent to those that apply within Pakistan – to protect your personal data in transit and at the destination.

9. Data Retention

pk38 retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and operational requirements. Specific retention periods include:

• Account data – retained for the duration of your pk38 account and for a period thereafter as required by applicable law;
• Transaction records – financial transaction data is retained for a minimum of five (5) years following the transaction, in line with anti-money laundering record-keeping requirements;
• KYC documentation – identity verification documents are retained for at least five (5) years following account closure;
• Customer support communications – retained for three (3) years following resolution of the relevant query or dispute;
• Marketing data – retained until you withdraw consent or opt out of marketing, plus a reasonable administrative period.

When personal data is no longer required, pk38 securely destroys or anonymises it in accordance with our data disposal procedures.

10. Security of Your Personal Data

pk38 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your browser and the pk38 Platform;
• Encrypted storage of sensitive account credentials;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and vulnerability assessments of Platform infrastructure;
• Two-factor authentication (2FA) support for all player accounts;
• Anomaly detection and real-time monitoring for suspicious login activity.

While pk38 takes all reasonable precautions, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your pk38 account credentials and for notifying us immediately of any suspected unauthorised access.

11. Your Rights

Subject to applicable law, you have the following rights with respect to your personal data held by pk38:

• Right of access – you may request a copy of the personal data pk38 holds about you;
• Right to rectification – you may request correction of inaccurate or incomplete personal data;
• Right to erasure – you may request deletion of your personal data, subject to pk38's legal obligations to retain certain records;
• Right to restriction of processing – you may request that pk38 restrict processing of your data in certain circumstances;
• Right to data portability – you may request a copy of your personal data in a structured, machine-readable format;
• Right to withdraw consent – where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal;
• Right to object – you may object to processing of your data based on legitimate interests, including for direct marketing purposes.

To exercise any of these rights, please contact the pk38 Data Privacy team using the contact details in Section 15. We will respond to verified requests within thirty (30) days.

12. Children's Privacy

The pk38 Platform is strictly intended for individuals aged 18 and over. pk38 does not knowingly collect personal data from persons under the age of 18. Age verification is conducted at account registration and at withdrawal. If pk38 becomes aware that personal data has been collected from a person under 18, the relevant account will be immediately closed and personal data deleted, with any funds returned in accordance with platform policy. If you believe a minor has registered on pk38, please contact us immediately at the details in Section 15.

13. Third-Party Links & Services

The pk38 Platform may contain links to third-party game studios, payment providers, and other services. This Privacy Policy applies solely to data processed by pk38 through the Platform. pk38 is not responsible for the privacy practices of any third-party services, and we encourage you to review the privacy policies of any third parties whose services you access through or in connection with pk38.

14. Changes to This Policy

pk38 reserves the right to update or modify this Privacy Policy at any time. Material changes will be communicated to registered users via email notification to the address on file or via a prominent notice on the Platform prior to the change taking effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the pk38 Platform following notification of changes constitutes your acceptance of the updated Policy.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by pk38, please contact our Data Privacy team:

Email: [email protected]

Please mark your correspondence clearly as a "Privacy / Data Request" and include your registered account email address and a description of your query. pk38 will acknowledge receipt of your request within five (5) business days and will aim to fully resolve data rights requests within thirty (30) calendar days.