Privacy Policy

This Privacy Policy ("Policy") describes how pk19 ("pk19", "we", "us", "our") collects, uses, stores, discloses and protects the personal data of individuals ("User", "you") who access or use the pk19 platform at https://pk19.cam and any associated services (collectively, the "Platform").

We are committed to handling your personal data responsibly and in accordance with applicable data protection legislation. For users accessing our Platform from Pakistan, we acknowledge the provisions of the Prevention of Electronic Crimes Act, 2016 (PECA) and the Personal Data Protection Bill framework currently under development in Pakistan, in addition to any international data protection standards applicable by virtue of our operating jurisdiction.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy. By using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with its terms, please discontinue use of the Platform immediately.

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, contact details, financial data, device identifiers and behavioural data where such information can reasonably be used to identify an individual.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure and deletion.
• "Data Controller" means pk19 in its capacity as the entity that determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of pk19 under a binding data processing agreement.
• "KYC Data" means identity verification documents submitted during the Know Your Customer process, including government-issued identification, proof of address and source-of-funds documentation.
• "Cookies" means small text files placed on your device by our Platform or by authorised third-party services for functional, analytics or performance purposes.
• "Special Category Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric data or data concerning a person's sex life or sexual orientation. We do not deliberately collect Special Category Data.
• "Legitimate Interests" means a legal basis for processing under which we may handle Personal Data where necessary for our genuine business interests, provided those interests are not overridden by your fundamental rights and freedoms.

We collect Personal Data in the following categories, depending on your interactions with the Platform:

We do not deliberately collect Special Category Data. If you voluntarily disclose health-related information (for example, in connection with a responsible-gambling request), we will treat that information with an elevated level of care and restrict access strictly to personnel involved in processing your request.

We process your Personal Data under one or more of the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions — including account management, payment processing and customer support.
• Legal Obligation: Processing required to comply with applicable laws, including KYC/AML obligations, regulatory reporting requirements and responses to valid legal orders.
• Legitimate Interests: Processing necessary for our genuine business interests, including fraud prevention, platform security, product improvement and responsible-gambling monitoring, where such interests are not overridden by your rights.
• Consent: Where we rely on your consent — for example, for sending non-essential marketing communications — we will obtain your prior, freely given, specific and informed consent. You may withdraw consent at any time by contacting us or adjusting your account marketing preferences.

We use your Personal Data for the following purposes:

1. Account Management: Creating, maintaining and administering your registered account, including verifying your identity and processing account closure requests.
2. Payment Processing: Facilitating deposits and withdrawals via available payment methods. References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are contextual — these providers process only the data necessary for the transaction under their own policies.
3. KYC & AML Compliance: Verifying your identity, assessing source of funds and meeting our anti-money laundering obligations.
4. Platform Operation: Delivering the games, features and services available on the Platform; responding to technical issues and service requests.
5. Fraud Prevention & Security: Detecting, investigating and preventing fraudulent activity, unauthorised account access and abuse of promotional structures.
6. Responsible Gambling: Monitoring account activity for indicators of problem gambling, applying player-protection tools (deposit limits, session timers, loss limits, self-exclusion) and communicating responsible-gambling resources.
7. Customer Support: Responding to enquiries, resolving disputes and providing account assistance in English (and Urdu on request).
8. Marketing Communications: Where you have opted in, sending promotional content by email. You may opt out at any time via your account settings or by contacting support.
9. Platform Improvement: Analysing aggregated usage data to improve the Platform's performance, user experience and content relevance.
10. Legal Compliance: Responding to valid court orders, regulatory enquiries and other statutory obligations.

pk19 does not sell, rent or trade your Personal Data. We may share your data with the following categories of recipients, strictly as necessary and under binding confidentiality obligations:

• Payment Processors: Entities facilitating your deposit or withdrawal transactions. Each processor handles data under their own privacy policy and applicable financial regulation.
• KYC / Identity Verification Providers: Third-party services that assist in verifying your identity and screening against sanctions and PEP (Politically Exposed Persons) lists as required by AML law.
• Game Content Providers: Studio and platform integrators whose games are accessible through the Platform. These providers may receive pseudonymised session data for technical purposes.
• Fraud Prevention Services: Third-party tools that analyse technical and behavioural data to detect account compromise, bonus abuse and money-laundering patterns.
• Responsible Gambling Platforms: Where required by the operator's licensing conditions, data may be shared with multi-operator self-exclusion registries.
• Professional Advisers: Legal, audit and compliance advisers under strict confidentiality obligations.
• Regulatory & Law Enforcement Authorities: Where required by a valid legal order, court direction or regulatory requirement under applicable law.

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention framework is as follows:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of verification, or longer where required by the applicable AML/CTF framework.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support Correspondence: Retained for up to three (3) years from the date of the interaction unless the subject matter relates to an ongoing legal or compliance matter.
• Marketing Data: Retained until you withdraw consent or for up to two (2) years of inactivity following your last marketing interaction.
• Technical / Log Data: Retained for up to twelve (12) months from collection, unless required for longer periods in connection with an active investigation.

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymised such that it can no longer be associated with any identifiable individual.

pk19 operates as an internationally licensed platform. Your Personal Data may be transferred to, and processed in, countries other than Pakistan, including the jurisdiction in which our operating entity is incorporated and countries where our third-party processors are based.

Where such transfers occur, we take steps to ensure that your data receives an equivalent level of protection to that provided under applicable data protection standards, through one or more of the following mechanisms:

• Transfers to jurisdictions recognised as providing adequate data protection;
• Standard contractual clauses or equivalent contractual safeguards binding on the recipient;
• Binding corporate rules where transfers occur within an approved corporate group structure;
• Explicit consent, where no other adequate mechanism is available for a specific transfer.

By using the Platform, you acknowledge that your Personal Data may be transferred internationally as described above.

The Platform uses cookies and similar tracking technologies to enable core functionality, analyse usage patterns and improve the user experience. We use the following categories of cookies:

You can manage cookie preferences through your browser settings. Please note that blocking essential cookies will impair Platform functionality. For detailed guidance on managing cookies in common browsers, refer to your browser's help documentation.

Subject to applicable data protection law and any overriding legal obligations (such as AML record-keeping requirements), you have the following rights in respect of your Personal Data:

The Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's licensing jurisdiction. We do not knowingly collect Personal Data from individuals below the applicable minimum age.

Age verification is conducted as part of the KYC process. Where we become aware that Personal Data has been collected from a minor — whether through our verification process, a report from a third party or any other means — we will take immediate steps to delete that data and close the associated account.

pk19 implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include, but are not limited to:

• SSL/TLS encryption for all data in transit between your device and our servers;
• Encryption at rest for sensitive Personal Data and KYC documentation;
• Role-based access controls ensuring that only authorised personnel can access Personal Data, and only to the extent necessary for their function;
• Multi-factor authentication for internal system access;
• Regular penetration testing and vulnerability assessments;
• Staff training on data protection and security protocols;
• Incident response and data breach notification procedures in compliance with applicable law.

No transmission of data over the internet is entirely secure. While we take all reasonable precautions, we cannot guarantee absolute security. If you suspect that your account has been compromised, please contact us immediately at [email protected].

The Platform may reference or integrate with third-party services in a contextual capacity — for example, payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are referenced as familiar Pakistani payment rails. Where you interact with such services, your data will be processed under their respective privacy policies, over which pk19 has no control.

We are not responsible for the privacy practices or content of any third-party services, platforms or websites. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of the Platform.

pk19 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations or operational requirements. Where material changes are made, we will notify registered users by email or by displaying a prominent notice on the Platform no less than seven (7) days prior to the change taking effect, unless an immediate update is required by law.

The "Last Updated" date at the top of this page indicates when the most recent version was published. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We recommend reviewing this page periodically to remain informed of any changes.

If you have any questions, concerns or requests in connection with this Privacy Policy — including requests to exercise your data rights — please contact us through the following channel:

If you are not satisfied with our response to a data-related complaint, you have the right to lodge a complaint with the competent supervisory authority in the jurisdiction governing our operations, as identified in our Terms & Conditions.