Privacy Policy

1 Introduction

pk37 ("we", "us", "our") operates the informational platform located at pk37.cam (the "Platform"). We are committed to protecting the privacy of every individual who visits or interacts with the Platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure and protection of personal data in connection with your use of pk37.

pk37 is an English-language online betting and casino information resource designed for Pakistani users. Our Platform covers sports wagering, live casino information, cricket markets — including PSL, ICC tournaments and T20 formats — football, UFC and more. We serve users across Pakistan, from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.

Importantly, pk37 is an informational platform only. We do not operate a betting exchange, accept wagers, hold user funds or act as a gambling operator. As a result, we do not collect the categories of sensitive financial or gambling data that licensed operators typically process. Our data collection is limited to what is necessary for the Platform to function and improve.

This Privacy Policy should be read in conjunction with our Terms & Conditions and our Responsible Gambling page, both of which form part of the overarching agreement governing your use of pk37.

2 Definitions

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

• "Personal Data" means any information that identifies or could reasonably identify a natural person, directly or indirectly — including name, email address, IP address, device identifiers and behavioural data tied to an identified individual.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. For the purposes of this policy, pk37 is the Data Controller in relation to data collected through the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a contractual agreement.
• "User", "You", "Your" refers to any individual who accesses or uses the Platform in any capacity.
• "Cookies" means small text files placed on your device by the Platform or third-party analytics providers for the purposes described in Section 6.
• "Platform" means the pk37 website accessible at pk37.cam, including all pages, subpages and functionality available through it.

3 Data We Collect

pk37 collects two broad categories of data: information you provide directly and information collected automatically through your use of the Platform.

3.1 Data You Provide Directly

pk37 does not currently require user registration or account creation to access Platform Content. However, if you contact us via the email address provided on the Platform, we may receive and store:

• Your name (if provided in your message);
• Your email address;
• The content of your communication, including any attachments;
• Your preferred language for correspondence.

We will only use this information to respond to your enquiry and will not use it for any other purpose without your explicit consent.

3.2 Data Collected Automatically

When you visit the Platform, we and our service providers may automatically collect certain technical and behavioural data, including:

We do not collect biometric data, government-issued identification numbers, financial account credentials or precise real-time location data through the Platform.

4 How We Use Your Data

pk37 uses the data we collect for the following purposes:

• Platform operation and delivery: To serve page content, maintain session continuity and ensure the Platform functions correctly across devices and browsers used by visitors in Pakistan and internationally.
• Analytics and improvement: To understand how users interact with the Platform, identify areas for improvement, and develop new content — particularly around topics such as cricket betting markets, PSL coverage, payment method guidance (including references to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) and responsible gambling information.
• Security and fraud prevention: To detect and prevent malicious activity, unauthorised access, scraping, abuse and technical threats against the Platform.
• Communications: To respond to enquiries submitted by users via email, including questions about Platform content, responsible gambling resources or data privacy rights.
• Legal compliance: To meet obligations under applicable law, respond to lawful requests from authorities, and enforce our Terms & Conditions where necessary.
• Aggregated reporting: To compile anonymised, aggregated statistical data about Platform usage, which does not identify any individual user, for internal reporting purposes.

We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects on you. We do not use your data to serve targeted gambling advertisements.

5 Legal Basis for Processing

Where data protection law requires a lawful basis for processing Personal Data, pk37 relies on the following grounds:

• Legitimate interests: The primary basis for processing automatically collected technical and analytics data. Our legitimate interest is the operation, security and improvement of an informational platform. We have assessed that this interest is not overridden by the privacy rights of users given the limited, non-sensitive nature of the data collected.
• Consent: Where we use non-essential cookies or tracking technologies, we rely on your consent, which you may withdraw at any time by adjusting your browser settings or clearing cookies.
• Contractual necessity: Where processing is necessary to fulfil a request you have made, such as responding to a support or data rights enquiry.
• Legal obligation: Where processing is required to comply with applicable laws or respond to lawful regulatory or judicial requests.

pk37 does not rely on consent as the basis for processing data collected automatically during normal Platform use (i.e., technical and analytics data), as this processing falls under legitimate interests given the minimal privacy impact involved.

6 Cookies & Tracking Technologies

pk37 uses cookies and similar technologies (such as local storage and session storage) to support the operation and analysis of the Platform. The following categories of cookies may be used:

• Strictly necessary cookies: Required for the Platform to function. These include session management cookies and security tokens. They cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to collect anonymised data about how visitors use the Platform — including which pages are visited most frequently, average session duration and navigation paths. This helps us improve content quality and structure.
• Preference cookies: Used to remember user preferences such as language settings or previously viewed content, improving your experience on return visits.

You can manage or disable cookies through your browser settings at any time. Most modern browsers allow you to block third-party cookies, clear existing cookies or receive alerts before a cookie is stored. Please note that disabling certain cookies may affect the functionality or appearance of some Platform features.

pk37 does not use advertising cookies, retargeting pixels or behavioural tracking cookies designed to build advertising profiles. We do not serve interest-based gambling advertisements through cookie-based targeting.

