399pk Privacy Policy

This Privacy Policy applies to all personal data processed by 399pk in connection with the operation of its online gaming platform accessible at 399pk.org, including all associated sub-pages, gaming services, customer support channels, and promotional communications.

This Policy applies to all individuals who interact with 399pk in any capacity — whether as a registered account holder, a visitor to the website who has not yet registered, or an individual who contacts 399pk via our support channels. By accessing the 399pk Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

This Policy operates alongside the 399pk Terms & Conditions and Responsible Gaming Policy, each of which is incorporated by reference. Where any inconsistency exists between this Policy and the Terms & Conditions on a privacy matter, this Privacy Policy shall prevail.

399pk collects personal data through several channels — directly from you during registration and account management, automatically through your use of the Platform, and from trusted third-party verification services where required by law. The categories of data we collect are set out below.

399pk does not collect sensitive personal data — such as religious beliefs, political affiliations, biometric data beyond document verification, or health information — and has no legitimate need to do so for the purposes of operating a gaming platform.

399pk uses the personal data it collects for the following purposes. For each purpose, the applicable legal basis is identified in Section 4 of this Policy.

• Account Registration & Management: To create and manage your 399pk account, verify your identity and age eligibility (21+), and maintain accurate account records.
• Payment Processing: To process deposits via JazzCash, EasyPaisa, Raast, HBL, UBL, and Meezan Bank, and to process withdrawal requests to verified payment accounts in your name.
• Gaming Service Delivery: To provide access to casino games, sportsbook markets (including PSL cricket, T20I, UFC, and other sports), poker, and slot titles, and to settle bets accurately.
• Fraud Prevention & Security: To detect and prevent fraudulent account activity, unauthorised access, multi-accounting, collusion, money laundering, and other prohibited conduct as defined in the 399pk Terms & Conditions.
• Regulatory Compliance: To fulfil obligations under applicable anti-money laundering (AML) laws, Know Your Customer (KYC) requirements, and other regulatory obligations including the maintenance of gaming records.
• Customer Support: To respond to your queries, complaints, and requests submitted via live chat or email, and to maintain records of such communications for quality assurance purposes.
• Responsible Gaming: To monitor gaming patterns and, where indicators of problem gambling are identified, to apply account-level responsible gaming interventions as provided for in the 399pk Responsible Gaming Policy.
• Marketing Communications: To send you promotional information about 399pk offers, bonuses, and new features via SMS or email, subject to your communication preferences. You may opt out at any time.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, design, and content of the 399pk Platform.

399pk processes personal data on the following legal bases, applied as appropriate to each processing activity:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you have accepted — including account management, payment processing, game settlement, and customer support.
• Legal Obligation: Processing required to comply with applicable laws, including KYC/AML obligations, age verification requirements, gaming regulatory requirements, and tax reporting obligations.
• Legitimate Interests: Processing for purposes of fraud prevention, platform security, responsible gaming monitoring, and platform improvement — where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for optional marketing communications, which requires your explicit opt-in consent and which you may withdraw at any time without affecting your ability to use the 399pk Platform.

399pk does not sell, rent, or trade your personal data to any third party. We share personal data with third parties only in the following limited, necessary circumstances:

• Payment Processors: We share financial data with JazzCash, EasyPaisa, Raast, and banking partners (HBL, UBL, Meezan Bank) as necessary to process deposits and withdrawals authorised by you.
• Identity Verification Providers: Where KYC verification is required, we may share identity data with authorised verification service providers who assist in confirming your identity and age.
• Game Technology Providers: Game providers who supply casino games, live dealer tables, and sportsbook infrastructure to 399pk may receive technical session data necessary to deliver and settle games.
• Regulatory & Law Enforcement Authorities: We are legally obligated to disclose personal data to relevant governmental authorities, regulators, or law enforcement agencies when required by applicable law, court order, or regulatory direction — including in connection with AML investigations. Such disclosures are made without prior notification to the account holder where legally required.
• Professional Advisors: Lawyers, auditors, and accountants engaged by 399pk may access personal data to the extent necessary to provide their professional services, subject to strict confidentiality obligations.

All third parties with whom 399pk shares personal data are contractually required to maintain appropriate data security standards and to use the data only for the purposes for which it was shared.

The 399pk Platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure user experience. A cookie is a small text file placed on your device by the Platform when you visit. Cookies cannot execute code or carry viruses.

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens that keep you logged in to your 399pk account and security tokens that prevent cross-site request forgery. These cannot be disabled without significantly impairing Platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data on how users navigate the 399pk Platform — which pages are visited most, where users exit, and how long sessions last. This data is used solely to improve Platform performance.
• Functional Cookies: Remember your preferences — such as language settings, responsible gaming limit configurations, and display preferences — so that you do not have to re-enter them on each visit.
• Marketing Cookies: Used, with your consent, to track your engagement with 399pk promotional content and to personalise promotional offers. You may withdraw consent for marketing cookies at any time.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the 399pk Platform, including the ability to remain logged in to your account.

399pk retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

• Active Account Data: Retained for the full duration of your active 399pk account and for a period of five (5) years following account closure, in compliance with applicable AML and gaming regulatory record-keeping requirements.
• Transaction Records: Financial records — including deposit, withdrawal, and wagering history — are retained for seven (7) years following the date of each transaction, as required for tax and regulatory compliance.
• KYC & Identity Verification Documents: Retained for five (5) years following account closure or the completion of the verification process, whichever is later.
• Support Communications: Live chat logs and email correspondence are retained for three (3) years from the date of the communication.
• Marketing Data: Retained until you withdraw consent for marketing communications or for three (3) years of inactivity, whichever is earlier.
• Technical & Access Logs: Retained for one (1) year from the date of generation, unless required for longer as part of a fraud or security investigation.

