PKR11 Privacy Policy

Introduction

This Privacy Policy (hereinafter "Policy") is issued by PKR11, the operator of the online casino and sports betting platform accessible at pkr11.cam (hereinafter "the Platform", "we", "us" or "our"). This Policy applies to all users who access or interact with the Platform, including users based in Pakistan and other jurisdictions.

PKR11 is an English-language platform serving Pakistani users and international audiences. We recognise the significance of personal data protection and are committed to handling your information responsibly, transparently and in accordance with the data protection standards applicable under our operating licence and international best practice.

This Policy should be read in conjunction with our Terms & Conditions and Responsible Gambling Policy, both of which are published on the Platform and incorporated herein by reference. By accessing the Platform, registering an account, making a deposit or otherwise using any of our services, you acknowledge that you have read and understood this Policy.

Definitions

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

• "Personal Data" — any information relating to an identified or identifiable natural person ("data subject"), including but not limited to name, email address, postal address, phone number, date of birth, national identity number, financial information and device identifiers.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the Platform, PKR11 is the Data Controller.
• "Data Processor" — a third party that processes Personal Data on behalf of PKR11 under a data processing agreement.
• "User" / "you" — any individual who accesses, registers for, or otherwise uses the Platform.
• "Cookies" — small text files placed on your device by the Platform or third-party service providers to store session preferences, analytics data and similar information.
• "KYC" — Know Your Customer — the identity and age verification process required under applicable licensing and AML obligations.
• "AML" — Anti-Money Laundering — legal and regulatory obligations governing the detection and prevention of money laundering and terrorist financing.

Data Controller

PKR11 acts as the Data Controller in respect of all Personal Data collected and processed through the Platform. As Data Controller, PKR11 determines the purposes for which your Personal Data is collected and the manner in which it is processed.

Where PKR11 engages third-party service providers to process Personal Data on its behalf — including payment processors, identity verification providers, customer support software vendors and analytics platforms — those parties act as Data Processors. PKR11 requires all Data Processors to process Personal Data only in accordance with documented instructions, to implement appropriate security measures and to enter into data processing agreements that comply with applicable data protection standards.

Data We Collect

PKR11 collects Personal Data in the following categories:

4.1 Registration & Account Data

When you create an account, we collect your full name, email address, date of birth, username, password (stored in hashed form) and your country of residence. For Pakistani users, your preferred currency (PKR) and time zone settings are recorded.

4.2 Identity Verification (KYC) Data

To comply with our licensing and AML obligations, we may collect copies of identity documents — such as a Pakistani CNIC (Computerised National Identity Card) or passport — proof of address, and biometric liveness check data. This data is processed exclusively for verification and fraud-prevention purposes.

4.3 Financial & Transaction Data

We record deposit and withdrawal transactions, payment method references and transaction identifiers. We do not store full payment card numbers or full mobile wallet credentials. Payment references — such as those relating to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — are stored as reference identifiers only and do not imply any affiliation between those institutions and PKR11.

4.4 Gameplay & Betting Activity

We log wager history, game session data, bet amounts, outcomes, bonus redemptions and responsible gambling tool configurations. This data is necessary for account management, dispute resolution and regulatory compliance.

4.5 Technical & Device Data

We automatically collect IP addresses, browser type and version, operating system, device identifiers, screen resolution, referring URLs and session timestamps. This data is used for security monitoring, platform optimisation and fraud detection.

4.6 Communications Data

We retain records of communications you send to our support team via email or live chat, including the content of those communications, for quality assurance, dispute resolution and regulatory audit purposes.

Legal Basis for Processing

PKR11 processes your Personal Data on the following legal bases:

How We Use Your Data

PKR11 uses the Personal Data we collect for the following purposes:

• To create, verify and administer your Account and provide access to Platform services.
• To verify your identity and age in accordance with our KYC obligations, and to ensure that you meet the minimum age requirement of 18 years or the higher minimum required by our licence jurisdiction.
• To process your deposits and withdrawals and to maintain accurate financial records.
• To detect, investigate and prevent fraud, collusion, money laundering, and other forms of prohibited conduct.
• To personalise your experience on the Platform — for example by surfacing cricket betting markets relevant to Pakistan during PSL fixtures or ICC events.
• To deliver customer support and respond to your queries, complaints and disputes.
• To send you account-related transactional communications, including deposit confirmations, withdrawal updates and security alerts.
• To send you marketing communications about promotions, bonuses and Platform updates, where you have consented to receive such communications.
• To monitor gameplay patterns for responsible gambling purposes and to enforce deposit limits, loss limits and self-exclusion requests.
• To comply with our legal obligations under applicable licensing, AML and data protection regulations.
• To improve the Platform's performance, identify and fix technical issues, and develop new features.

PKR11 does not use your Personal Data to make solely automated decisions that produce legal or similarly significant effects without providing you with an opportunity for human review.

Cookies & Tracking Technologies

PKR11 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your browser or device when you visit the Platform.

Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, load-balancing cookies and security tokens. These cannot be disabled without breaking core Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised statistical data about how users interact with the Platform — pages visited, time on site, error events. This data helps us improve Platform performance.
• Functional Cookies: Used to remember your preferences such as language settings, currency display (PKR) and responsible gambling configuration.
• Marketing Cookies: Used to deliver relevant promotional content and to measure the effectiveness of our advertising campaigns. These are only set where you have provided your consent.

You may manage or disable non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the Platform. Strictly necessary cookies cannot be disabled without preventing you from logging in or using the Platform.

