🔒 Legal Document

Privacy Policy

This Privacy Policy explains how 91pk collects, uses, stores, shares and protects your personal data. We are committed to handling your information with transparency, security and respect — whether you are accessing the platform from Karachi, Lahore, Islamabad or anywhere else.

Document Version: 2026-01  ·  Last Updated: January 2026  ·  Applies to: https://91pk.cam

Our Privacy Commitments

Minimal Data Collection

91pk collects only the personal data necessary to operate your account, process transactions, fulfil KYC obligations and maintain platform security. We do not collect data speculatively or beyond what each stated purpose requires.

No Data Selling

Your personal information is never sold to third-party marketers, data brokers or advertising networks. Data is shared with processors only where necessary to provide services — and only under strict contractual data-protection obligations.

Your Rights, Respected

You have the right to access, correct, export or request deletion of your personal data, subject to legal retention obligations. All requests are handled through our support team and acknowledged within a reasonable timeframe.

KYC Data Handled Carefully

Identity documents (CNIC, passport, proof of address) collected for KYC are processed securely, retained only as long as required by applicable regulatory obligations, and never used beyond verification and compliance purposes.

Secure Storage & Transmission

All data in transit is protected using industry-standard TLS encryption. Data at rest is stored on secured infrastructure with access controls restricted to authorised personnel only. Security practices are reviewed and updated regularly.

Transparent Cookie Use

Cookies are used for session management, platform functionality and basic analytics. We do not deploy invasive tracking pixels or share cookie-derived behavioural profiles with advertising networks. Cookie categories and their purposes are detailed in the Cookies section below.

Section 01

Introduction

This Privacy Policy is published by 91pk, the operator of the online sports betting and live casino platform accessible at https://91pk.cam (the "Platform"). 91pk is an English-language service built for the Pakistan market, covering cricket, PSL, ICC tournaments, football, UFC and a full range of live casino, slot and instant game titles.

We understand that privacy matters to our users — whether they are placing a bet on a PSL T20 match from Lahore, managing their account in Islamabad, or accessing the live casino from Karachi. This Policy explains what personal data 91pk collects, why we collect it, how long we keep it, who we share it with, and what rights you have in relation to your data.

By registering an account on 91pk or using any part of the Platform, you confirm that you have read and understood this Privacy Policy. If you do not agree with any aspect of this Policy, you should not use the Platform.

Read alongside: This Privacy Policy should be read in conjunction with 91pk's Terms & Conditions and Responsible Gambling Policy, all of which form part of the agreement between you and 91pk.

Section 02

Definitions

The following defined terms are used in this Privacy Policy:

Term Meaning
"Personal Data" Any information relating to an identified or identifiable natural person — including name, email address, CNIC number, IP address, device identifiers and transaction records.
"Processing" Any operation performed on Personal Data, including collection, storage, use, disclosure, transfer and deletion.
"Data Controller" The entity that determines the purposes and means of Processing Personal Data. For the purposes of this Policy, 91pk is the Data Controller.
"Data Processor" A third party that processes Personal Data on behalf of 91pk under a contractual data-processing agreement.
"KYC" Know Your Customer — the identity and age verification process required of all registered Users.
"User" / "you" Any individual who accesses or uses the 91pk Platform, whether registered or unregistered.
"Sensitive Data" A sub-category of Personal Data requiring heightened protection, which may include identity document numbers, financial account details and device location data.
Section 03

Data Controller

91pk acts as the Data Controller in respect of the Personal Data of Users who register accounts and use the Platform. As Data Controller, 91pk determines why and how your personal data is processed, and bears responsibility for ensuring that processing is lawful, fair and transparent.

Where 91pk engages third-party service providers to process data on its behalf — such as KYC verification providers, payment processors and analytics platforms — those parties act as Data Processors and are bound by contractual obligations requiring them to process data only as instructed by 91pk, to maintain appropriate security measures, and not to retain or use data beyond the scope of the services provided.

For all data-related enquiries, requests and complaints, please contact 91pk via the support channels set out in Section 16 of this Policy.

