29pak Privacy
Policy

1 Introduction

This Privacy Policy ("Policy") describes how 29pak ("the Company," "we," "us," or "our") collects, processes, stores, and protects personal data relating to users ("Player," "you," or "your") of the 29pak platform, accessible at https://29pak.net and any associated mobile applications or software (collectively, the "Platform").

29pak is committed to protecting the privacy of all Pakistani players who engage with our platform. We understand that trust is foundational to the relationship between a player and their gaming provider, and we take our obligations in this area seriously. This Policy has been written to be as clear and straightforward as possible, so that you can make informed decisions about how you share your information with us.

By registering a 29pak account or using the Platform in any capacity, you acknowledge that you have read this Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree to this Policy, you must not use the 29pak Platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement between you and 29pak.

2 Data Controller

For the purposes of applicable data protection law, 29pak is the data controller in respect of all personal data collected through the Platform. As data controller, 29pak is responsible for determining the purposes and means by which your personal data is processed. Decisions about what data is collected, how it is used, and how long it is retained are made by 29pak in accordance with this Policy and applicable legal and licensing obligations.

Where 29pak engages third-party service providers to process data on its behalf — for example, payment processors, game studios, or identity verification providers — those parties act as data processors under contract with 29pak and are bound by strict confidentiality and data protection obligations.

3 Personal Data We Collect

29pak collects personal data through several channels, including during account registration, when you interact with Platform features, when you contact support, and automatically as you use the site. The categories of personal data we collect are detailed in the table below:

4 Legal Basis for Processing

29pak processes your personal data on the following legal grounds, depending on the nature and purpose of the processing activity:

• Contractual Necessity: Processing your data is necessary to perform the contract between you and 29pak — for example, operating your account, processing deposits via JazzCash or EasyPaisa, and settling your bets and withdrawals.
• Legal Obligation: We are required by our international gaming license to carry out KYC identity verification, maintain anti-money laundering records, and report certain transactions to regulatory authorities. This processing is mandatory and cannot be declined.
• Legitimate Interests: 29pak processes certain data on the basis of legitimate business interests, including fraud prevention, platform security, improving our services, and detecting patterns indicative of problem gambling. We assess that these interests are not outweighed by your privacy rights in these specific contexts.
• Consent: Where we send you promotional communications about 29pak offers, bonuses, or new games, we do so on the basis of your consent. You may withdraw your consent to marketing communications at any time via your account settings or by contacting support.

5 How We Use Your Personal Data

29pak uses your personal data for the following purposes:

5.1 Account Management and Platform Services

We use your registration data to create and manage your 29pak account, process your 29pak login sessions, verify your identity at onboarding and during periodic KYC checks, and respond to your support requests. Without this processing, we cannot operate the Platform for you.

5.2 Payment Processing

Your financial data is used to process PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank. We pass minimum required data to payment processors to facilitate transactions. We do not store full bank account numbers or JazzCash PINs on our servers.

5.3 Regulatory Compliance and Anti-Fraud

29pak is obligated under its gaming license to verify player identities, monitor transactions for suspicious activity, and maintain records for anti-money laundering (AML) compliance purposes. Your data may be analysed by our compliance systems to detect unusual betting patterns, multi-account activity, or payment anomalies that suggest fraudulent behaviour.

5.4 Responsible Gaming Monitoring

We analyse account activity data to identify behavioural patterns associated with problem gambling — such as rapidly escalating deposit sizes, unusual session lengths, or frequent self-exclusion requests followed by return. Where such patterns are detected, our responsible gaming team may proactively reach out to affected players. This processing is carried out in the interests of player welfare.

5.5 Platform Improvement and Analytics

Aggregated and anonymised technical and behavioural data is used to improve the 29pak Platform, optimise game performance, identify technical issues, and enhance the overall player experience. This analysis does not involve identifying individual players and uses data that cannot be traced back to you personally.

5.6 Marketing Communications

With your consent, 29pak may send you promotional messages about new games, bonus offers, and platform updates via SMS to your registered Pakistani mobile number or via email. You can opt out of marketing communications at any time and this will not affect your ability to use the Platform.

6 Data Sharing and Disclosure

29pak does not sell your personal data to third parties. We may share your data in the following limited circumstances only:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card processors receive the minimum data necessary to facilitate your transactions. These parties have their own privacy policies and are bound by PCI-DSS payment data standards.
• Game Providers: Licensed third-party game studios that supply casino and slot games on the 29pak Platform receive anonymised session data necessary to operate games and resolve disputes. They do not receive your full identity details.
• Identity Verification Services: Where required for KYC, your identity documents and personal details may be passed to licensed identity verification service providers. These providers are contractually bound to use your data solely for verification purposes.
• Regulatory and Law Enforcement Authorities: 29pak will disclose personal data to gaming regulators, financial intelligence units, or law enforcement agencies where legally compelled to do so under applicable law or our licensing obligations.
• Legal Proceedings: We may disclose data where necessary to establish, exercise, or defend legal claims involving 29pak or its players.

