Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is published by 89pk ("we", "us", "our", "the Platform"), the operator of the website accessible at https://89pk.cam. It sets out in clear terms how 89pk collects, processes, stores, shares, and protects personal data submitted by users ("you", "your") of the Platform.

89pk is an English-language online gaming information platform targeted primarily at Pakistani users. We cover sports betting markets, casino game categories, responsible gambling resources, and platform guides. We are an information platform — not a gambling operator — and do not directly accept bets or deposits.

By accessing or using the 89pk Platform, you acknowledge that you have read, understood, and agree to the collection and use of your personal information as described in this Policy. If you do not agree with this Policy, please do not use the Platform.

2 Definitions

For the purposes of this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, IP address, device identifiers, and browsing behaviour.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — in this case, 89pk.
• "Data Processor" means a third party that processes personal data on behalf of 89pk under a data-processing agreement.
• "Consent" means a freely given, specific, informed, and unambiguous indication of agreement to the processing of personal data.
• "Cookies" means small text files placed on your device by the Platform to support functionality, session management, and analytics.
• "User" means any individual accessing or using the 89pk Platform.

3 Data Controller

For the purposes of this Policy, the Data Controller responsible for the personal data processed via the 89pk Platform is the operator of 89pk as identified at https://89pk.cam. Contact details for the Data Controller are set out in Section 14 of this Policy.

Where 89pk engages third-party service providers to process personal data on its behalf, those providers act as Data Processors and are bound by contractual data-processing agreements that restrict their use of personal data to the specific purpose for which it was shared.

4 Data We Collect

89pk collects personal data through different mechanisms depending on how you interact with the Platform:

4.1 Data You Provide Directly

• Account registration details: full name, date of birth, email address, username, and password.
• Identity verification documents submitted during KYC checks (e.g., national identity card, passport).
• Contact information provided when submitting a support request, including queries submitted from Pakistani cities such as Karachi, Lahore, Islamabad, Rawalpindi, Multan, Faisalabad, and Peshawar.
• Payment information sufficient to process transactions — note that full payment instrument details are handled by the relevant payment processor, not stored by 89pk.
• Preferences and settings you configure within your Account.

4.2 Data Collected Automatically

• IP address and approximate geolocation.
• Device type, operating system, browser type, and version.
• Pages visited, time on page, click-path data, and session duration.
• Referral source (how you arrived at the Platform).
• Cookies and similar tracking technology data (see Section 10).

4.3 Data From Third Parties

In limited circumstances, 89pk may receive personal data about you from third-party sources, including identity verification service providers, fraud-prevention services, and analytics platforms. Such data is used solely for the purposes described in this Policy.

5 Data Processing & Legal Basis

89pk processes personal data only where there is a lawful basis to do so. The table below summarises the primary purposes for which we process personal data and the corresponding legal basis:

6 Data Sharing

89pk does not sell personal data. We may share personal data with third parties only in the following defined circumstances:

• Service Providers (Data Processors): Third-party companies engaged to provide services on our behalf, including cloud hosting, email delivery, analytics, identity verification, fraud prevention, and customer support. All such providers are bound by contractual obligations consistent with this Policy.
• Legal and Regulatory Authorities: Where required by applicable law, court order, or regulatory obligation, 89pk may disclose personal data to competent authorities. This includes disclosures required under anti-money laundering legislation.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 89pk's assets, personal data held by 89pk may be transferred to the successor entity, subject to this Policy continuing to apply.
• With Your Explicit Consent: In circumstances not covered above, 89pk will seek your explicit consent before sharing your personal data with any third party.

At no point will 89pk share your personal data with third-party advertisers, data brokers, or marketing aggregators without your explicit and separate consent.

7 Data Retention

89pk retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship plus a post-closure period as required by applicable law (typically 5–7 years for financial and compliance records).
• KYC Documents: Retained for the period required by applicable anti-money laundering and identity verification regulations.
• Support Correspondence: Retained for up to 3 years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Analytics Data: Anonymised or aggregated usage data may be retained indefinitely as it is no longer attributable to an identifiable individual.
• Marketing Consent Records: Retained for as long as the marketing relationship continues, plus a reasonable period thereafter to demonstrate compliance.

When personal data is no longer required for its original purpose and no retention obligation applies, it is securely deleted or irreversibly anonymised.