Data Sharing & Disclosure

PKR11 does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We share Personal Data only in the following circumstances and to the minimum extent necessary:

• Identity Verification Providers: We share KYC data (identity documents, liveness check results) with regulated third-party identity verification service providers for the purpose of verifying your identity and age.
• Payment Processors: We share transaction data with payment service providers to facilitate deposits and withdrawals. These providers are subject to their own data protection obligations. Familiar payment references for Pakistani users — such as those associated with Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — may appear in transaction records; their inclusion does not imply those institutions' endorsement of or affiliation with PKR11.
• Technology & Infrastructure Providers: We engage cloud hosting providers, CDN services and platform infrastructure vendors. These providers process data only in accordance with our instructions and under contractual data processing obligations.
• Customer Support Platforms: Support communications may be processed by third-party helpdesk software providers under data processing agreements.
• Regulatory & Law Enforcement Authorities: We will disclose Personal Data to licensing authorities, financial intelligence units, law enforcement agencies or courts where required to do so by law, regulatory obligation or valid legal process.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of our business, Personal Data may be transferred to the acquiring entity. We will notify active account holders of any such transfer and the resulting changes to data processing arrangements.

International Data Transfers

PKR11 is an international platform and your Personal Data may be transferred to and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where such transfers occur, PKR11 takes appropriate steps to ensure that your Personal Data is adequately protected. These steps may include reliance on standard contractual clauses approved by applicable data protection authorities, adequacy decisions, or other lawful transfer mechanisms recognised under the applicable regulatory framework.

Users in Pakistan should be aware that Pakistan has its own evolving data protection framework. PKR11 processes data in accordance with international best practice and the standards required under our operating licence, though we do not specifically claim compliance with any particular Pakistani domestic data protection statute as our primary legal basis.

Data Retention

PKR11 retains your Personal Data for as long as your Account is active and for such additional period as may be required by applicable legal, licensing and AML obligations. The following general retention principles apply:

• Active Account Data: Retained for the duration of your account's active status.
• Account Closure / Termination: Following account closure, core account data (including transaction history and KYC documents) is retained for a minimum of five (5) years to comply with AML record-keeping obligations. This minimum period may be extended by applicable regulatory requirements.
• Marketing Data: Marketing opt-in preferences and associated data are retained until you withdraw consent or for a period not exceeding three (3) years following your last interaction with a marketing communication, whichever is sooner.
• Support Communications: Retained for a minimum of three (3) years from the date of the communication.
• Technical Logs: System access logs and security event data are retained for periods appropriate to our security monitoring needs, typically twelve (12) months.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our data disposal procedures.

Security Measures

PKR11 implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, destruction or accidental loss. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your browser or device and the Platform's servers.
• Encryption of sensitive Personal Data at rest, including stored identity documents and financial records.
• Strict role-based access controls ensuring that Personal Data is accessible only to authorised personnel with a defined and documented business need.
• Regular security assessments, penetration testing and vulnerability scanning of Platform infrastructure.
• Pseudonymisation of analytics and reporting datasets where full identification is not necessary for the processing purpose.
• Incident response procedures that include notification to affected users and relevant authorities where a Personal Data breach occurs and is likely to result in a risk to your rights and freedoms.

While PKR11 employs robust security measures, no digital platform can guarantee absolute security against all threats. You are responsible for maintaining the security of your Account credentials. Please use a strong, unique password and enable two-factor authentication where it is available on the Platform.

Your Rights as a Data Subject

Subject to applicable law and the specific data protection framework under which your rights arise, you may hold the following rights in relation to your Personal Data held by PKR11:

To exercise any of these rights, please contact our Data Protection team using the contact details in Section 16. We will respond to valid requests within a reasonable timeframe consistent with applicable law — typically within thirty (30) days. We may need to verify your identity before processing your request.

Children & Minors

The Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required under our operating licence jurisdiction. PKR11 does not knowingly collect Personal Data from persons under the age of 18.

If PKR11 becomes aware that Personal Data has been collected from a person under the minimum age threshold, that Account will be immediately suspended, all balances will be forfeited in accordance with our Terms & Conditions, and all Personal Data collected in connection with that Account will be securely deleted — subject only to any mandatory regulatory retention requirement.

Third-Party Links

The Platform may contain references to, or links to, third-party websites, services or content. PKR11 does not control those third-party platforms and is not responsible for their privacy practices or content.

This Policy applies solely to Personal Data collected and processed by PKR11 through the Platform at pkr11.cam. Where you follow a link to a third-party site, we encourage you to review the privacy policy of that site before providing any Personal Data. PKR11 accepts no liability for any data handling practices of third-party platforms.

Policy Amendments

PKR11 reserves the right to amend, update or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing practices or the services we offer. The "Last Updated" date at the top of this document reflects the date of the most recent revision.

Where any change to this Policy is material — meaning it materially affects your rights or the way we process your Personal Data — PKR11 will endeavour to provide advance notice to registered Account Holders via email notification or a prominent in-platform banner prior to the change taking effect. Your continued use of the Platform following any amendment constitutes acceptance of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how PKR11 protects your information. Previous versions of this Policy are available on request via the contact details in Section 16.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or PKR11's data processing activities, please contact us using the details below. For data subject rights requests, please include your registered Account username or email address and clearly describe the right you wish to exercise.

Where your rights request is refused or you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction. For users in Pakistan, applicable data governance frameworks are administered at national and regulatory level; PKR11 will cooperate with any lawful regulatory inquiry directed to us through appropriate channels.