pkgems Privacy Policy

1Introduction

pkgems ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all individuals who interact with our platform — whether as registered players, casual visitors, or prospective users browsing our website at pkgems.org.

This Privacy Policy ("Policy") sets out in clear, straightforward terms the categories of personal data we collect, the lawful bases upon which we process that data, how we use and share it, and the rights available to you under applicable data protection law. It applies to all pkgems services, including our website, mobile-optimised interface, customer support channels, and any other digital touchpoints operated by pkgems.

By registering an account with pkgems or continuing to use our platform, you acknowledge that you have read and understood this Privacy Policy. If you disagree with any part of this Policy, you should discontinue use of pkgems services and contact our support team to close your account.

2Data Controller

For the purposes of applicable data protection legislation, pkgems acts as the Data Controller in respect of all personal data collected through this platform. As Data Controller, pkgems determines the purposes for which and the means by which your personal data is processed.

Where pkgems engages third-party service providers to process personal data on its behalf — for example, payment processors, identity verification providers, or analytics platforms — those parties act as Data Processors and are bound by contractual obligations that restrict their use of your data to the specific purposes authorised by pkgems.

If you have any questions about how your data is handled, or wish to exercise any of your data protection rights, you may contact us at the details provided in Section 14 of this Policy.

3Personal Data We Collect

pkgems collects personal data across several categories depending on how you interact with our platform. The table below summarises the main data types we process:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, religious beliefs, or biometric data beyond what is strictly required for identity verification purposes.

4How We Collect Your Data

pkgems collects personal data through a variety of channels and mechanisms, including:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or responding to a promotion.
• Automated technologies: When you browse or interact with our website, we automatically collect certain technical and usage data via cookies, server logs, and similar tracking technologies. See Section 9 for full details on our cookie practices.
• Third-party sources: We may receive identity or risk-scoring data from regulated third-party identity verification providers, fraud detection services, and payment processors where necessary to fulfil our regulatory obligations. All such third parties are contractually bound to share data with us only in accordance with applicable law.
• Public sources: In limited circumstances related to fraud prevention or AML screening, pkgems may consult publicly available information such as sanctions lists or official government databases.

5Purpose & Legal Basis for Processing

pkgems processes your personal data only where a valid legal basis exists. The primary legal bases we rely upon are as follows:

• Performance of a contract: Processing necessary to create and manage your pkgems account, process deposits and withdrawals, and deliver the gaming services you have requested.
• Legal obligation: Processing required to comply with Know Your Customer (KYC) rules, Anti-Money Laundering (AML) regulations, responsible gambling requirements, and the conditions of our international gaming licence.
• Legitimate interests: Processing carried out for fraud detection, platform security, abuse prevention, service quality improvement, and internal analytics — provided these interests are not overridden by your fundamental rights.
• Consent: Where we send you marketing emails, SMS promotions, or personalised bonus offers, we do so only on the basis of your freely given, informed, and specific consent. You may withdraw this consent at any time.

6Data Sharing & Third Parties

pkgems does not sell your personal data. We may share your data with carefully selected third parties only in the following circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and cryptocurrency gateway providers — solely to process your financial transactions.
• Identity verification providers: Regulated KYC and AML screening services that assist us in verifying your identity and monitoring for financial crime risk.
• Technology and hosting partners: Cloud infrastructure providers, CDN services, and platform hosting partners who process data on our behalf under strict data processing agreements.
• Customer support tools: Secure helpdesk and live chat platforms used to manage and respond to your support queries.
• Legal and regulatory authorities: Where we are required by law, court order, or a directive from a competent regulatory or law enforcement authority to disclose your information, we will do so. We will notify you of such disclosure where legally permitted.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of our business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the applicable privacy arrangements in advance.

All third parties with whom pkgems shares personal data are required to implement appropriate technical and organisational security measures and to process your data only for the purposes specified by pkgems.

7Data Retention

pkgems retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The general retention principles we follow are:

• Active account data: Retained for the full duration of your account relationship with pkgems, plus a period of up to 5 years following account closure to satisfy AML and gaming regulatory record-keeping requirements.
• KYC and verification documents: Retained for a minimum of 5 years from the date of verification in line with standard anti-money laundering regulatory requirements.
• Transaction records: Retained for a minimum of 5 years from the date of the relevant transaction.
• Marketing and communications data: Retained until you withdraw consent or opt out, after which it is deleted or anonymised within 30 days.
• Technical and usage logs: Generally retained for 12 months, after which they are anonymised or deleted.

Once the applicable retention period expires, your personal data will be securely deleted or irreversibly anonymised so that it can no longer be associated with you.