7 Data Sharing & Disclosure

pk37 does not sell, rent or trade Personal Data to any third party. We may share data in the following limited circumstances:

• Service providers and processors: We engage trusted third-party service providers (such as hosting providers, analytics platforms and security monitoring services) that process data on our behalf under contractual data processing agreements. These providers are prohibited from using your data for purposes other than those we specify.
• Legal requirements: We may disclose Personal Data if required to do so by law, court order, or in response to a valid request from a competent authority, government body or regulatory agency — including in Pakistan where applicable law requires disclosure.
• Protection of rights: We may share data where we reasonably believe disclosure is necessary to protect the rights, property or safety of pk37, its users or the public, or to enforce our Terms & Conditions.
• Business transfers: In the event of a merger, acquisition, restructuring or sale of assets involving pk37, Personal Data may be transferred as part of that transaction. We will notify users of any material ownership change via a prominent notice on the Platform.

We do not share Personal Data with gambling operators, payment providers (including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah) or sports organisations referenced on the Platform. References to these entities on pk37 are contextual and informational only.

8 International Data Transfers

pk37 is operated by a team that may use service providers located in various jurisdictions. As a result, your data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, we take reasonable steps to ensure that appropriate safeguards are in place to protect your data — including contractual protections with service providers and use of providers operating under recognised data protection frameworks.

Pakistan does not currently have a comprehensive data protection law equivalent to the EU General Data Protection Regulation (GDPR). However, pk37 voluntarily applies reasonable data protection standards consistent with international best practice in its handling of user data, regardless of where processing occurs.

If you are located in a jurisdiction with specific legal requirements for international data transfers and have concerns about how your data is handled, please contact us using the details in Section 13.

9 Data Retention

pk37 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention principles are:

• Email correspondence: Retained for up to 24 months from the date of last communication, unless an ongoing matter requires extended retention.
• Analytics data: Aggregated or anonymised analytics data may be retained indefinitely, as it no longer constitutes Personal Data once anonymised.
• Log and security data: Server logs and security-related data are typically retained for 90 days, unless an active security investigation requires longer retention.
• Cookie data: Session cookies expire at the end of your browsing session. Persistent cookies expire as specified in our cookie configuration, typically between 30 days and 12 months.

When data is no longer required, we take reasonable steps to securely delete or anonymise it. You may also request early deletion of your Personal Data as set out in Section 10.

10 Your Rights

Subject to applicable law, you may have the following rights in relation to your Personal Data held by pk37. We will respond to valid, verified requests within 30 days of receipt, or notify you if additional time is required:

• Right of access: You may request a copy of the Personal Data we hold about you, along with information about how it is being used.
• Right to rectification: You may request correction of inaccurate or incomplete Personal Data held by pk37.
• Right to erasure: You may request deletion of your Personal Data where there is no compelling reason for its continued processing. This right is not absolute and may be subject to legal retention obligations.
• Right to restriction: You may request that we restrict the processing of your Personal Data in certain circumstances — for example, while a rectification request is being assessed.
• Right to object: You may object to processing based on legitimate interests where your particular circumstances justify it. We will assess the objection and either cease processing or provide compelling grounds for its continuation.
• Right to data portability: Where processing is based on consent or contractual necessity, you may request that we provide your Personal Data in a commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us using the details provided in Section 13. We may need to verify your identity before processing your request. We do not charge a fee for reasonable data rights requests.

11 Children's Privacy

The pk37 Platform is strictly intended for adults aged 18 and over — or the higher minimum age required by the applicable operator or licence jurisdiction. We do not knowingly collect Personal Data from individuals under the age of 18.

If you are under 18, you must not use the Platform or submit any Personal Data to pk37. If we become aware that we have inadvertently collected data from a person under 18, we will take prompt steps to delete that data from our systems.

If you are a parent or guardian and believe that a minor has submitted Personal Data to pk37 without your consent, please contact us immediately at the address provided in Section 13 and we will act without unnecessary delay.

12 Updates to This Privacy Policy

pk37 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations or Platform functionality. When changes are made, we will update the "Last Updated" date at the top of this page.

For material changes — those that significantly affect how we collect, use or share Personal Data — we will make reasonable efforts to notify users through a prominent notice on the Platform for a reasonable period following the update. We encourage you to review this Privacy Policy periodically.

Your continued use of the Platform following any update to this Privacy Policy constitutes your acknowledgement of the revised terms. If you disagree with the updated policy, you should discontinue use of the Platform.

13 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy, your Personal Data or your data rights, please contact the pk37 privacy team. We take all privacy enquiries seriously and aim to respond within 30 calendar days.

For responsible gambling support or resources, please visit our Responsible Gambling page. For the general terms governing your use of pk37, refer to our Terms & Conditions.