Section 04

Data We Collect

91pk collects the following categories of Personal Data in the course of operating the Platform. Data is collected directly from you, automatically through platform interactions, and in some cases from third-party verification services.

4.1 Registration Data

  • Full legal name
  • Date of birth (for age verification)
  • Email address
  • Mobile phone number
  • Residential address (including city — e.g. Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
  • Chosen username and encrypted password

4.2 KYC & Verification Data

  • Government-issued photo identification (e.g. CNIC, passport, driving licence)
  • Proof of address documentation
  • Payment method verification documents (e.g. bank statement header, mobile wallet screenshots — without full account numbers where possible)
  • Source of funds documentation where enhanced due diligence is required

4.3 Transaction Data

  • Deposit and withdrawal amounts, dates and payment method references
  • Account balance history
  • Bonus credit and redemption records
  • Bet and game history, including stake amounts, odds, outcomes and timestamps

4.4 Technical & Usage Data

  • IP address and approximate geolocation derived from IP
  • Device type, operating system and browser information
  • Session duration, page views and feature interactions
  • Cookies and similar tracking technologies (see Section 10)
  • Log data including access timestamps and error reports

4.5 Communications Data

  • Support messages, live chat transcripts and email correspondence
  • Responsible gambling interaction records (limit-setting, self-exclusion requests)
  • Marketing preference records and opt-in / opt-out history

Special Category Data: 91pk does not intentionally collect special category data (such as health, religious or political information). If you choose to disclose such information voluntarily in a support communication, it will be handled with heightened care and not used for any purpose beyond addressing the specific query you raised.

Section 05

How We Use Your Data

91pk processes your Personal Data for the following stated purposes. Data is not used for any purpose incompatible with those set out below without your prior consent or a valid legal basis.

Purpose Data Categories Used Basis
Account registration and management Registration data, KYC data Contract performance
Identity and age verification (KYC) KYC data, registration data Legal obligation / contract
Processing deposits, withdrawals and bet settlement Transaction data, payment method references Contract performance
Anti-money laundering (AML) and fraud prevention Transaction data, KYC data, technical data Legal obligation / legitimate interest
Responsible gambling monitoring and limit enforcement Transaction data, communications data Legitimate interest / contract
Customer support and dispute resolution Communications data, transaction data, account data Contract performance / legitimate interest
Platform security and abuse prevention Technical data, transaction data Legitimate interest
Marketing communications (where opted in) Registration data, preference records Consent
Platform analytics and performance improvement Technical data, usage data (aggregated / pseudonymised) Legitimate interest
Section 06

Legal Basis for Processing

Where applicable data protection law requires a lawful basis for processing Personal Data, 91pk relies on the following bases:

  • Contract Performance: Processing necessary to perform the contract between you and 91pk — including account registration, bet processing, deposit and withdrawal handling, and KYC verification.
  • Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, identity verification requirements and data retention mandates imposed by the operator's license jurisdiction.
  • Legitimate Interests: Processing necessary for 91pk's legitimate business interests — including fraud prevention, platform security, responsible gambling monitoring and performance analytics — provided those interests are not overridden by your data-protection rights.
  • Consent: Where processing is based on your freely given, specific and informed consent — primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
Section 07

Data Sharing & Processors

91pk does not sell, rent or trade your Personal Data to any third party. We share data with carefully selected service providers only where necessary to deliver Platform services, and only under contractual data-protection obligations.

Categories of third parties with whom data may be shared include:

  • KYC / Identity Verification Providers: To verify the identity and age of registered users as required by applicable regulations.
  • Payment Processors: To facilitate the processing of deposits and withdrawals. Note: Easypaisa, JazzCash, Raast and banking institutions referenced contextually on the Platform are independent providers; their own privacy policies govern data they independently collect.
  • AML / Fraud Detection Providers: To screen transactions and user activity against risk indicators and sanctions lists.
  • Platform Technology Providers: Including game content studios, sports data feed providers and platform infrastructure suppliers, under strict data-processing agreements.
  • Customer Support Tooling: Third-party live chat or helpdesk platforms used to deliver support services, operating under data-processor agreements.
  • Regulatory Authorities and Law Enforcement: Where disclosure is required by law, court order or regulatory instruction. 91pk will endeavour to notify you of any such disclosure where legally permissible.

