ClubPK Privacy Policy

This Privacy Policy (hereinafter "the Policy") describes how ClubPK (hereinafter "ClubPK", "We", "Us" or "the Platform") collects, uses, stores, protects and discloses personal data relating to registered users, website visitors and any other individuals who interact with the ClubPK platform at https://clubpk.cam.

ClubPK takes the privacy and security of your personal data seriously. This Policy is designed to give you clear, honest information about our data practices so that you can make informed decisions about your interaction with the Platform. We encourage you to read this Policy in full before creating an account or providing any personal information.

This Policy applies to all personal data collected through the ClubPK website, mobile-optimised platform, live chat system, email correspondence, KYC verification processes and any other communication channels operated by ClubPK.

This Policy should be read alongside the Terms & Conditions, which govern the contractual relationship between ClubPK and its users.

For the purposes of this Policy, the following terms carry the meanings defined below:

ClubPK collects the following categories of personal data, depending on the nature of your interaction with the Platform:

ClubPK does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (beyond KYC liveness checks) or health data, except where such data is voluntarily provided in the context of a responsible gambling support interaction.

ClubPK collects personal data through the following channels and mechanisms:

• Account Registration Forms: Data you provide directly when creating your ClubPK account, including name, date of birth, email and contact details.
• KYC Verification Portal: Documents and photographs you upload through the secure in-account verification section. ClubPK does not accept KYC documents submitted via unsecured channels.
• Payment Transactions: Transaction data generated when you make deposits or request withdrawals through payment channels available on the Platform, which may include references to local payment methods such as Easypaisa, JazzCash, Raast or bank transfers (HBL, UBL, Meezan Bank, Bank Alfalah). These payment brands are cited as familiar context only; none of them endorses or facilitates gambling on behalf of ClubPK.
• Cookies and Tracking Technologies: Automatically collected data from your browser when you visit the Platform. Full details are provided in Section 7.
• Customer Support Interactions: Correspondence and chat transcripts generated when you contact ClubPK's support team.
• Third-Party Identity Verification Services: Where ClubPK uses an approved third-party KYC or AML service provider to verify identity documents, that provider may transmit verification outcomes and associated data to ClubPK under a data processing agreement.

ClubPK processes personal data for the following purposes:

• Account Management: To create, maintain and administer your ClubPK account, including authenticating your identity on login and managing your preferences and responsible gambling settings.
• KYC and AML Compliance: To verify your identity and age, prevent fraud, detect and report money laundering activity, and comply with applicable regulatory obligations imposed by the operator's licence jurisdiction.
• Transaction Processing: To process deposits, withdrawals and associated payment confirmations accurately and securely in PKR.
• Platform Operation and Security: To monitor platform usage, detect technical issues, prevent unauthorised access, detect and investigate suspected fraud or abuse, and maintain the integrity of the Platform.
• Customer Support: To respond to your enquiries, resolve disputes, handle complaints and provide account-related assistance.
• Responsible Gambling: To enforce account limits, self-exclusion periods and cool-off requests, and to identify patterns of play that may indicate problem gambling.
• Marketing Communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications and platform updates. You may withdraw marketing consent at any time through your account settings or by contacting support.
• Legal and Regulatory Obligations: To retain records as required by applicable law, respond to lawful requests from regulatory or law enforcement authorities, and defend against legal claims.

ClubPK processes personal data on the following legal bases, as applicable under the laws of the operator's licence jurisdiction:

• Contractual Necessity: Processing required to perform the contract between ClubPK and the User (i.e., operating your account, processing transactions, providing gaming services).
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC identity verification, AML record-keeping and responses to lawful authority requests.
• Legitimate Interests: Processing carried out in the legitimate interests of ClubPK, such as fraud prevention, platform security, responsible gambling monitoring and improving service quality, where those interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific and informed consent, such as receiving marketing communications. Where consent is the legal basis, you may withdraw it at any time without affecting the lawfulness of prior processing.

ClubPK uses cookies and similar tracking technologies to operate the Platform, maintain your session, remember your preferences and collect aggregate usage statistics that help us improve the platform experience.

