clubpk Privacy Policy — How We Handle Your Data

01 Introduction

This Privacy Policy ("Policy") is published by clubpk ("clubpk", "we", "us", or "our"), the operator of the website located at https://clubpk.ws. clubpk provides online casino gaming and sports betting services to registered users in Pakistan and other permitted jurisdictions.

By registering an account on clubpk, accessing our website, or using any service provided through the clubpk platform, you acknowledge that you have read, understood, and agreed to the collection and use of your personal data as described in this Policy. If you do not agree with any part of this Policy, you should not use the clubpk platform.

This Policy applies to all personal data that clubpk collects from users through the website, mobile browser interface, customer support channels, and any other point of interaction between a user and the clubpk platform. It does not cover the data practices of third-party game providers, payment processors, or any external websites that may be referenced within the platform.

02 Data We Collect

clubpk collects personal data in two primary ways: information you provide directly, and information collected automatically through your use of the platform.

Information You Provide Directly

• Registration Data: Full legal name, date of birth, gender, residential address (including city — Karachi, Lahore, Islamabad, Faisalabad, or otherwise), email address, and mobile phone number.
• Identity Verification Documents: Copies of government-issued identification such as a CNIC (Computerised National Identity Card), passport, or driver's license, which may be required for account verification under our Know Your Customer (KYC) obligations.
• Payment Information: Mobile wallet identifiers (JazzCash account number, EasyPaisa mobile number), bank account details (HBL, UBL, Meezan Bank, and other local banks), or Raast payment IDs used for deposits and withdrawals. clubpk does not store full card numbers or CVV codes on its servers.
• Communications: Messages you send via live chat, email to [email protected], or any feedback and support request submitted through the platform.
• Responsible Gaming Declarations: Any self-exclusion requests, deposit limit settings, or cooling-off period requests you submit through your account dashboard

Information Collected Automatically

• Device & Technical Data: IP address, browser type and version, operating system, device model, screen resolution, and language settings.
• Usage Data: Pages visited, games played, session duration, betting history, wagering patterns, click-stream data, and timestamps of platform activity.
• Location Data: General geographic location inferred from your IP address. clubpk does not collect precise GPS-level location data unless explicitly enabled by you on a mobile device.
• Cookies & Tracking Technologies: Data collected via cookies, web beacons, and similar technologies as described in Section 6 of this Policy.

03 How We Use Your Data

clubpk uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your clubpk account, verify your identity, and process your registration.
• Service Delivery: To provide access to casino games, sports betting markets, live dealer tables, and all other features of the clubpk platform.
• Payment Processing: To process deposits and withdrawals via JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and other supported local payment methods.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, and other prohibited behaviours on the clubpk platform.
• Legal & Regulatory Compliance: To fulfil our obligations under applicable gaming regulations, anti-money laundering (AML) requirements, and Know Your Customer (KYC) standards.
• Responsible Gaming: To monitor gameplay patterns that may indicate problem gambling behaviour and to enforce self-exclusion, deposit limits, and other responsible gaming tools requested by users.
• Customer Support: To respond to queries, resolve complaints, and provide assistance through our support team available daily from 9:00 AM to 1:00 AM PKT.
• Platform Improvement: To analyse usage trends, test new features, and improve the performance and user experience of the clubpk platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and updates about new games or features on clubpk — subject to your communication preferences. You may opt out at any time via your account settings.

04 Legal Basis for Processing

clubpk processes your personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing is required to perform the contract between you and clubpk — specifically, to operate your account and deliver the services you have registered to use.
• Legal Obligation: Processing is required for clubpk to comply with applicable laws and regulatory requirements, including AML, KYC, and gaming licence conditions.
• Legitimate Interests: Processing is necessary for clubpk's legitimate business interests, such as fraud prevention, platform security, and service improvement — provided those interests are not overridden by your rights and interests.
• Consent: Where processing is based on your consent (for example, receiving marketing emails or enabling location-based features), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

05 Data Sharing & Disclosure

clubpk does not sell, rent, or trade your personal data to third parties for their own commercial marketing purposes. We may, however, share your data with trusted parties in the following circumstances:

• Payment Processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and other payment service providers receive only the minimum data necessary to process your deposit or withdrawal transaction.
• Game Software Providers: Third-party game studios and live dealer platform providers may receive a anonymised or pseudonymised player identifier to facilitate gameplay. They do not receive your full name, CNIC, or payment details.
• Identity Verification Services: KYC and AML compliance partners may receive identity documents to verify your age (21+) and identity as required by our licensing obligations.
• Regulatory & Law Enforcement Authorities: clubpk may disclose personal data to competent authorities where required by law, court order, or lawful regulatory request. We will notify you of such disclosure where legally permitted to do so.
• Service Providers: Technology, analytics, customer support software, and cloud infrastructure providers who act as data processors on behalf of clubpk under strict contractual data protection obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of the clubpk business, your personal data may be transferred as part of that transaction. You will be notified in advance of any such transfer and any change in applicable privacy terms.