No Marketing Sharing: 91pk does not share your Personal Data with third-party marketers, advertising networks or data brokers for the purpose of serving targeted advertisements on other platforms.

Section 08

International Data Transfers

As an international platform, 91pk may process or store Personal Data in jurisdictions outside your country of residence, including countries where data protection laws may differ from those applicable in Pakistan. Where such transfers occur, 91pk implements safeguards to ensure that your data receives an equivalent level of protection, including:

  • Standard contractual clauses (SCCs) or equivalent mechanisms incorporated into data-processing agreements with third-party processors
  • Restricting cross-border transfers to jurisdictions with recognised adequacy frameworks where operationally possible
  • Due diligence assessments on third-party processors operating in high-risk transfer territories

If you have specific questions about the countries to which your data may be transferred, please contact 91pk using the details in Section 16.

Section 09

Data Retention

91pk retains Personal Data only for as long as is necessary to fulfil the purposes set out in this Policy, or as required by applicable legal and regulatory obligations. The following general retention framework applies:

Data Category Retention Period Basis
Account registration data Duration of account + 5 years post-closure (minimum) AML / regulatory obligation
KYC documents Duration of account + 5 years post-closure (minimum) Legal obligation (license conditions)
Transaction and betting records Minimum 5 years from transaction date AML / regulatory obligation
Support communications 3 years from last interaction Legitimate interest / dispute resolution
Technical / log data Up to 12 months Security / legitimate interest
Marketing preference records Until consent withdrawn + 3 years Consent / legal obligation

Following the expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be attributed to an identified individual.

Section 10

Cookies & Tracking Technologies

91pk uses cookies and similar technologies to operate and improve the Platform. A cookie is a small text file placed on your device by the Platform when you visit. Cookies do not contain executable code and cannot be used to access other data on your device.

Cookie Category Purpose Basis
Strictly Necessary Session management, authentication, security tokens, CSRF protection. Essential for the Platform to function — cannot be disabled. Contract / legitimate interest
Functional Remembering your preferences (language, display settings), live chat continuity. Legitimate interest
Analytics Aggregated / pseudonymised data on page views, feature usage and session flow — used to improve the Platform. No individual profiling. Legitimate interest

91pk does not use advertising or retargeting cookies. No cookie data is shared with advertising networks. You can manage cookie preferences through your browser settings; disabling strictly necessary cookies will affect Platform functionality.

Section 11

Your Data Rights

Depending on the data protection laws applicable in your jurisdiction, you may have some or all of the following rights in relation to your Personal Data held by 91pk. To exercise any of these rights, contact 91pk support using the details in Section 16. We will acknowledge your request within a reasonable timeframe and respond substantively within 30 days, unless an extension is required and you are notified accordingly.

Right of Access

You have the right to request a copy of the Personal Data 91pk holds about you, together with information on how it is processed. This is sometimes called a Subject Access Request (SAR).

Right to Rectification

If any Personal Data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Some data can be updated directly within your Account settings.

Right to Erasure ("Right to be Forgotten")

You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where consent has been withdrawn, or where processing is unlawful. This right is subject to overriding legal retention obligations — for example, AML and KYC records must be retained for minimum statutory periods regardless of erasure requests.

Right to Restriction of Processing

You may request that 91pk restrict processing of your data in certain circumstances — for example, where you contest the accuracy of data while a rectification request is pending.

Right to Data Portability

Where processing is based on consent or contract and carried out by automated means, you have the right to receive your data in a structured, commonly used and machine-readable format, and to request transfer to another controller where technically feasible.

Right to Object

You have the right to object to processing based on legitimate interests, and to object at any time to processing of your data for direct marketing purposes. Where you object to marketing, processing will cease immediately.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time by contacting support or by using the opt-out controls within your Account settings. Withdrawal does not affect the lawfulness of processing that took place prior to withdrawal.

