Privacy Policy — 67pk

67pk ("we", "us", "our") operates the online gaming information platform at https://67pk.cam (the "Platform"). We are committed to protecting the privacy and personal data of all individuals who access or use the Platform ("you", "your", "User").

This Privacy Policy ("Policy") sets out, in formal legal-register terms, how 67pk collects, processes, stores, shares and protects personal data obtained through the Platform. It also describes the rights you hold in respect of that data and how you can exercise them.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform generally. By accessing or using the Platform, you acknowledge that you have read and understood this Policy and consent to data processing as described herein.

For the purposes of this Policy, the following terms carry the meanings given 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.
• "Processing" — any operation performed on Personal Data, including collection, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. For this Platform, the Data Controller is 67pk.
• "Data Processor" — a third party that Processes Personal Data on behalf of the Data Controller, pursuant to written instructions.
• "Cookies" — small text files placed on your device by the Platform to store and retrieve session or preference information.
• "Consent" — freely given, specific, informed and unambiguous agreement to the Processing of your Personal Data for a defined purpose.
• "Applicable Law" — all legislation, regulations and codes of practice applicable to data protection in the relevant jurisdiction, including but not limited to internationally recognised data protection principles.
• "Platform" — the 67pk website at https://67pk.cam and all associated pages, subdomains and services.
• "Third Party" — any entity other than you and 67pk, including analytics providers, hosting services and infrastructure partners.

This Policy applies to all Personal Data collected from Users who access the Platform from any location, including Pakistan and other jurisdictions. It covers data collected through the Platform's web interface, any contact forms, support channels and cookie-based analytics technologies.

Data Controller: 67pk is the Data Controller for all Personal Data Processed through this Platform. All data protection enquiries should be directed to our contact address set out in Section 15.

This Policy does not apply to data collected by third-party gaming operators, payment providers or other external platforms that you may access through information or references on this Platform. Those entities operate their own independent privacy policies, and 67pk has no control over or responsibility for their data practices.

We collect the following categories of Personal Data:

4.1 Data You Provide Directly

• Contact and enquiry data: If you contact us via our support email address, we collect your name (if provided), email address, and the content of your message.
• Preference data: Any preferences or settings you communicate to us through support channels.

4.2 Data Collected Automatically

• Usage data: Pages visited, time spent on pages, navigation paths, search queries within the Platform, buttons clicked and other interaction data.
• Device and technical data: IP address, browser type and version, operating system, device type (mobile, tablet, desktop), screen resolution, language settings and referring URL.
• Session data: Session identifiers, login timestamps (where applicable) and authentication tokens.
• Cookie data: Data stored via cookies and similar technologies as described in Section 7.

4.3 Data We Do Not Collect

67pk does not collect, process or store the following categories of data through this Platform:

• Financial data, payment card details, bank account numbers or cryptocurrency wallet addresses;
• Government-issued identity document numbers, CNIC details or passport numbers;
• Biometric data;
• Health or medical data;
• Gambling transaction history or betting records (as 67pk is not a gambling operator).

We collect Personal Data through the following methods:

• Direct communication: When you email our support address, submit a query or otherwise contact us directly.
• Automated technical collection: When you access the Platform, our servers and analytics tools automatically record technical and usage data as described in Section 4.2.
• Cookies and tracking technologies: As set out in Section 7, cookies placed on your device collect session and preference data.
• Third-party analytics: We may use third-party analytics services to aggregate and analyse Platform usage data. These services may collect IP addresses and usage patterns subject to their own privacy policies.

We process Personal Data only for specific, legitimate purposes. The table below summarises our Processing activities, their purposes and the legal bases on which we rely:

We do not use your Personal Data for automated profiling that produces significant legal effects, nor do we use it for the purpose of targeting gambling advertising at you specifically.

67pk uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small data files stored on your device that help the Platform remember your preferences and understand how you interact with our content.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. They enable core features such as page navigation and security. These cookies do not require your consent.
• Analytics Cookies: Help us understand how visitors interact with the Platform by collecting aggregated, anonymised usage data. These cookies are only placed with your consent where required by applicable law.
• Preference Cookies: Remember your language preferences and display settings to improve your experience on subsequent visits.

7.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies or receive a warning when a cookie is being placed. Please note that disabling certain cookies may affect the functionality of the Platform.

For detailed guidance on managing cookies in common browsers, please consult your browser's help documentation. We do not currently respond to browser "Do Not Track" signals, though we respect other opt-out mechanisms described in this Policy.

67pk does not sell, rent or trade your Personal Data to third parties for commercial purposes. We may share Personal Data only in the following limited circumstances:

8.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process Personal Data on our behalf, under binding data processing agreements, for purposes including:

• Web hosting and infrastructure services;
• Analytics platforms for aggregated usage reporting;
• Content delivery networks (CDNs);
• Email communication services for support responses.

These providers may only process your data in accordance with our documented instructions and are contractually prohibited from using it for their own independent purposes.

8.2 Legal Obligations

We may disclose Personal Data where required to do so by applicable law, regulation, court order or lawful request from a competent governmental or regulatory authority, provided such request is made in accordance with due legal process.