You can control and manage cookies through your browser settings. Disabling strictly necessary cookies will impair core Platform functionality including login. Disabling analytics or marketing cookies will not affect your ability to use the Platform.

ClubPK does not sell your personal data to third parties. We may share personal data in the following limited circumstances:

• KYC and AML Service Providers: Approved third-party identity verification and anti-money laundering screening providers, acting as Data Processors under contractual data processing agreements that require equivalent data protection standards.
• Payment Processing Partners: Payment service providers involved in processing your deposits and withdrawals. These providers process only the data necessary to complete the transaction and are bound by their own regulatory and contractual data protection obligations.
• Gaming Technology Providers: Game studios and sports data partners that supply the games and odds content available on the Platform, where technical data is shared to facilitate gameplay and bet settlement.
• Legal and Regulatory Authorities: Where ClubPK is required by law, court order or lawful regulatory direction to disclose personal data, including to financial intelligence units in connection with AML obligations.
• Corporate Transactions: In the event of a merger, acquisition, asset sale or restructuring, personal data may be transferred to the acquiring entity as part of the business assets, subject to equivalent data protection commitments.
• Fraud Prevention: Where necessary to prevent, detect or investigate fraud, money laundering or other criminal activity affecting the Platform or its users.

All third-party data processors engaged by ClubPK are subject to contractual obligations requiring them to process personal data only for specified purposes and to maintain appropriate technical and organisational security measures.

ClubPK retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Specific retention periods are as follows:

• Account Data: Retained for the duration of the active account and for a minimum of five (5) years following account closure, to satisfy AML record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of last transaction or account closure, as required by applicable AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years, or longer where required by applicable tax or regulatory law.
• Communications and Support Records: Retained for a minimum of three (3) years, or longer where relevant to an active dispute or regulatory inquiry.
• Marketing Consent Records: Retained until consent is withdrawn and for a reasonable period thereafter to demonstrate prior consent compliance.
• Analytics Data: Aggregated and anonymised analytics data may be retained indefinitely as it does not constitute personal data once anonymised.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised using appropriate technical methods.

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

• TLS/SSL encryption for all data in transit between your device and ClubPK servers.
• Encryption of sensitive data at rest, including identity documents and financial records.
• Access controls restricting internal access to personal data on a strict need-to-know basis, with audit logging of access events.
• Regular security assessments and penetration testing of the Platform infrastructure.
• Secure document upload portals for KYC submissions, with no acceptance of sensitive documents via unsecured channels.
• Employee training on data protection obligations and information security best practices.

Despite these measures, no online platform can guarantee absolute security. If you become aware of any suspected security incident affecting your ClubPK account, you must notify our support team immediately. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, ClubPK will notify affected users without undue delay in accordance with applicable law.

Subject to applicable law and certain limitations (for example, where processing is required for legal compliance purposes), you have the following rights in relation to the personal data ClubPK holds about you:

To exercise any of these rights, please contact ClubPK's support team using the details in Section 12. ClubPK will respond to all valid data rights requests within thirty (30) calendar days. Where a request is complex or there are multiple requests, we may extend this period by a further two months, in which case we will notify you of the extension and the reason.

For any questions, concerns or requests relating to this Privacy Policy or your personal data, you may contact ClubPK through the following channels. Please note that all contact details are displayed as plain text — no clickable email or telephone links are provided.

ClubPK takes all privacy-related complaints seriously. If you are not satisfied with our response to a data concern, you may have the right to lodge a complaint with the relevant data protection supervisory authority in the operator's licence jurisdiction.

ClubPK reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will provide notice through one or more of the following: a prominent notice on the Platform homepage, an in-account notification or an email to your registered email address.

The effective date of the most recent revision is shown at the top of this page. We recommend that you review this Policy periodically to remain informed of any changes. Your continued use of the Platform following the posting of a revised Policy constitutes your acknowledgment of those changes.

If any revised terms materially reduce your rights under this Policy, ClubPK will provide at least fourteen (14) days' advance notice before the revised terms take effect.