paki11 Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") describes how paki11 ("we", "us", "our", the "Operator"), the operator of the online platform accessible at https://paki11.cam, collects, uses, stores, processes and protects the personal data of individuals ("Users", "you", "your") who access or use the paki11 platform, whether as registered account holders or as visitors.

By creating an account on paki11 or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not accept the terms of this Policy, you must not register an account or continue using the Platform.

This Policy is to be read alongside the paki11 Terms & Conditions, which govern the overall legal relationship between you and the Operator.

2. Definitions

The following terms carry the meanings assigned below throughout this Policy:

• "Personal Data" — any information that identifies or could reasonably identify a natural person, including name, email address, phone number, CNIC number, IP address and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission and deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data; in this context, the Operator of paki11.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller under a contractual arrangement.
• "Consent" — a freely given, specific, informed and unambiguous indication of the User's agreement to the processing of their Personal Data.
• "KYC Data" — identity verification documents and related information collected as part of the Know Your Customer process, including CNIC, passport scans and proof of address.
• "Cookies" — small text files placed on a User's device by the Platform to store session data, preferences and usage information.
• "Platform" — the paki11 website at https://paki11.cam and all associated mobile interfaces, APIs and services.

3. Data Controller

The Data Controller for Personal Data collected through the paki11 Platform is the Operator of paki11. Contact details for data-related enquiries are provided in Section 17 (Contact Us) of this Policy.

The Operator processes Personal Data in connection with the provision of the paki11 Platform and in accordance with the requirements of the operator's applicable license jurisdiction. The Operator may appoint Data Processors (third-party service providers) to carry out specific processing activities on its behalf, subject to appropriate contractual data protection obligations.

4. Data We Collect

paki11 collects the following categories of Personal Data, depending on how you interact with the Platform:

4.1 Registration Data

• Full legal name
• Date of birth (for age verification)
• Email address
• Mobile phone number
• Residential address (city, country — for example, Karachi, Lahore, Islamabad, Rawalpindi)
• Chosen username and password (password stored in hashed form only)
• Account currency preference (e.g., PKR)

4.2 KYC and Verification Data

• Copy of valid government-issued identity document (CNIC or passport)
• Proof of address documentation (where required)
• Selfie or liveness verification image
• Source-of-funds documentation (where required for AML compliance)

4.3 Financial Data

• Deposit and withdrawal transaction records
• Payment method identifiers (e.g., mobile wallet account references for Easypaisa, JazzCash or Raast, bank account references for HBL, UBL, Meezan Bank, Bank Alfalah transfers, or cryptocurrency wallet addresses where applicable)
• Transaction amounts and timestamps in PKR

* Payment provider names are referenced as illustrative identifiers only. paki11 does not represent that any listed payment provider endorses the Platform or gambling services.

4.4 Gameplay and Betting Data

• Bet placement history, stakes, outcomes and winnings
• Games accessed and session durations
• Bonus and promotion usage records
• Responsible gambling tool activations and limit settings

4.5 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system and browser version
• Session tokens and authentication logs
• Platform interaction logs and clickstream data

4.6 Communications Data

• Support ticket and live chat conversation records
• Email correspondence with the support team
• Survey responses and feedback submissions where provided voluntarily

5. How Data is Collected

paki11 collects Personal Data through the following means:

• Directly from you — when you register an account, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions.
• Automatically — through cookies, session tracking, server logs and similar technologies when you access and navigate the Platform.
• From third parties — from identity verification service providers used to validate KYC documents, from payment processors to confirm transaction status, and from fraud detection services used to monitor account activity.

6. Legal Basis for Processing

paki11 processes Personal Data on the following legal bases, depending on the nature of the processing activity:

7. How We Use Your Data

Personal Data collected by paki11 is used for the following purposes:

• To create, maintain and manage your Account on the Platform.
• To verify your identity and age in accordance with KYC requirements.
• To process deposits, withdrawals and related payment transactions.
• To detect, investigate and prevent fraud, money laundering, bonus abuse and prohibited conduct as defined in the Terms & Conditions.
• To comply with AML obligations, including source-of-funds checks for high-value transactions.
• To operate and enforce responsible gambling controls, including monitoring usage patterns for indicators of problem gambling and facilitating the application of self-exclusion or limit requests.
• To communicate with you regarding your Account, including security alerts, verification requests, withdrawal status updates and support responses.
• To send promotional communications and bonus offers where you have opted in to receive them. You may withdraw marketing consent at any time through your Account settings or by contacting support.
• To analyse Platform usage data (in anonymised or aggregated form where possible) to improve the performance, content and features of the Platform.
• To respond to regulatory requests, court orders or law enforcement enquiries where legally required.

8. Data Sharing & Disclosure

paki11 does not sell, rent or trade your Personal Data to third parties for their own commercial purposes. Personal Data may be disclosed to the following categories of recipients where necessary:

• Identity Verification Providers: Third-party KYC and identity verification services engaged to validate documents submitted during registration or account review.
• Payment Processors: Payment service providers and financial institutions engaged to process deposit and withdrawal transactions. This may include referencing payment account identifiers associated with services such as Easypaisa, JazzCash, Raast or banking institutions such as HBL, UBL, Meezan Bank or Bank Alfalah, solely for the purpose of processing transactions.
• Fraud & AML Services: Third-party fraud detection and anti-money laundering compliance services used to monitor Platform activity and screen against relevant watchlists.
• Technology Infrastructure Providers: Cloud hosting, platform software and security service providers engaged to operate the technical infrastructure of the Platform.
• Regulatory and Licensing Authorities: The operator's applicable gaming licensing authority, to whom certain user data may be reported as required under license conditions.
• Law Enforcement and Legal Authorities: Where required by a valid court order, law enforcement request or other legally binding obligation, Personal Data may be disclosed to the relevant authority.

