Privacy Policy — pk47 Data Protection Statement

This Privacy Policy ("Policy") is published by pk47 ("pk47", "we", "us" or "our") and governs the collection, processing, storage and transfer of personal data relating to users ("you" or "User") of the website located at https://pk47.cam and all associated pages and features (the "Platform").

pk47 is an independent, English-language information and review platform serving Pakistani players and others interested in online sports betting and casino gaming. We do not operate as a gambling platform, accept bets or process any financial transactions. Our role is purely informational and educational.

By accessing or using the Platform, you acknowledge that you have read this Policy and consent to the collection and use of your data as described herein. If you do not agree to this Policy, you must stop using the Platform immediately.

In this Policy, the following terms have the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers and browsing behaviour on the Platform.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" — pk47, the entity that determines the purposes and means of Processing Personal Data collected via the Platform.
• "Third-Party Service Provider" — any external service provider engaged by pk47 to assist in operating the Platform, such as web analytics services, hosting providers or content delivery networks.
• "Cookies" — small text files placed on a User's device by the Platform for the purposes described in Section 6 of this Policy.
• "Applicable Law" — all laws and regulations applicable to the processing of Personal Data, including those of the jurisdiction in which pk47 is registered and any mandatory data protection laws applicable in the User's location.

3.1   Data collected automatically. When you access the Platform, we and our Third-Party Service Providers may automatically collect certain technical data, including:

• Internet Protocol (IP) address and approximate geographic location derived from it;
• Browser type, version and language settings;
• Operating system and device type;
• Pages visited, time spent on each page and navigation path through the Platform;
• Referring URL (the page from which you arrived at the Platform);
• Date and time of each visit.

3.2   Data provided voluntarily. If you contact us by email or through any inquiry form on the Platform, we collect the information you submit, which may include your name, email address and the content of your message.

3.3   Cookie data. Cookies and similar technologies may be used to collect data about your interactions with the Platform. Please refer to Section 6 for full details.

3.4   Data we do not collect. pk47 does not collect payment card details, bank account information, CNIC numbers, passwords or any sensitive financial data. We do not operate account registration on the Platform.

4.1   pk47 uses the data collected for the following purposes:

• Platform operation and delivery — to serve the Platform's pages and content to your device correctly and efficiently;
• Analytics and performance — to understand how Users interact with the Platform, identify popular content, detect technical errors and improve the overall user experience;
• Security and fraud prevention — to detect, investigate and prevent unauthorised access, malicious traffic, abuse or other security incidents;
• Communications — to respond to enquiries submitted by Users via email or through inquiry forms on the Platform;
• Legal compliance — to comply with Applicable Law, including obligations to retain certain records and to respond to lawful requests from competent authorities;
• Platform improvement — to test new content formats, layouts and features and to make informed editorial decisions about the coverage on pk47.

4.2   pk47 does not use Personal Data for the following purposes:

• Selling, renting or trading data to third parties;
• Targeted advertising or behavioural profiling;
• Automated decision-making that produces legal or similarly significant effects on any User.

5.1   To the extent that data protection legislation requiring a legal basis for Processing applies (for example, where a User is located in a jurisdiction with applicable data protection laws), pk47 processes Personal Data on the following bases:

• Legitimate interests — for analytics, Platform security, fraud prevention and improvement of Platform content, where such interests are not overridden by the rights and interests of the User;
• Consent — where we have obtained your consent for the placement of non-essential cookies or other optional data processing activities;
• Contractual necessity — where processing is necessary to respond to an inquiry or request submitted by the User;
• Legal obligation — where processing is required to comply with a legal requirement applicable to pk47.

5.2   Where processing is based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

6.1   The Platform may use cookies and similar tracking technologies (such as web beacons and pixels) to collect usage data, support platform functionality and facilitate analytics. Cookies are small text files stored on your device.

6.2   The types of cookies that may be used on the Platform include:

• Strictly necessary cookies — required for the Platform to function. These cannot be disabled without affecting core functionality.
• Analytics cookies — collect aggregated, anonymised data about how Users interact with the Platform (e.g., page views, session duration, traffic sources). This data helps us improve the Platform.
• Preference cookies — remember choices you have made (such as language or display preferences) to provide a more personalised experience.

6.3   You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies or be notified when a cookie is being set. Disabling certain cookies may affect the functionality of the Platform.

6.4   Third-Party Service Providers engaged by pk47 (such as web analytics providers) may place their own cookies on your device. pk47 does not control the cookie practices of such providers. Please refer to the respective provider's privacy documentation for details.

