Privacy Policy — How pkgems
Handles Your Personal Data

01 Introduction

This Privacy Policy ("Policy") is published by pkgems, operator of the website located at https://pkgems.cam ("Platform", "we", "us", "pkgems"). It governs the collection, processing, storage, transfer and deletion of personal data relating to individuals ("Users", "Players", "you") who access or use the Platform, including those located in Pakistan — in cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar — and Pakistani nationals accessing the Platform from abroad.

pkgems is committed to protecting the privacy and security of the personal data entrusted to us. We process personal data only where there is a lawful basis to do so, and only to the extent necessary for the stated purpose. This Policy explains your rights in relation to your personal data and how to exercise them.

By accessing the Platform or creating an Account, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms set out herein, you must not use the Platform.

02 Definitions

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

03 Data Controller

For the purposes of applicable data protection law, the Data Controller responsible for your personal data collected through the pkgems Platform is the legal entity operating the website at https://pkgems.cam.

If you have questions about how your personal data is processed, or wish to exercise any of your data rights, please contact our Privacy team using the details provided in Section 16 of this Policy.

04 Data We Collect

4.1 Data You Provide Directly

When you register an Account, complete KYC, contact support, or interact with Platform features, we may collect:

• Full legal name;
• Date of birth (for age verification purposes);
• Residential address, including city (e.g., Lahore, Karachi, Islamabad);
• Email address and contact telephone number;
• Government-issued identity document details (CNIC number, passport number);
• Payment method details necessary to process deposits and withdrawals — this may include references to wallet identifiers associated with services such as Easypaisa, JazzCash or Raast, or bank account details for HBL, UBL, Meezan Bank, Bank Alfalah and similar institutions. None of these providers has endorsed gambling services. Details are used solely for transaction processing and AML compliance;
• Correspondence and communications submitted to our support team.

4.2 Data Collected Automatically

When you use the Platform, certain technical data is collected automatically:

4.3 Data from Third Parties

We may receive personal data from third-party identity verification providers, payment processors and fraud-detection services as part of our KYC and AML obligations. Such data is processed solely for compliance and security purposes.

05 Legal Basis for Processing

pkgems processes personal data only where a lawful basis exists. The primary legal bases applicable to our processing activities are as follows:

06 How We Use Your Data

pkgems uses personal data for the following specific purposes:

1. Account Registration & Management — creating and maintaining your Player account, verifying your identity and age, and ensuring one account per person;
2. Transaction Processing — processing deposits and withdrawals in PKR or supported currencies, and communicating with payment service providers;
3. KYC & AML Compliance — verifying identity documents (CNIC, passport), monitoring transactions for suspicious activity, and meeting regulatory obligations;
4. Responsible Gambling — monitoring betting patterns for signs of problem gambling, enforcing deposit/loss/time limits, and communicating with Players who may need support;
5. Customer Support — responding to support enquiries, resolving disputes, and maintaining records of communications;
6. Platform Security — detecting and preventing fraud, account takeover, bot activity and other prohibited conduct;
7. Platform Improvement — analysing usage patterns to improve site performance, mobile experience and content relevance for Pakistani users;
8. Marketing Communications — where you have given consent, sending promotional emails regarding bonuses, new features or sports betting opportunities. You may opt out at any time.

07 Data Sharing & Disclosure

7.1 What We Share and With Whom

pkgems does not sell, rent or trade your personal data to any third party for their independent commercial purposes. Personal data may be shared with third parties only in the following circumstances:

• Payment Processors: Transaction data shared with payment service providers as necessary to process deposits and withdrawals. This may include data relevant to transactions processed through bank transfers or digital wallet services;
• Identity Verification Providers: Document data shared with KYC/AML service providers operating under contractual data processing agreements with pkgems;
• Technology Service Providers: Technical data shared with hosting, analytics and security providers under strict data processing agreements that prohibit independent use of the data;
• Legal & Regulatory Authorities: Data disclosed to law enforcement, regulatory bodies or courts where required by applicable law, court order or to protect the rights of pkgems and its users;
• Business Transfers: In the event of a merger, acquisition or sale of substantially all assets, personal data may be transferred as part of that transaction. Affected users will be notified in advance.