Section 12

Children's Privacy

The 91pk Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. 91pk does not knowingly collect Personal Data from individuals below the applicable minimum age.

Age verification is a mandatory step within the KYC process. Any Account found to have been registered by or on behalf of an underage individual will be immediately closed, all funds handled in accordance with applicable regulatory guidance, and the matter escalated as required by law.

If you have reason to believe that a person under the minimum age has registered an Account on 91pk, please contact support immediately using the details in Section 16.

Section 13

Security Measures

91pk implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

  • TLS encryption for all data transmitted between your device and the 91pk Platform
  • Encryption or hashing of passwords and sensitive authentication credentials at rest
  • Role-based access controls limiting staff access to Personal Data to those with a legitimate operational need
  • Regular security reviews of platform infrastructure, access logs and third-party processor controls
  • Incident response procedures for identifying, containing and notifying relevant parties of any data breach

Your Role in Security: You are responsible for maintaining the confidentiality of your Account password. Use a strong, unique password and enable any available two-factor authentication. Never share your credentials with any third party. If you suspect unauthorised access to your Account, contact 91pk support immediately.

Despite 91pk's security measures, no data transmission over the internet or electronic storage system is completely secure. We cannot guarantee absolute security and accept no liability for interceptions or breaches outside our reasonable control.

Section 14

Pakistan Privacy Context

Pakistan's primary data-related legislation currently includes the Prevention of Electronic Crimes Act (PECA) 2016 and the Personal Data Protection Bill, which has been under parliamentary consideration. 91pk acknowledges this regulatory context and endeavours to apply data-handling practices consistent with internationally recognised privacy principles, regardless of whether Pakistan-specific law formally imposes a given requirement.

91pk does not claim to be regulated, endorsed or supervised by the State Bank of Pakistan, the Pakistan Telecommunication Authority (PTA) or any other Pakistani governmental authority in relation to data protection or any other matter. References to Pakistani payment methods (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are for contextual familiarity only; those providers' independent privacy policies govern any data they collect directly from users through their own services.

Not Legal Advice: This section is informational only and does not constitute legal advice on Pakistani data protection law. Users with specific concerns about data privacy rights under Pakistani law should consult a qualified legal professional.

Section 15

Policy Amendments

91pk reserves the right to update this Privacy Policy at any time. Where material changes are made — for example, changes to the categories of data we collect, the purposes for which we use data, or the third parties with whom we share data — we will notify registered Users via the email address associated with their Account or via a prominent notice on the Platform, providing a reasonable period for review before the changes take effect.

Non-material changes (such as typographical corrections, clarifications of existing practices or administrative updates) may be made without advance notice. The version date displayed at the top of this page indicates the most recent revision. Continued use of the Platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

Section 16

Contact & Complaints

For all data protection queries, Subject Access Requests, rights exercise requests and privacy-related complaints, please contact 91pk through the following channels:

  • Email: [email protected] (plain text only — not a clickable link)
  • Live Chat: Available within your Account dashboard during published support hours
  • Help Centre: Accessible via your Account settings for self-service data queries

When submitting a data rights request, please include: your full name as registered, your Account username, the specific right you wish to exercise, and any supporting context that helps us locate and process your request accurately. Identity verification may be required before a request can be actioned, to prevent unauthorised access to another person's data.

91pk will acknowledge all data rights requests within 5 business days and will provide a substantive response within 30 calendar days. If your request requires additional time to process, we will notify you of the extension and the reason for it.

Complaints: If you are dissatisfied with how 91pk has handled your Personal Data or responded to a rights request, you may have the right to lodge a complaint with the supervisory authority in your jurisdiction. 91pk encourages you to contact us in the first instance so we have the opportunity to address your concern directly.

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Privacy Understood — Back to 91pk

Now that you understand how 91pk handles your data, head back to the homepage to explore cricket markets, live casino games and more. Your data, your rights, your platform. Adults 18+ only.

18+ Only — or the higher minimum required by the operator/license jurisdiction. Local laws may restrict gambling in Pakistan. This site does not constitute legal advice.