7 Data Retention

29pak retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and our gaming license obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active account with 29pak, plus a minimum of 5 years following account closure, in compliance with gaming license and anti-money laundering record-keeping requirements.
• KYC Documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later, as required by AML regulations.
• Transaction Records: Retained for a minimum of 5 years from the date of the transaction.
• Support Communications: Retained for 2 years from the date of the relevant interaction, unless the content forms part of a formal complaint or legal matter.
• Marketing Consent Records: Retained for the duration of your consent or until you withdraw it, plus 1 year thereafter for accountability purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual player.

8 Data Security

29pak implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• TLS 1.2/1.3 encryption for all data transmitted between your device and the 29pak Platform.
• One-way cryptographic hashing of player passwords — 29pak staff cannot read your password.
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent necessary for their specific role.
• Regular security assessments and penetration testing of Platform infrastructure.
• Secure, encrypted storage of KYC documents and verification data.
• PCI-DSS compliant handling of all payment data through certified third-party processors.

While 29pak takes all reasonable steps to secure your data, no internet-based platform can guarantee absolute security against all threats. You are responsible for keeping your 29pak login credentials confidential and for reporting any suspected unauthorised access to your account immediately.

9 Cookies & Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device by your browser when you visit the 29pak Platform. They allow us to recognise your device on return visits and to provide a consistent, personalised experience. Cookies do not contain your password or payment information.

9.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your 29pak account during a session. You cannot opt out of essential cookies while using the Platform.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and game lobby filters. These improve your experience but are not strictly necessary.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform — such as which pages are visited most, session duration, and navigation paths. This helps us improve the Platform.
• Security Cookies: Used to detect suspicious login activity, bot traffic, and other security threats. These help us protect your account.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Most modern browsers allow you to block or delete cookies, though disabling essential cookies will prevent you from logging in to your 29pak account. For detailed guidance on managing cookies in your specific browser, refer to your browser's help documentation.

10 Minors and Under-21 Policy

The 29pak Platform is strictly intended for use by individuals who are 21 years of age or older. 29pak does not knowingly collect personal data from any person under the age of 21. Our registration process includes age verification steps, and we conduct additional KYC checks where age is uncertain.

If we become aware that a player under the age of 21 has registered an account and provided personal data, we will immediately close the account, delete all associated personal data to the extent permitted by our legal retention obligations, and return any deposited funds. If you believe a minor has registered on the 29pak Platform, please contact us immediately at [email protected].

11 Your Data Rights

As a player on the 29pak Platform, you have the following rights regarding your personal data. To exercise any of these rights, please contact our support team with "Data Privacy Request" in your message:

29pak will respond to all data rights requests within 30 days of receipt. We may request proof of identity before processing your request to ensure we are dealing with the account holder. Where a request is declined, we will explain the reason in writing. Note that some data — particularly KYC and transaction records — may be retained even after an erasure request where retention is required by law or our gaming license obligations.

12 International Data Transfers

As 29pak operates under an international gaming license and uses globally-hosted technology infrastructure, your personal data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, 29pak ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy. These safeguards may include standard contractual clauses, data processing agreements, or transfer to countries with recognised adequate data protection frameworks.

By using the 29pak Platform and agreeing to this Policy, you consent to the transfer of your personal data to other jurisdictions as described in this section.

13 Changes to This Privacy Policy

29pak reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered players via notification upon 29pak login or by email to the registered address. Minor clarifications or non-substantive changes may be made without direct notification, though the updated date at the top of this Policy will always reflect the most recent version.

Your continued use of the 29pak Platform following any change to this Policy constitutes your acceptance of the updated version. We encourage you to review this Policy periodically to stay informed about how we protect your data.

14 Contact Our Data Protection Team

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 29pak handles your personal data, please get in touch with our data protection team. We are committed to addressing all privacy-related enquiries promptly and transparently.

• Email: [email protected] — use subject line "Data Privacy Request" for all data rights requests.
• Live Chat: Available 24/7 directly on the 29pak Platform. Average response time is 3–5 minutes.
• Response Time: We aim to acknowledge all privacy enquiries within 48 hours and resolve them within 30 calendar days.