8.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of 67pk's business, Personal Data held by us may be transferred to the successor entity, subject to the same protections as described in this Policy. We will notify Users of any material change to data controller identity as required by applicable law.

8.4 No Sharing with Pakistani Financial Institutions or Government Bodies

67pk does not share User data with the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any Pakistani financial institution including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah, except where compelled by a valid and lawful legal process.

Subject to applicable law, you hold the following rights in respect of your Personal Data processed by 67pk. You may exercise any of these rights by contacting us using the details in Section 15. We will acknowledge your request within five (5) business days and aim to fulfil it within thirty (30) calendar days, subject to the complexity of the request.

1. Right of Access (Subject Access): You have the right to request confirmation of whether we process your Personal Data and, if so, to receive a copy of that data along with information about how it is processed.
2. Right to Rectification: You have the right to request correction of inaccurate Personal Data or completion of incomplete Personal Data held by us.
3. Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of your Personal Data where: (a) the data is no longer necessary for the purposes for which it was collected; (b) you withdraw consent on which Processing was based; (c) you object to Processing and there is no overriding legitimate ground; or (d) the data was unlawfully processed.
4. Right to Restriction of Processing: You have the right to request that we restrict Processing of your Personal Data in certain circumstances, such as while the accuracy of the data is contested.
5. Right to Data Portability: Where Processing is based on consent or contract and carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format.
6. Right to Object: You have the right to object to Processing of your Personal Data carried out on the basis of legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease Processing immediately.
7. Rights Related to Automated Decision-Making: You have the right not to be subject to decisions based solely on automated Processing, including profiling, that produce legal or similarly significant effects on you.
8. Right to Withdraw Consent: Where Processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of Processing carried out prior to withdrawal.
9. Right to Lodge a Complaint: You have the right to lodge a complaint with the competent supervisory authority in your jurisdiction if you believe that our Processing of your Personal Data infringes applicable data protection law.

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. The following general retention principles apply:

• Support and enquiry data: Retained for a reasonable period necessary to handle the relevant enquiry and related follow-up, typically not exceeding 24 months from last contact, unless a longer period is required by applicable law.
• Analytics and usage data: Retained in aggregated or anonymised form for ongoing Platform improvement purposes. Identifiable usage data is retained for no longer than 14 months in standard analytics configurations.
• Cookie data: Session cookies expire when you close your browser. Persistent cookies expire at the point indicated in the cookie's expiry setting, which varies by cookie type.
• Legal compliance data: Retained for the minimum period required by applicable law, which may exceed the above timeframes.

Upon expiry of applicable retention periods, Personal Data is securely deleted or anonymised so that it can no longer be associated with any individual.

67pk implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include, but are not limited to:

• HTTPS encryption across all Platform pages to protect data in transit;
• Access controls limiting Personal Data access to authorised personnel only, on a need-to-know basis;
• Regular security assessments and review of data processing practices;
• Secure server infrastructure with industry-standard hosting security configurations;
• Data minimisation practices limiting the volume of Personal Data collected and retained.

While we take reasonable precautions to protect your data, no internet transmission or electronic storage method is completely secure. We cannot guarantee absolute security and are not liable for security breaches beyond our reasonable control. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify affected users in accordance with applicable law.

The Platform is intended exclusively for adults aged 18 years and over, or the higher minimum age required by the applicable operator or licence jurisdiction. 67pk does not knowingly collect Personal Data from individuals under the age of 18.

If we become aware that we have inadvertently collected Personal Data from a minor, we will take prompt steps to delete that data from our records. If you are a parent or guardian and believe that your child has provided Personal Data to us, please contact us immediately using the details in Section 15.

We do not produce content designed to attract or appeal to minors, and we do not target advertising or marketing material at individuals under the age of 18.

67pk's Platform infrastructure and service providers may be located in jurisdictions outside Pakistan. If your Personal Data is transferred to or processed in a country that does not provide a level of data protection equivalent to the applicable standards in your jurisdiction, we will ensure that appropriate safeguards are in place.

Such safeguards may include standard contractual clauses approved by relevant data protection authorities, adequacy decisions, binding corporate rules or other legally recognised mechanisms. By using the Platform, you acknowledge that your data may be processed in countries outside your own jurisdiction, including where data protection laws differ from those in Pakistan.

67pk reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or operational requirements. When we make material changes, we will update the "Last Updated" date displayed at the top of this document.

For significant changes that materially affect how we process your data, we may also provide more prominent notice on the Platform. It is your responsibility to review this Policy periodically. Your continued use of the Platform following any update constitutes your acceptance of the revised Policy.

If you do not agree to any revised version of this Policy, you must immediately cease using the Platform.

For any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data by 67pk, please contact us using the details below. We aim to acknowledge all privacy-related enquiries within five (5) business days.

When submitting a data access, rectification or erasure request, please provide sufficient information to allow us to identify the data concerned and verify your identity. We may request additional verification steps to protect your security and the security of other users' data.

You also have the right to escalate any unresolved data protection concern to the competent supervisory authority in your jurisdiction. For users in Pakistan, this may include contacting the relevant authority responsible for data protection matters in Pakistan, as such authority or framework is established under Pakistani law.