8Security Measures

pkgems takes the security of your personal and financial data seriously. We have implemented a layered set of technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, or destruction. These include:

• AES-256 encryption for all data stored at rest on our servers.
• TLS 1.2 / 1.3 encryption for all data transmitted between your device and our platform.
• Multi-factor authentication options for player account access.
• Intrusion detection systems and 24/7 security monitoring of our infrastructure.
• Role-based access controls ensuring that only authorised personnel can access player data, and only to the extent required for their role.
• Regular third-party security audits and penetration testing of our platform.
• Staff training on data protection obligations and secure data handling practices.

In the event of a personal data breach that poses a risk to your rights and freedoms, pkgems will notify affected users and relevant supervisory authorities in accordance with our legal obligations and within the timeframes required by applicable law.

9Cookies & Tracking Technologies

pkgems uses cookies and similar tracking technologies to operate and improve our platform, personalise your experience, and gather analytics about how our services are used. The main categories of cookies we deploy are:

• Strictly necessary cookies: Essential for the basic functioning of the platform — for example, maintaining your login session and remembering items in your account settings. These cannot be disabled.
• Functional cookies: Allow the platform to remember your preferences such as language settings, preferred currency display (PKR), and game filters.
• Analytics cookies: Help us understand how visitors interact with our platform — which pages are most visited, how long sessions last, and where users encounter difficulties. This data is aggregated and anonymised.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts.

Non-essential cookies are only placed on your device with your prior consent, which you can provide or withdraw through our cookie consent banner. You may also manage cookie preferences at any time through your browser settings, though disabling certain cookies may affect the functionality of the pkgems platform.

10Your Data Protection Rights

As a pkgems user, you hold meaningful rights over your personal data. These rights include:

• Right of access: Request a copy of the personal data pkgems holds about you, along with information about how it is being used.
• Right to rectification: Ask us to correct any inaccurate or incomplete personal data we hold about you.
• Right to erasure ("right to be forgotten"): 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 restriction: Ask us to temporarily suspend processing of your data in certain circumstances — for example, while you contest the accuracy of data we hold.
• Right to data portability: Receive a copy of the personal data you provided to pkgems in a structured, commonly used, machine-readable format.
• Right to object: Object to processing carried out on the basis of our legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact our support team at [email protected]. We will respond to all verified requests within 30 days. In some cases, we may need to verify your identity before fulfilling a request.

11Minors & Age Policy

pkgems enforces a strict 21+ age policy. Our platform is not intended for, directed at, or accessible to persons under the age of 21. We do not knowingly collect personal data from anyone under this age threshold.

During the registration process, all users are required to confirm that they are at least 21 years of age. pkgems conducts age verification as part of its standard KYC process, and accounts found to belong to persons under 21 will be immediately closed with any balances refunded and any bonus winnings forfeited.

If you are a parent or guardian and believe that a minor has registered on pkgems or provided personal data to us without your consent, please contact us immediately at [email protected] and we will take prompt action to investigate and, where confirmed, delete the data and close the account.

12International Data Transfers

pkgems operates under an international gaming licence and may process or store your personal data on servers located outside Pakistan. Where personal data is transferred internationally, pkgems ensures that appropriate safeguards are in place to protect your data to a standard equivalent to applicable data protection requirements.

These safeguards may include:

• Standard contractual clauses approved by relevant supervisory authorities.
• Transfers to countries or organisations that have been deemed to provide an adequate level of data protection.
• Binding corporate rules applicable to our group companies and authorised data processors.

You may request further information about the specific safeguards in place for any international transfer of your personal data by contacting us at the details in Section 14.

13Policy Updates

pkgems reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or business operations. Where changes are material — meaning they significantly affect how we process your personal data or your rights as a data subject — we will notify registered users by email or via an in-platform notification prior to the changes taking effect.

The revised Policy will always be available on this page, clearly marked with the updated effective date at the top. We encourage you to review this page periodically to stay informed about how pkgems protects your information. Your continued use of the platform following the publication of any updated Policy constitutes your acknowledgement of the changes.

14Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pkgems handles your personal data, please do not hesitate to get in touch with our dedicated support team. We aim to acknowledge all privacy-related enquiries within 48 business hours and resolve them within 30 days.

You can reach us at: [email protected]

If you are unsatisfied with our response to a privacy complaint, or believe that pkgems is processing your personal data in a manner inconsistent with applicable data protection law, you have the right to escalate your complaint to the relevant supervisory or regulatory authority in your jurisdiction.

pkgems takes all privacy complaints seriously and is committed to resolving disputes fairly, transparently, and in a timely manner. We will always explain our reasoning clearly and, where we have made an error, take prompt steps to correct it.