Upon expiry of the applicable retention period, personal data will be securely deleted or permanently anonymised in accordance with 399pk's internal data lifecycle procedures.

As a 399pk user, you hold the following rights with respect to the personal data we hold about you. These rights are subject to applicable legal limitations and will be assessed on a case-by-case basis:

• Right of Access: You have the right to request a copy of the personal data 399pk holds about you. We will respond to access requests within 30 days.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. Basic profile corrections can be made directly in your Account Settings; identity or financial data corrections require support team assistance.
• Right to Erasure: You may request deletion of your personal data in circumstances where retention is no longer necessary, consent has been withdrawn, or the data has been unlawfully processed. This right is subject to overriding legal retention obligations, particularly AML and gaming regulatory record-keeping requirements.
• Right to Data Portability: You may request that personal data you have provided to 399pk be provided to you in a structured, machine-readable format.
• Right to Restriction of Processing: You may request that 399pk limit 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 of your data carried out on the basis of legitimate interests. 399pk will assess whether compelling legitimate grounds override your objection.

To exercise any of the above rights, please contact the 399pk support team via live chat or at [email protected]. We will acknowledge your request within 48 hours and provide a substantive response within 30 calendar days.

399pk employs age verification procedures at registration to confirm that all new Users meet the minimum age requirement of 21 years. If you have reason to believe that an individual under 21 years of age has registered on 399pk, please contact us immediately at [email protected] with relevant details so that we can take appropriate action promptly.

Parents or guardians who become aware of minor account registration are strongly encouraged to contact 399pk directly. We cooperate fully with all such reports and take underage access seriously as both a legal and ethical obligation.

399pk implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• Transport Encryption: All data transmitted between your device and the 399pk Platform is encrypted using TLS 1.3 with 256-bit AES encryption, ensuring that data cannot be intercepted in transit.
• Data-at-Rest Encryption: Personal data stored in 399pk's databases is encrypted at rest using industry-standard encryption protocols, ensuring that even in the event of a data infrastructure breach, stored data cannot be read without decryption keys.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff members access only the data necessary to perform their specific role. All internal data access is logged and audited.
• Two-Factor Authentication: 399pk offers two-factor authentication (2FA) for all User accounts, providing an additional layer of protection against unauthorised account access. All Users are strongly encouraged to enable 2FA.
• Penetration Testing: 399pk's infrastructure undergoes regular independent security testing to identify and remediate potential vulnerabilities before they can be exploited.
• Incident Response: 399pk maintains a documented data breach response plan. In the event of a breach, affected Users will be notified within 72 hours of detection, and appropriate remediation steps will be taken immediately.

The operation of a global gaming platform requires that certain technical infrastructure — including game delivery servers, payment processing systems, and cloud hosting — may be located outside Pakistan. As a result, your personal data may be transferred to, stored in, or processed in countries other than Pakistan.

Where such international transfers occur, 399pk ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to the protections provided under this Privacy Policy. Such safeguards include:

• Contractual data protection clauses binding all international data processors to equivalent privacy and security standards.
• Transfer to jurisdictions that maintain recognised adequate data protection frameworks under applicable international standards.
• Technical measures — including encryption of data in transit and at rest — that protect personal data regardless of geographic location of storage.

By using the 399pk Platform, you acknowledge and consent to the transfer of your personal data in accordance with this Section. If you have questions about specific international transfers affecting your data, please contact our support team.

The 399pk Platform may reference or link to third-party services — including game provider interfaces, payment processor portals, and responsible gaming support resources. This Privacy Policy applies solely to personal data processed by 399pk in its capacity as the Platform operator.

399pk is not responsible for the privacy practices of third-party service providers whose systems you interact with as part of the gaming experience — including but not limited to JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, or any game technology provider. We encourage you to review the privacy policies of any third-party service before providing your personal information to that service.

Game providers who supply content to the 399pk Platform are contractually bound by data processing agreements that restrict their use of any technical data received in connection with game delivery to the purposes of game functionality and session settlement only. They are prohibited from using such data for their own marketing or commercial purposes.

399pk reserves the right to amend this Privacy Policy at any time. The following process governs amendments:

• Material Amendments: Any amendment that substantially changes how we collect, use, or share your personal data will be communicated to registered Users via SMS or email to the contact details held on your Account, with a minimum of seven (7) days' advance notice before the amendment takes effect.
• Non-Material Amendments: Minor corrections, clarifications, or changes required to comply with applicable law may take effect immediately upon publication without prior notice.
• Version Control: Each published version of this Policy is identified by its effective date and version number. The current version is always accessible on this page. Previous versions are available on request.

Your continued use of the 399pk Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept a material amendment, you may close your Account and withdraw your remaining real money Balance prior to the amendment taking effect.

If you have any questions about this Privacy Policy, wish to exercise any of the data rights described in Section 8, or wish to make a complaint about 399pk's data handling practices, please contact us through one of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, via the support widget on the 399pk Platform. Average first response time is under two (2) minutes. This is the fastest channel for urgent privacy concerns.
• Email: Non-urgent privacy enquiries and formal data rights requests may be directed to [email protected]. Please include "Privacy Request" in the subject line and your registered mobile number in the email body to expedite processing. We respond to all privacy emails within four (4) business hours.

All formal privacy complaints will be acknowledged within 48 hours and investigated within 30 calendar days. Where a complaint cannot be resolved to your satisfaction through our internal process, you may have the right to escalate your complaint to the applicable data protection authority in your jurisdiction.