8 Data Security

89pk takes the security of your personal data seriously and has implemented technical and organisational measures designed to protect it against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encrypted storage of sensitive personal data at rest.
• Role-based access controls limiting internal access to personal data to those with a genuine operational need.
• Regular security audits and vulnerability assessments.
• Incident response procedures for detecting and responding to personal data breaches.

While 89pk employs robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials and for notifying 89pk promptly if you suspect any unauthorised access to your Account.

9 User Rights

Subject to applicable law, you have the following rights with respect to your personal data held by 89pk. To exercise any of these rights, please contact us using the details in Section 14.

• Right of Access: Request confirmation of whether we process personal data about you and, if so, obtain a copy of that data along with supplementary information about how it is used.
• Right to Rectification: Request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data where it is no longer necessary, where consent has been withdrawn, or where processing is unlawful, subject to legal retention obligations that override this right.
• Right to Restriction of Processing: Request that processing of your personal data be restricted in certain defined circumstances.
• Right to Data Portability: Receive your personal data in a structured, commonly used, machine-readable format and transmit it to another controller, where technically feasible and where processing is based on consent or contract.
• Right to Object: Object to the processing of your personal data on grounds of legitimate interests, or for direct marketing purposes (in which case processing will cease immediately upon receipt of a valid objection).
• Right to Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time by contacting us. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: Lodge a complaint with the relevant data protection supervisory authority if you believe your rights under applicable data protection law have been infringed.

89pk will acknowledge data rights requests within a reasonable period and will aim to respond substantively within 30 days. Where requests are complex or numerous, we may extend this period by up to an additional 60 days, and will notify you accordingly.

10 Cookies & Tracking Technologies

89pk uses cookies and similar tracking technologies (including web beacons and local storage) to support the operation of the Platform and to improve the user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that maintain your login state and security cookies that prevent cross-site request forgery. These cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Remember your preferences and settings (such as language preference and display configuration) to provide a more personalised experience.
• Analytics Cookies: Collect anonymised information about how users interact with the Platform — pages visited, session duration, and navigation paths — to help 89pk understand usage patterns and improve content. Analytics data is aggregated and not attributable to individual users.
• Marketing Cookies: Used only where you have provided explicit consent to receive marketing communications. These track engagement with promotional content to allow us to tailor communications to your preferences.

10.1 Managing Cookie Preferences

You can manage or withdraw your consent to non-essential cookies at any time through your browser settings. Most modern browsers allow you to refuse, delete, or block cookies. Please note that disabling strictly necessary cookies may impair the functionality of the Platform. Instructions for managing cookies are available in the help documentation of your browser.

11 Minors

The 89pk Platform is strictly intended for adults aged 18 years or older — or the higher minimum required by the applicable operator or license jurisdiction. 89pk does not knowingly collect, process, or store personal data from individuals under the applicable minimum age.

If 89pk becomes aware that personal data has been submitted by a minor without appropriate consent, we will take immediate steps to delete that data and close any associated account. If you are a parent or guardian and believe your child has submitted personal data to 89pk, please contact us immediately using the details in Section 14.

Being 18 years of age or older does not by itself make online gambling lawful in Pakistan. Users are responsible for understanding and complying with applicable local law.

12 International Data Transfers

As an online platform, 89pk may process or store personal data in jurisdictions outside Pakistan. Where personal data is transferred internationally, 89pk ensures that appropriate safeguards are in place to protect that data in accordance with applicable data protection principles.

Safeguards may include contractual clauses binding recipient organisations to data protection standards consistent with those described in this Policy, or transfers to jurisdictions that provide an adequate level of data protection as recognised by relevant authorities.

By using the 89pk Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Pakistan where necessary for the delivery of Platform services.

13 Changes to This Policy

89pk reserves the right to amend, update, or replace this Privacy Policy at any time. When material changes are made, the updated Policy will be published on this page with a revised "Last Updated" date. Where technically feasible, registered users will be notified of material changes via their registered email address.

Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy, or if you wish to exercise any of your data rights described in Section 9, please contact 89pk using the following details:

The email address above is displayed as plain text only and is not a clickable link. All data rights requests and privacy enquiries submitted to this address will be handled confidentially and in accordance with this Policy. We aim to acknowledge all requests within 5 business days and to provide a substantive response within 30 days.

For issues relating to responsible gambling, please visit our dedicated Responsible Gambling page for immediate resources and tools.