399pak Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 399pak ("399pak", "we", "us", or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you", "your", or "Member") who access or use the 399pak platform available at https://399pak.biz, including all associated games, betting services, payment facilities, and support channels.

399pak is committed to handling your personal information with transparency, integrity, and respect. We operate in accordance with internationally recognised data protection standards and the requirements set by our gaming license authority. This Policy applies to all personal data processed in connection with your 399pak account, regardless of the device or channel through which you access our services.

By registering for a 399pak account or continuing to use our platform after this Policy has been made available to you, you acknowledge that you have read and understood the practices described herein. If you do not agree with any part of this Policy, you should discontinue use of the 399pak platform and request closure of your account.

2 Data Controller

For the purposes of this Privacy Policy, 399pak acts as the data controller in respect of the personal data you provide when using the 399pak platform. As data controller, 399pak determines the purposes and means by which your personal data is processed.

If you have any questions about this Policy or wish to exercise any of your data rights as described in Section 10, you may contact our Data Privacy team directly. Contact details are provided in Section 14 of this document.

3 Data We Collect

399pak collects personal data through several channels, including information you provide directly, data generated through your use of the platform, and information received from third-party service providers. The categories of personal data we collect include:

3.1 Identity & Registration Data

• Full legal name, date of birth, and gender;
• Government-issued identification number (CNIC or passport number) for age and identity verification;
• Residential address, city, and country of residence;
• Username and account credentials (passwords are stored in hashed, non-reversible form).

3.2 Contact Data

• Email address used for account registration and communications;
• Mobile phone number for account security, two-factor authentication, and transactional notifications.

3.3 Financial & Transaction Data

• JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, or other payment method identifiers;
• Deposit and withdrawal history, transaction amounts, and timestamps;
• Cryptocurrency wallet addresses (where USDT TRC20 is used);
• Documentation submitted for KYC verification, including proof of identity and proof of payment ownership.

3.4 Usage & Behavioural Data

• Betting and gaming history, including games played, stakes placed, and outcomes;
• Session duration, login timestamps, and frequency of platform use;
• Device information including device type, operating system, browser type, and IP address;
• Clickstream data, page navigation patterns, and feature interaction logs.

3.5 Communications Data

• Records of correspondence between you and the 399pak support team via live chat or email;
• Responses to surveys, feedback forms, or promotional campaigns where you choose to participate.

4 How We Use Your Data

399pak processes your personal data for the following specific purposes:

• Account Creation & Management: To register your account, verify your identity and age (21+ requirement), maintain your account profile, and facilitate your access to 399pak services;
• Transaction Processing: To process deposits, withdrawals, and PKR-denominated transactions via your chosen payment method, and to maintain accurate financial records;
• Service Delivery: To provide you with access to cricket betting, live casino games, slot machines, Money Wheel, Star Fishing, and all other games and markets available on the 399pak platform;
• Regulatory Compliance: To fulfil obligations under applicable anti-money laundering (AML), know-your-customer (KYC), and responsible gaming frameworks, including age verification and player protection measures;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account abuse, collusion, and unauthorised access to the platform;
• Customer Support: To respond to your queries, resolve disputes, and process responsible gaming requests such as deposit limits and self-exclusion;
• Marketing Communications: Where you have provided consent, to send you promotional offers, bonus notifications, and platform updates. You may withdraw this consent at any time;
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the 399pak product experience for all members across Pakistan.

5 Legal Basis for Processing

399pak processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you accepted upon registration — including account management, transaction processing, and service delivery;
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including AML legislation, KYC obligations, and gaming license conditions;
• Legitimate Interests: Processing necessary for 399pak's legitimate business interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your fundamental rights;
• Consent: Where we rely on your consent — for example, for marketing communications — you may withdraw that consent at any time without affecting the lawfulness of prior processing.

6 Sharing Your Personal Data

399pak does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent strictly necessary:

• Payment Processors: Authorised and regulated payment service providers (including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, and crypto processors) to facilitate your deposit and withdrawal transactions;
• Identity Verification Providers: Third-party KYC and age verification services used to confirm your identity in accordance with our regulatory obligations;
• Technology & Infrastructure Providers: Cloud hosting, data storage, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Gaming Software Providers: Game developers and RNG certification bodies who supply the casino games and sports betting technology available on the 399pak platform, to the extent required for game operation and auditing;
• Regulatory & Law Enforcement Authorities: Gaming regulators, financial intelligence units, law enforcement agencies, or courts where we are legally required or permitted to disclose information;
• Professional Advisors: Legal counsel, auditors, and compliance consultants who are bound by professional confidentiality obligations.