08 Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. They allow the website to remember information about your visit — such as your language preference, session state, and which pages you have viewed. Similar technologies include web beacons, pixel tags and local storage objects.

8.2 Categories of Cookies Used

You can manage cookie preferences through your browser settings. Note that disabling cookies other than strictly necessary ones may affect certain Platform features and your overall user experience.

09 Data Retention

pkgems retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active Account Data: Retained for the duration of the active account relationship and for a defined period following account closure, as required by AML and regulatory obligations (typically five to seven years);
• KYC Documentation: Retained for the period required under applicable AML regulations following the end of the account relationship. Documents are stored securely and access is restricted;
• Transaction Records: Retained in line with applicable financial record-keeping obligations;
• Support Communications: Retained for a reasonable operational period sufficient to resolve disputes and maintain quality records;
• Marketing Data: Retained until consent is withdrawn or the relevant campaign period concludes, whichever is sooner;
• Technical Logs: Retained for a limited operational period for security and fraud monitoring purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identified or identifiable individual.

10 Data Security

pkgems implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the Platform;
• Encryption at rest for sensitive data including identity documents and payment details;
• Role-based access controls restricting personal data access to authorised personnel with a genuine operational need;
• Regular security assessments and vulnerability testing;
• Intrusion detection and real-time activity monitoring;
• Staff training on data protection obligations and secure data handling procedures.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, pkgems will notify affected individuals without undue delay and take all reasonable steps to mitigate the impact of the breach.

11 International Data Transfers

pkgems may process or store personal data in countries outside of Pakistan. Where personal data is transferred to a jurisdiction that does not provide a level of data protection equivalent to that in the originating jurisdiction, pkgems will implement appropriate safeguards — such as standard contractual clauses, data processing agreements or other recognised transfer mechanisms — to ensure that your data continues to receive adequate protection.

By using the Platform, you acknowledge that your personal data may be transferred, stored and processed in countries outside Pakistan as described in this Policy.

12 Your Data Rights

Subject to applicable law, you have the following rights in relation to your personal data held by pkgems. These rights may be exercised by submitting a written request to the contact details provided in Section 16.

13 Minors & Age Policy

The pkgems Platform is strictly intended for users aged 18 years and over — or the higher minimum age required by the applicable operator or license jurisdiction. pkgems does not knowingly collect personal data from minors.

Where pkgems becomes aware that personal data has been collected from a person under the applicable minimum age, that data will be immediately and permanently deleted, the associated Account will be closed, and any funds in the Account will be handled in accordance with applicable regulatory guidance.

14 Third-Party Links & Services

The Platform may contain references to or contextual information about third-party services — including payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah. These are referenced for educational and contextual purposes only. pkgems has no control over the privacy practices of these third parties.

This Privacy Policy applies solely to data collected through the pkgems Platform. pkgems accepts no responsibility for the privacy or data practices of any third-party website, service or application. You should review the privacy policies of any third-party service you use independently.

15 Amendments to This Policy

pkgems reserves the right to update or replace this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or Platform functionality. Where changes are material, we will provide reasonable prior notice to registered Users via email or a prominent Platform notice before the revised Policy takes effect.

The "Last updated" date displayed at the top of this Policy and in the Table of Contents sidebar will always reflect the date of the most recent revision. Your continued use of the Platform following the effective date of any revised Policy constitutes your acknowledgement of the changes.

16 Contact & Complaints

For any questions, requests or concerns relating to this Privacy Policy or the processing of your personal data, please contact the pkgems Privacy team using the details below. All privacy-related enquiries will be responded to within 30 days. Support is available in both English and Urdu.

If you are not satisfied with our response to a privacy concern, you have the right to lodge a complaint with the relevant data protection authority or supervisory body in your jurisdiction. pkgems will cooperate fully with any investigation by a competent supervisory authority.

When contacting us regarding a data rights request, please include sufficient information for us to identify your Account and verify your identity. Do not send identity documents via unencrypted email — use the secure upload portal within your Account settings for all document submissions.