7.1   pk47 does not sell, rent, trade or otherwise transfer Personal Data to third parties for commercial gain. We may share data only in the following limited circumstances:

• Third-Party Service Providers — We engage service providers to assist with hosting, content delivery, analytics and platform maintenance. Such providers may process data on our behalf under contractual data-processing obligations that restrict their use of that data to the purposes for which it was shared.
• Legal requirements — We may disclose data where required by law, court order or lawful request from a competent government or regulatory authority.
• Protection of rights — We may disclose data where we reasonably believe disclosure is necessary to protect the rights, property or safety of pk47, its users or the public, or to detect and prevent fraud or security incidents.
• Business transfers — In the event of a merger, acquisition or sale of all or part of pk47's assets, Personal Data may be transferred as part of that transaction. Users will be notified of any such transfer via a prominent notice on the Platform.

7.2   Where data is shared with service providers, we require those providers to handle data in a manner consistent with this Policy and Applicable Law, and specifically to refrain from using it for their own commercial purposes.

8.1   pk47 retains Personal Data for no longer than is necessary to fulfil the purposes for which it was collected, taking into account applicable legal retention obligations and legitimate operational needs.

8.2   As a general guide, our retention approach is as follows:

• Analytics and log data — typically retained in aggregated or anonymised form for up to 26 months, after which individual session data is deleted or anonymised.
• Enquiry and correspondence data — retained for as long as necessary to handle the enquiry and for a reasonable period thereafter to manage any follow-up, generally not exceeding two years from last contact.
• Legally required records — retained for the period required by the applicable law mandating retention.

8.3   When data is no longer required, we delete or irreversibly anonymise it using secure methods appropriate to the sensitivity of the data.

9.1   Depending on the data protection laws applicable in your jurisdiction, you may have some or all of the following rights in relation to your Personal Data:

9.2   To exercise any of the above rights, please contact us using the details set out in Section 14 of this Policy. We will respond to all valid requests within a reasonable timeframe and in any event within the period required by Applicable Law.

9.3   We may need to verify your identity before processing a rights request. We will not charge a fee for handling a rights request unless the request is manifestly unfounded or excessive.

10.1   pk47 implements technical and organisational security measures designed to protect Personal Data against unauthorised access, accidental loss, alteration or disclosure. Measures in place include:

• HTTPS/TLS encryption for all data transmitted between your device and the Platform;
• Restricted access to Personal Data limited to personnel with a legitimate operational need;
• Regular review of security practices and infrastructure;
• Contractual security obligations imposed on Third-Party Service Providers who process data on our behalf.

10.2   Notwithstanding the above, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security and we disclaim liability for breaches that occur despite reasonable security measures being in place.

10.3   In the event of a data security incident that is likely to result in a high risk to the rights and freedoms of Users, we will notify affected Users in accordance with the requirements of Applicable Law.

11.1   The pk47 Platform is strictly intended for adults aged 18 or older, or the higher minimum age required under Applicable Law in the User's jurisdiction. The Platform describes gambling products and services that are age-restricted, and persons under the applicable minimum age must not use this Platform.

11.2   pk47 does not knowingly collect Personal Data from persons under the applicable minimum age. If we become aware that we have inadvertently collected data from a minor, we will take prompt steps to delete that data.

11.3   If you believe that a minor has accessed the Platform or submitted Personal Data to pk47, please notify us immediately using the contact details in Section 14.

12.1   pk47 is an English-language platform designed primarily for Pakistani users. If you are accessing the Platform from Pakistan, the following additional information is relevant to you.

12.2   Payment service references. The Platform may reference payment services including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah as contextual examples of services familiar in Pakistan. Such references do not constitute a data-sharing relationship with those institutions. pk47 does not share your Personal Data with any of those payment service providers.

12.3   Local data protection law. Pakistan's data protection framework continues to develop. To the extent that Pakistani law imposes requirements on the processing of data relating to Pakistani residents, pk47 aims to comply with those requirements. This Policy will be updated as the regulatory framework evolves.

12.4   International data transfers. As an online platform, data processed in connection with your use of pk47 may be transferred to and stored on servers located outside Pakistan. We take reasonable steps to ensure that such transfers are handled in a manner consistent with the protections described in this Policy.

13.1   pk47 reserves the right to update or amend this Privacy Policy at any time. Any changes will be posted on this page with a revised "Last Updated" date. Where changes are material, we may draw them to Users' attention via a prominent notice on the Platform.

13.2   Your continued use of the Platform following the posting of any revision to this Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically.

If you have any questions, concerns or requests relating to this Privacy Policy or the way in which pk47 handles your Personal Data — including requests to exercise your data subject rights under Section 9 — please contact us using the details below.

We will acknowledge receipt of your enquiry promptly and provide a substantive response within a reasonable period, and in any case within any timeframe required by Applicable Law.