06 Cookies & Tracking Technologies

The clubpk website uses cookies and similar tracking technologies to enhance your experience, maintain session state, and analyse platform usage. A cookie is a small text file placed on your device by your web browser when you visit a website.

clubpk uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the website to function. These include session management cookies that keep you logged in to your clubpk account. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, last visited game category, and display options. Disabling these may affect your experience.
• Analytics Cookies: Help us understand how users interact with the clubpk platform — which pages are visited most, where users drop off, and how features are used. This data is aggregated and anonymised.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorised login attempts on your clubpk account.

You may configure your browser to refuse or delete cookies at any time. Please note that disabling certain cookies may limit your ability to use some features of the clubpk platform, including maintaining an active login session.

07 Data Security

clubpk implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the clubpk servers.
• Encryption of sensitive data at rest, including identity documents and payment identifiers.
• Multi-factor authentication options for your clubpk account login.
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments of the clubpk platform infrastructure.
• Incident response procedures with defined timelines for notifying affected users in the event of a data breach.

While clubpk takes all reasonable steps to protect your data, no system is entirely immune to security risks. You are responsible for keeping your clubpk account credentials confidential and for notifying us immediately at [email protected] if you suspect any unauthorised access to your account.

08 Data Retention

clubpk retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Active Accounts: Data is retained for the duration of your account registration with clubpk.
• Closed Accounts: Following account closure, clubpk retains transaction records, KYC documents, and AML-related data for a minimum of five (5) years to comply with anti-money laundering regulations and gaming licence requirements.
• Support Communications: Records of customer support interactions are retained for a minimum of two (2) years.
• Marketing Data: If you have opted in to marketing communications, your preferences are retained until you opt out. Following opt-out, your marketing profile is suppressed within 30 days.

When personal data is no longer required for any legitimate purpose, clubpk will securely delete or anonymise it in accordance with our internal data lifecycle management procedures.

09 Your Rights

As a clubpk user, you have the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data that clubpk holds about you.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held by clubpk.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restrict Processing: You may request that clubpk limit the processing of your personal data in certain circumstances.
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to clubpk, where technically feasible.
• Right to Object: You may object to processing of your personal data where that processing is based on legitimate interests, including profiling for marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw it at any time via your account settings or by contacting our support team.

To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request". clubpk will respond to all valid requests within thirty (30) calendar days. In some cases, we may need to verify your identity before processing your request.

10 Minors & Age Verification

As part of our registration and KYC process, clubpk requires all users to verify their date of birth and to provide a valid government-issued identification document confirming they are 21 or older. Accounts where age verification cannot be completed will be suspended pending document review.

If clubpk discovers or is notified that personal data has been collected from an individual under the age of 21, we will immediately close the associated account, refund any remaining balance in accordance with our Terms & Conditions, and permanently delete all personal data associated with that account.

Parents and guardians who believe a minor may have registered on the clubpk platform should contact our support team immediately at [email protected]. We take all such reports seriously and will act on them promptly.

11 Third-Party Services

The clubpk platform integrates with a number of third-party services to deliver its features — including game software providers, payment processors, and platform analytics tools. Each of these third parties operates under its own privacy policy and data protection practices.

clubpk is not responsible for the privacy practices of third-party providers. We encourage you to review the relevant privacy policies of any third-party service that you interact with through the clubpk platform. Our disclosure of data to third parties is governed by the data sharing principles set out in Section 5 of this Policy.

12 International Data Transfers

clubpk may transfer personal data to servers or service providers located outside Pakistan. Where such international transfers occur, clubpk takes all reasonable steps to ensure that your data continues to be protected to a standard consistent with this Policy, including through the use of contractual data protection clauses with receiving parties.

By using the clubpk platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside Pakistan where clubpk or its service providers operate infrastructure, subject to the safeguards described in this Policy.

13 Changes to This Policy

clubpk reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will notify registered users via email or through a prominent notice on the clubpk platform at least seven (7) days before the changes take effect.

The "Last Reviewed" date at the top of this Policy will be updated whenever a revision is published. Your continued use of the clubpk platform after the effective date of any revision constitutes your acceptance of the updated Policy. If you do not agree to the revised terms, you should close your account before the effective date.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way clubpk handles your personal data, please contact our Data Protection team:

clubpk is committed to resolving any privacy-related concerns in a timely and transparent manner. We aim to acknowledge all enquiries within two (2) business days and to provide a full response within thirty (30) calendar days.