All third parties with whom 399pak shares personal data are required to implement appropriate technical and organisational measures to protect that data and to process it only for the purposes specified by 399pak.

7 Data Retention

399pak retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, taking into account applicable legal retention obligations. Specifically:

• Active Account Data: Retained for the duration of your membership with 399pak and for a period of five (5) years following account closure, to comply with anti-money laundering record-keeping requirements;
• Transaction Records: Financial transaction data is retained for a minimum of five (5) years from the date of the transaction, in line with applicable financial regulations;
• Identity Documents: KYC documentation is retained for the period required by our gaming license authority, typically five (5) years post-account closure;
• Support Communications: Customer support records are retained for three (3) years from the date of the interaction;
• Marketing Preferences: Records of your consent to or withdrawal from marketing communications are retained for the lifetime of your account plus three years.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to you as an individual.

8 Security Measures

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

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or app and 399pak servers is encrypted in transit;
• Data Encryption at Rest: Sensitive data stored on our servers — including payment information, identity documents, and authentication credentials — is encrypted using industry-standard algorithms;
• Access Controls: Strict role-based access controls ensure that only authorised 399pak personnel can access personal data, on a need-to-know basis;
• Two-Factor Authentication: Members are encouraged to enable two-factor authentication (2FA) on their 399pak accounts for an additional layer of login security;
• Regular Security Audits: The 399pak platform undergoes periodic penetration testing and security assessments by independent security specialists;
• Incident Response: We maintain a formal data breach response plan. In the event of a security incident affecting your data, we will notify you and relevant authorities as required.

9 Cookies & Tracking Technologies

399pak uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file placed on your device when you visit the 399pak website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting core functionality;
• Functional Cookies: Used to remember your preferences such as language settings, display options, and game history to personalise your experience on return visits;
• Analytical Cookies: Used to collect aggregated, anonymised data about how members use the 399pak platform, helping us identify popular features, diagnose technical issues, and improve service quality;
• Marketing Cookies: Used — where you have provided consent — to track visits from promotional campaigns and measure the effectiveness of our marketing activities. No third-party behavioural advertising networks are used on 399pak.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may limit the functionality of the 399pak platform.

10 Your Data Rights

As a 399pak member, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact our Data Privacy team at [email protected]. We will respond to all valid requests within 30 days.

11 Minors & Age Policy

The 399pak platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect or process personal data from anyone under the age of 21. If 399pak becomes aware that personal data has been collected from a person under 21, that account will be immediately closed and the data securely deleted, with any funds held subject to investigation.

If you are a parent or guardian and believe that a minor in your care has registered on the 399pak platform, please contact us immediately at [email protected] so we can take prompt action.

12 International Data Transfers

399pak's primary operations and data storage are managed within environments that maintain appropriate data protection standards consistent with our international gaming license obligations. Where your personal data is transferred to, stored in, or processed in a jurisdiction outside Pakistan, 399pak ensures that adequate safeguards are in place, including:

• Data processing agreements with all third-party service providers that include appropriate data protection clauses;
• Use of service providers that are certified under internationally recognised security and privacy standards;
• Where required, implementation of standard contractual clauses or equivalent transfer mechanisms.

By using the 399pak platform, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan as described in this section, subject to the safeguards outlined above.

13 Changes to This Policy

399pak reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify active members via email or a prominent notice on the 399pak platform, with a minimum of seven (7) days advance notice before the updated Policy takes effect.

The most current version of this Privacy Policy is always available at https://399pak.biz/privacy-policy. The effective date at the top of this document indicates when the most recent review was completed. Your continued use of the 399pak platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

14 Contact Us & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how 399pak is handling your personal information, please contact our Data Privacy team. We take all privacy enquiries seriously and are committed to resolving them promptly.

If you are not satisfied with 399pak's response to your privacy complaint, you may have the right to escalate your concern to the relevant data protection authority or gaming regulatory body applicable in your jurisdiction. 399pak will cooperate fully with any such investigation.