All third parties with whom Personal Data is shared are required to handle such data in accordance with applicable data protection standards and are bound by appropriate contractual confidentiality obligations.

9. International Transfers of Personal Data

The paki11 Platform is operated by an entity in the operator's licensing jurisdiction, which may not be Pakistan. As a result, your Personal Data may be transferred to, stored in, and processed in countries outside Pakistan, including countries in which the Operator's infrastructure providers and service processors are located.

Where Personal Data is transferred internationally, paki11 takes reasonable steps to ensure that appropriate safeguards are in place, including contractual data protection clauses with receiving parties. By using the Platform, you acknowledge that your Personal Data may be transferred and processed internationally.

10. Data Retention

paki11 retains Personal Data for as long as is necessary for the purposes outlined in this Policy, or as required by applicable law and the operator's licensing obligations. In general terms:

• Account data is retained for the duration of your account's active status and for a period thereafter as required by the operator's licensing conditions and applicable AML record-keeping obligations.
• KYC and identity documents are retained for the period required under the operator's license jurisdiction AML record-keeping requirements, typically a minimum of five years from the date of submission or account closure, whichever is later.
• Transaction records are retained for the period required by the applicable license jurisdiction's financial record-keeping regulations.
• Support communications are retained for a period sufficient to resolve disputes and for quality-assurance purposes.
• Marketing consent records are retained until consent is withdrawn and for a reasonable period thereafter to demonstrate compliance.

When data is no longer required for any of the purposes above, paki11 will delete or anonymise it in a secure manner. You may request early deletion of certain data categories subject to the limitations described in Section 13 (Your Rights).

11. Data Security

paki11 implements technical and organisational measures designed to protect Personal Data against unauthorised access, accidental loss, destruction, alteration and unlawful processing. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between user devices and the Platform.
• Encrypted storage of sensitive data fields including passwords (stored as hashed values) and identity document data.
• Access controls limiting staff access to Personal Data to those with a documented need for access in connection with their role.
• Two-factor authentication options available to all registered Users for Account access.
• Regular security assessments and monitoring of the Platform infrastructure for vulnerabilities and anomalous activity.

Despite these measures, no data transmission or storage system can be guaranteed to be 100% secure. In the event of a data breach that is likely to result in a high risk to User rights, paki11 will take steps to notify affected Users in accordance with applicable requirements.

12. Cookies & Tracking Technologies

paki11 uses cookies and similar technologies (local storage, session tokens) to operate and improve the Platform. The following categories of cookies are used:

You can manage or delete cookies through your browser settings at any time. Disabling Essential Cookies will prevent the Platform from functioning correctly. Disabling other cookie categories may reduce the personalisation of your experience but will not prevent basic access to the Platform.

13. Your Rights

Subject to applicable law and the operator's licensing obligations, you have the following rights in relation to your Personal Data held by paki11:

To exercise any of the above rights, please submit a request through the Live Chat or Help Centre within your registered Account. paki11 will respond to verified requests within a reasonable period. Where a request cannot be fully accommodated — for example, due to legal retention obligations — paki11 will explain the reason.

14. Minors

The paki11 Platform is strictly for individuals aged 18 years or older — or the higher minimum age required by the operator's license jurisdiction. paki11 does not knowingly collect Personal Data from persons below the applicable minimum age.

Age verification is a mandatory step in the KYC process. Where paki11 identifies or has reason to believe that a registered User is below the minimum age requirement, the Account will be suspended immediately pending investigation, and any funds associated with the Account will be handled in accordance with the operator's under-age gambling procedures.

If you believe that a minor has registered an Account on paki11, please contact support immediately via the Live Chat or Help Centre within the Platform.

15. Third-Party Links

The paki11 Platform may contain references to third-party services (for example, payment providers or game software suppliers) in descriptive or informational contexts. paki11 is not responsible for the privacy practices of any third-party services that operate outside the paki11 Platform. This Policy applies solely to data collected and processed by paki11 through the Platform.

Users are encouraged to review the privacy policies of any third-party services they interact with in connection with their use of paki11, including payment provider apps or mobile wallets.

16. Changes to This Policy

paki11 reserves the right to update or amend this Privacy Policy at any time. The revised Policy will be published on the Platform with an updated review date at the top of the document. For material changes, paki11 will take reasonable steps to notify registered Users via email or in-platform notification in advance of the changes taking effect.

Continued use of the Platform following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not accept the changes, you should cease using the Platform and request Account closure through the support team.

17. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data, please contact paki11 through the following channels, all accessible within your registered Account:

• Live Chat: Available 24/7 through the Live Chat button in your Account portal. Recommended for urgent data queries.
• Help Centre: Self-service knowledge base accessible from your Account dashboard, covering data subject rights, cookie management and KYC procedures.
• Email Support: For formal data rights requests or complaints. The support email address is provided within your Account settings.

Support email (plain text — not a clickable link): [email protected]

paki11 does not publish external telephone numbers. All privacy-related enquiries must be submitted through the channels listed above. When submitting a data rights request, please provide sufficient information to allow us to verify your identity and locate your Account records.