Privacy Policy – pakbat Platform

1. Introduction

pakbat ("we", "us", "our", "the Company") operates the online betting and casino platform accessible at pakbat.com (the "Platform"). This Privacy Policy describes how we collect, process, store, and protect personal data provided by users ("you", "your") in connection with your use of the Platform.

By registering an account or using any part of the pakbat Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

pakbat takes data privacy seriously. We do not sell your personal data to third parties. We do not use your information for purposes beyond those described in this Policy. We apply industry-standard technical and organisational security measures to protect all data we hold about you.

2. Personal Data We Collect

pakbat collects personal data through your interactions with the Platform. The categories of data we collect include:

• Identity Data: Full name, date of birth, gender, and CNIC number, collected at registration for age verification and identity confirmation purposes.
• Contact Data: Pakistani mobile number, email address, and city of residence (e.g. Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan), used for account communications and regulatory compliance.
• Financial Data: Deposit and withdrawal transaction records, payment method identifiers (e.g. JazzCash mobile number, Easypaisa account, bank account numbers for HBL, UBL, Meezan Bank, Bank Alfalah). We do not store full banking credentials — payment processing is handled by certified payment processors.
• Technical Data: IP address, device type and operating system, browser type, session timestamps, and login activity logs, collected automatically when you access the Platform.
• Usage Data: Betting history, game play records, deposit and withdrawal history, bonus usage, and session duration data, generated by your activity on the Platform.
• Communications Data: Records of correspondence between you and pakbat support, including live chat transcripts and email exchanges.
• Responsible Gaming Data: Deposit limits, loss limits, self-exclusion requests, and session time settings you configure through your account.

We collect only the personal data that is necessary for the purposes identified in this Policy. We do not collect sensitive categories of personal data (such as health data, religious beliefs, or political opinions) except where directly relevant to a responsible gaming assessment and only with your explicit consent.

3. How We Use Your Personal Data

pakbat uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and securing your pakbat account, including verifying your identity and age at registration and upon request.
• Service Delivery: Processing bets, settling markets, processing deposits and withdrawals in PKR, and providing access to all Platform features including cricket betting, slots, and casino games.
• Regulatory Compliance: Meeting our obligations under applicable anti-money laundering, know-your-customer, and age verification regulations. This includes retaining transaction records and reporting obligations where required by law.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, unauthorised account access, money laundering, and other illegal conduct on the Platform.
• Responsible Gaming: Monitoring account behaviour to identify patterns that may indicate problem gambling, enforcing self-exclusions and limits you have set, and contacting you if responsible gaming concerns arise.
• Customer Support: Responding to your queries, complaints, and requests through live chat and email support channels.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve platform performance, identify technical issues, and develop new features that better serve Pakistani players.
• Marketing Communications: Sending you promotional offers, bonus notifications, and Platform updates, where you have provided consent and subject to your communication preferences. You may withdraw consent at any time through your account settings.

4. Legal Basis for Processing

pakbat processes your personal data on the following legal bases:

• Contractual Necessity: Processing necessary to provide you with the services described in the Terms & Conditions you have agreed to, including account management, bet settlement, and payment processing.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering regulations, age verification requirements, and tax reporting obligations.
• Legitimate Interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and internal analytics where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications, where we rely on your explicit consent. You retain the right to withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing and Disclosure

pakbat does not sell, rent, or trade your personal data to any third party. We may share your personal data in the following limited circumstances:

• Payment Processors: We share necessary financial data with our certified payment processing partners (including providers supporting JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah transactions) solely for the purpose of processing your deposits and withdrawals.
• Technology and Service Providers: We engage third-party providers for hosting, analytics, customer support tooling, and game content delivery. All providers are contractually bound to process your data only on our instructions and to maintain appropriate security standards.
• Regulatory and Law Enforcement Authorities: We may disclose personal data to relevant governmental authorities, regulators, or law enforcement agencies where required to do so by applicable law, court order, or in connection with the investigation of suspected fraud or criminal activity. We will notify you of such disclosures where legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of the Company's assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections. We will notify you of any such transfer.

In all cases of data sharing, pakbat requires recipients to maintain appropriate security and confidentiality obligations consistent with this Privacy Policy.

6. Cookies and Tracking Technologies

pakbat uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session, remembering your account preferences, and ensuring security. These cannot be disabled without significantly impairing your use of the Platform.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate and interact with the Platform. This data helps us identify performance issues and improve user experience. Analytics data is not linked to your personal identity.
• Preference Cookies: Used to remember settings you have configured, such as your preferred odds format (decimal, fractional, or Malay) and your default stake amount.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect Platform functionality. By continuing to use the Platform, you consent to our use of cookies as described in this section.

7. Data Retention

pakbat retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention periods:

• Account Data: Retained for the duration of your active account relationship with pakbat and for a period of five (5) years following account closure, in order to comply with anti-money laundering record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction in accordance with applicable financial regulations.
• Communications: Live chat and email correspondence retained for three (3) years for customer service quality and dispute resolution purposes.
• Marketing Consent Records: Retained for as long as your consent remains active, and for one (1) year following withdrawal of consent to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

8. Data Security

pakbat employs comprehensive technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the pakbat Platform.
• Encryption of sensitive data fields (including payment identifiers and identity document numbers) at rest in our databases.
• Role-based access controls ensuring that Platform staff can only access personal data necessary for their specific function.
• Regular security assessments, penetration testing, and vulnerability scanning of Platform infrastructure.
• Incident response procedures to detect, investigate, and respond to data security breaches, including notification procedures where required by applicable law.

While we implement robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account password and for using strong, unique credentials. Do not share your pakbat password with any third party, including individuals claiming to be pakbat support staff.

9. Your Data Rights

Subject to applicable law, you have the following rights in relation to the personal data pakbat holds about you:

• Right of Access: You may request a copy of the personal data pakbat holds about you. We will respond to verified access requests within thirty (30) days.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held in your account. You can update most information directly through the account settings panel.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Note that data subject to mandatory anti-money laundering retention periods cannot be deleted before those periods expire.
• Right to Restrict Processing: You may request that we restrict processing of your data in certain circumstances, for example while a correction request is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity, you may request a copy of your data in a structured, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (such as for marketing communications), you may withdraw consent at any time through your account settings or by contacting [email protected].

To exercise any of the above rights, please contact us at [email protected] with the subject line "Data Rights Request" and your registered account mobile number. We may need to verify your identity before processing your request.

10. Children's Privacy

The pakbat Platform is strictly intended for users aged 18 and above. We do not knowingly collect personal data from anyone under the age of 18. Age verification via CNIC is a mandatory step in the registration process, and registration cannot be completed without confirming that the user meets the minimum age requirement.

If we become aware that personal data has been collected from a person under the age of 18, we will immediately close the relevant account, void any transactions, return any funds to the original payment source, and delete the associated personal data from our systems. If you believe that a minor has registered on the Platform, please contact us immediately at [email protected].

11. Third-Party Links

The pakbat Platform does not contain links to third-party websites. All navigation links on the Platform direct to pages within the pakbat domain. This Privacy Policy applies solely to data collected and processed by pakbat in connection with its own Platform.

12. Changes to This Privacy Policy

pakbat reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. The "Last Updated" date at the top of this Policy indicates when the most recent revision was made.

Where changes are material, we will notify you via email to your registered address or through an in-platform notification prior to the changes taking effect. Your continued use of the Platform following notification of changes constitutes your acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or the way pakbat handles your personal data, please contact our data protection team: