Privacy Policy — 75pak

1. Introduction

75pak ("we", "us", "our", "Platform") is committed to protecting and respecting the privacy of all individuals ("User", "you", "your") who register an Account, visit, browse or otherwise interact with the services available at https://75pak.cam and any related subdomains.

This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed. It is intended to meet the obligations of transparency required under applicable data protection frameworks. By creating an Account or continuing to use the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read in conjunction with our Terms & Conditions and our Responsible Gambling Policy, both of which form part of the overall agreement governing your use of the Platform.

2. Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person ("Data Subject"), including but not limited to name, email address, contact number, date of birth, residential address, financial information and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, restriction, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data. In this context, 75pak acts as Data Controller in respect of Account-holder data.
• "Data Processor" means any third party that Processes Personal Data on behalf of the Data Controller under a contractual arrangement.
• "KYC Data" means identity verification documents and information collected as part of Know Your Customer procedures, including government-issued identification, proof of address and source-of-funds documentation.
• "Cookies" means small text files stored on a User's device by a web browser that record information about User sessions, preferences and behaviour on the Platform.
• "Account" means the registered user profile created upon successful completion of the registration and verification process on the Platform.

3. Data Controller

75pak, operating the Platform at https://75pak.cam, acts as the Data Controller in respect of Personal Data collected from Users. All data processing activities described in this Policy are carried out by, or on behalf of, 75pak in accordance with this Policy and applicable data protection obligations.

For all data-related enquiries, including requests to exercise your rights under Section 12 of this Policy, please contact us using the details provided in Section 16 (Contact Us).

4. Personal Data We Collect

We collect Personal Data from you in the following circumstances and categories:

4.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, residential address, email address, contact phone number and chosen username when creating an Account.
• KYC Verification Data: Copies of government-issued photo ID (national identity card, passport or driving licence), proof of address documentation, and source-of-funds information where required by compliance obligations.
• Payment Data: Details necessary to process deposits and withdrawals. The specific data collected depends on the payment method used (for example, mobile wallet account numbers for Easypaisa or JazzCash transactions, bank account details for IBFT via HBL, UBL, Meezan Bank or Bank Alfalah, or cryptocurrency wallet addresses). We do not store full card numbers; card processing is handled by our payment processor partners.
• Support Communications: Content of any messages, emails or live chat conversations you initiate with our support team, including the nature of your query and any information you provide in the course of the exchange.
• Responsible Gambling Submissions: Information you provide when setting limits, requesting cooling-off periods or initiating self-exclusion, including stated reasons where provided voluntarily.

4.2 Data Collected Automatically

• Device and Technical Data: IP address, browser type and version, operating system, device type and screen resolution, time zone setting and geographic region derived from IP.
• Usage and Behavioural Data: Pages visited, time spent on pages, links clicked, betting and gaming activity (markets accessed, stakes placed, game sessions, wager history), deposit and withdrawal history, and Platform feature interaction logs.
• Session Data: Login and logout timestamps, session duration, and authentication events including failed login attempts.
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 8 of this Policy.

4.3 Data Received from Third Parties

• Identity Verification Providers: Confirmation results from KYC and anti-fraud verification services used to validate identity documents and check against sanctions or watchlists.
• Payment Processors: Transaction status, reference numbers and fraud screening outcomes from payment gateway partners.
• Fraud and Risk Detection Services: Risk scores and signals used to identify potentially fraudulent account activity.

4.4 Summary Table of Data Categories

5. Legal Basis for Processing

Where applicable data protection law requires a legal basis for Processing, we rely on one or more of the following:

• Contractual Necessity: Processing necessary to fulfil our obligations to you as an Account holder — including account creation, transaction processing, customer support and platform delivery.
• Legal Obligation: Processing required for compliance with applicable legal and regulatory requirements, including anti-money laundering (AML), know-your-customer (KYC) and counter-terrorism financing obligations under the laws of the operator's license jurisdiction.
• Legitimate Interests: Processing necessary for our legitimate interests, including fraud prevention, platform security, responsible gambling monitoring, business analytics and service improvement, where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific and informed consent, including consent to receive marketing communications (where applicable) and non-essential cookie placement.

6. How We Use Your Data

75pak uses Personal Data for the following purposes:

• Account Management: To register, maintain and administer your Account, including verifying your identity, processing KYC documentation and managing Account settings and preferences.
• Service Delivery: To provide access to sports betting markets (including PSL, ICC and other cricket fixtures), live casino games, slots, table games and all other Platform services.
• Transaction Processing: To process deposits and withdrawals through available payment methods, reconcile transactions and maintain accurate financial records for your Account.
• Responsible Gambling: To monitor betting patterns for indicators of problem gambling, enforce limits and restrictions you have set, and act on self-exclusion or cooling-off requests in accordance with our Responsible Gambling Policy.
• Compliance and Fraud Prevention: To verify user identity, screen against sanctions watchlists, detect and investigate fraudulent activity, money laundering or bonus abuse, and meet legal obligations under applicable law.
• Customer Support: To respond to enquiries, resolve account issues and handle complaints — in English and Urdu — through live chat and email channels.
• Security: To monitor for unauthorised access, secure accounts and detect and remediate technical vulnerabilities on the Platform.
• Analytics and Service Improvement: To analyse aggregated usage data to improve Platform performance, user experience and product development. Where possible, this analysis uses anonymised or pseudonymised data.
• Legal Proceedings: To establish, exercise or defend legal claims and to comply with court orders, regulatory investigations or law enforcement requests.

We do not use your Personal Data for automated decision-making that produces significant legal effects without human oversight, except where required by law or where you have given explicit consent to such processing.

7. Data Sharing & Disclosure

75pak does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly as necessary for the purposes described in this Policy:

• KYC and Identity Verification Providers: Third-party services used to verify the authenticity of identity documents and check against sanctions, PEP (Politically Exposed Persons) and adverse media databases.
• Payment Processors and Gateway Providers: Third parties who facilitate the technical processing of deposits and withdrawals. The data shared is limited to what is necessary to complete the specific transaction.
• Fraud Prevention and Risk Services: Providers of fraud detection, risk scoring and anti-money laundering monitoring tools who process data on our behalf under data processing agreements.
• IT Infrastructure and Hosting Providers: Cloud and server infrastructure providers who host Platform data. These providers are bound by contractual obligations to process data only on our instructions.
• Game and Technology Providers: Generic third-party studios and technology partners whose games or data feeds are integrated into the Platform. Data shared is limited to session identifiers and is governed by data processing agreements.
• Legal and Regulatory Authorities: Law enforcement agencies, courts, regulatory bodies or government authorities where we are required by law, court order or binding regulatory instruction to disclose Personal Data.
• Professional Advisors: Legal counsel, auditors and financial advisors subject to obligations of professional confidentiality.

All third-party Data Processors engaged by 75pak are required to implement appropriate technical and organisational security measures and to process Personal Data only in accordance with our documented instructions.

8. Cookies & Tracking Technologies

75pak uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate and improve the Platform. The categories of cookies used are described below:

• Strictly Necessary Cookies: Essential for the Platform to function, including session management, login authentication, security tokens and load balancing. These cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Used to remember your preferences — such as language settings and responsible gambling limit displays — to improve your experience across sessions.
• Analytics Cookies: Used to collect aggregated, anonymised information about how Users interact with the Platform, including pages visited, session duration and feature usage. This data is used to identify areas for improvement.
• Security Cookies: Used to detect fraudulent activity, authenticate users and protect against cross-site request forgery and other security threats.

You may control cookie settings through your browser preferences. Disabling strictly necessary cookies will impair Platform functionality. Disabling analytics or functional cookies will not prevent you from using the Platform but may affect your experience.

We do not use third-party advertising or behavioural targeting cookies that share your data with external advertising networks.

9. Data Retention

We retain Personal Data for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, compliance, audit and regulatory obligations. Our general retention approach is as follows:

• Active Account Data: Retained for the duration of the Account relationship and for a period thereafter as required by applicable AML, KYC and financial record-keeping obligations.
• KYC Documentation: Retained for the minimum period required under applicable anti-money laundering legislation in the operator's license jurisdiction — typically five (5) years from the end of the business relationship or last transaction.
• Transaction Records: Retained for the period required by applicable financial and gambling regulatory requirements, which may be up to seven (7) years.
• Support Communications: Retained for a period sufficient to resolve any related disputes or complaints, typically up to three (3) years.
• Self-Exclusion Records: Retained for the duration of the exclusion period and for a minimum period thereafter to prevent re-registration and to maintain an accurate responsible gambling history.
• Cookie and Analytics Data: Session cookies are deleted at the end of a browser session. Persistent cookie data is retained for the period set in the individual cookie configuration, typically no longer than twelve (12) months.

Once Personal Data is no longer required for its original purpose and retention period obligations have been satisfied, it is securely deleted or anonymised.

10. Data Security

75pak implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, disclosure, alteration, destruction or accidental loss. These measures include:

• Encryption of data in transit using TLS (Transport Layer Security) protocols;
• Encryption of sensitive data at rest using industry-standard encryption algorithms;
• Access controls and role-based permissions limiting staff access to Personal Data on a need-to-know basis;
• Multi-factor authentication requirements for internal system access;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures for the detection, containment and notification of data security incidents.

While we take reasonable steps to protect your data, no internet-based transmission or electronic storage method is completely secure. You are responsible for maintaining the security of your Account credentials and for reporting any suspected unauthorised access to the Platform support team promptly.

11. International Data Transfers

75pak may transfer Personal Data to, or store it in, locations outside your country of residence, including countries that may not have data protection laws equivalent to those in your jurisdiction. This may occur, for example, where we use third-party infrastructure, KYC verification or payment processing services hosted in other jurisdictions.

Where such transfers occur, we implement appropriate safeguards to protect your Personal Data, which may include standard contractual clauses, data processing agreements with appropriate security obligations, or transfers to jurisdictions that have been assessed as providing adequate data protection.

By using the Platform and providing your Personal Data, you acknowledge that your data may be transferred, processed and stored in jurisdictions outside Pakistan. If you have concerns about international data transfers, please contact us using the details in Section 16.

12. Your Rights

Subject to applicable law and the obligations of the Platform under relevant regulatory frameworks, you may have the following rights in relation to the Personal Data we hold about you:

To exercise any of these rights, please contact us using the details in Section 16. We will respond within a reasonable period. Note that exercising certain rights — such as erasure — may result in Account closure where retention of data is a mandatory legal or contractual requirement.

We may require you to verify your identity before processing a rights request to prevent unauthorised access to Personal Data.

13. Minors

The Platform is strictly intended for adults. 18+ You must be at least 18 years of age — or the higher minimum age required by the operator or the applicable license jurisdiction — to register an Account and use the Services.

75pak does not knowingly collect or process Personal Data from individuals under the applicable minimum age. Age verification is conducted as part of the KYC process for all Accounts. Where we become aware that Personal Data has been provided by a minor, we will promptly delete such data and close the associated Account in accordance with applicable procedures.

If you believe a minor may have created an Account on the Platform, please contact our support team immediately using the contact details in Section 16.

Local laws may impose a higher minimum age or may restrict gambling participation entirely. Users are responsible for complying with the laws applicable in their jurisdiction.

14. Third-Party Links & Services

The Platform may contain references to third-party services — such as payment processors, identity verification providers and game studios — whose own privacy policies govern the handling of any Personal Data they collect independently. 75pak is not responsible for the privacy practices of third-party services accessed outside of the Platform.

The mention of payment service names — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — throughout this Policy and on the Platform is for reference and user familiarity only. These providers operate independently under their own privacy policies and terms of service. Their mention does not imply any data-sharing relationship beyond what is strictly necessary for the processing of individual transactions where applicable.

We encourage Users to review the privacy policies of any third-party service they interact with, particularly payment providers through which they transact.

15. Amendments to This Policy

75pak reserves the right to update or revise this Privacy Policy at any time. Where changes are material — for example, changes to the categories of data collected, the purposes for which data is processed, or new categories of third-party sharing — we will endeavour to notify Users by email or by publishing a prominent notice on the Platform prior to the changes taking effect.

The "Last updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the Platform following any update constitutes your acknowledgement of the revised Policy. If you do not agree to the updated Policy, you should cease using the Platform and may request Account closure in accordance with the Terms & Conditions.

We recommend reviewing this Policy periodically to stay informed of how we protect your Personal Data.

16. Contact Us

For all data protection enquiries, rights requests, or privacy-related complaints regarding 75pak's handling of your Personal Data, please contact us using the details below. Our support team is available 24/7 in English and Urdu.

For responsible gambling support, including self-exclusion and limit management, please visit our Responsible Gambling page.

For full terms governing your use of the Platform, please review our Terms & Conditions.