Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how WinPKS ("we", "us", "our" or "the Platform"), available at https://winpks.cam, collects, uses, stores, discloses and protects the personal data of individuals who access or use the WinPKS platform. WinPKS is an English-language online gaming information service operated for users in the Pakistan market.

We are committed to protecting the privacy and security of all users, including those based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar and elsewhere across Pakistan. This Policy is written in plain English to ensure you can understand exactly how your data is handled — not buried in impenetrable legal language.

By accessing or using WinPKS, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any aspect of this Policy, you must not use the Platform.

Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" — Any information relating to an identified or identifiable natural person. This includes, but is not limited to, name, email address, date of birth, CNIC or passport number, IP address, device identifiers and financial transaction data.
• "Processing" — Any operation or set of operations performed on personal data, including collection, recording, organisation, structuring, storage, adaptation, retrieval, use, disclosure, dissemination, restriction, erasure or destruction.
• "Data Subject" — The identified or identifiable natural person to whom personal data relates — i.e., you, the user of WinPKS.
• "Data Controller" — The entity that determines the purposes and means of processing personal data. For the purposes of this Policy, WinPKS acts as the Data Controller in respect of user data collected via the Platform.
• "Data Processor" — An entity that processes personal data on behalf of the Data Controller, such as a payment processing provider or KYC verification service.
• "Cookies" — Small text files stored on your device by the Platform to enable functionality, remember preferences and collect usage analytics.
• "KYC" — Know Your Customer — identity and age verification procedures required before access to certain platform features.
• "AML" — Anti-Money Laundering — regulatory controls and compliance processes designed to detect and prevent financial crime.

Data We Collect

WinPKS collects different categories of personal data depending on how you interact with the Platform. The categories and specific types of data we collect are set out below.

3.1 Registration Data

When you create a WinPKS account, we collect: full name; email address; date of birth; username; password (stored as a one-way cryptographic hash); country of residence; and, where applicable, your city (for example, Karachi, Lahore or Islamabad).

3.2 Identity Verification (KYC) Data

To comply with age verification and anti-fraud requirements, we may collect: a copy of your valid Pakistani CNIC or passport; a selfie or liveness verification image; and, where required by the Operator, a proof of address document.

3.3 Financial Data

In connection with deposits and withdrawals, we may collect: transaction amounts in PKR; payment method references (e.g., Easypaisa account reference, JazzCash number, Raast ID, bank account details for institutions such as HBL, UBL, Meezan Bank or Bank Alfalah); and transaction history. We do not store raw card data. Payment provider names are referenced as context familiar to Pakistani users — they do not imply provider endorsement or affiliation with gambling activities.

3.4 Technical Data

Automatically collected when you access WinPKS: IP address; device type and operating system; browser type and version; session duration and page interaction data; referring URL; and geolocation data (country/city level only, derived from IP address).

3.5 Communications Data

When you contact our support team via email, live chat or any other channel, we retain the content of those communications, including your enquiry, our responses and any attachments.

How We Collect Data

WinPKS collects personal data through the following methods:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, or contact customer support.
• Automatically — through the use of cookies, web beacons, server log files and similar technologies when you visit or interact with the Platform.
• From third-party service providers — such as KYC verification providers, payment processors and fraud detection services, who may share data with us in the course of providing their services to the Platform.
• From public sources — where permitted by applicable law, we may supplement your data with information from publicly available databases for fraud prevention or compliance purposes.

Data Processing

WinPKS processes your personal data for the following purposes:

• Account administration — Creating and managing your user account, authenticating login sessions, processing password resets and maintaining your account preferences.
• Identity and age verification (KYC) — Verifying that you are the person you claim to be and confirming that you meet the minimum age requirement (18+ or the higher age mandated by the Operator's license jurisdiction).
• Transaction processing — Processing PKR deposits and withdrawals, maintaining transaction records and resolving payment disputes.
• Fraud prevention and AML compliance — Monitoring transactions and account behaviour for indicators of fraud, money laundering or other financial crime, and reporting to relevant authorities where legally required.
• Customer support — Handling enquiries, complaints and technical support requests submitted by users. English and Urdu language support is available.
• Platform improvement — Analysing aggregated usage data to improve Platform performance, user experience and content relevance for Pakistani users.
• Legal compliance — Fulfilling obligations under applicable laws, responding to lawful requests from regulatory authorities or courts, and enforcing our Terms and Conditions.
• Communications — Sending you transactional communications (such as account confirmations, withdrawal notifications and security alerts) and, where you have opted in, marketing communications about WinPKS promotions and features.

Legal Basis for Processing

WinPKS processes your personal data only where a lawful basis exists for doing so. The primary legal bases relied upon are:

• Contractual necessity — Processing required to perform our contract with you, including account registration, transaction processing and KYC verification.
• Legitimate interests — Processing necessary for our legitimate business interests, such as fraud prevention, platform security, analytics and improving the platform, provided those interests are not overridden by your rights and interests.
• Legal obligation — Processing required to comply with applicable laws and regulations, including AML obligations, regulatory reporting requirements and responses to lawful authority requests.
• Consent — Where we rely on your consent as the lawful basis (for example, for certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Data Sharing & Disclosure

WinPKS does not sell, rent or trade your personal data. We may share your data with third parties only in the limited circumstances described below:

7.1 Service Providers

We work with carefully selected third-party service providers who process data on our behalf, including: KYC and identity verification providers; payment processing partners; fraud detection and AML compliance services; cloud hosting and infrastructure providers; and customer support software platforms. All such providers are bound by data processing agreements and may not use your data for any purpose other than providing services to WinPKS.

7.2 Legal and Regulatory Disclosure

We may disclose your personal data where required or permitted by applicable law, including in response to valid court orders, subpoenas, regulatory requests or other lawful authority demands. We will notify you of such disclosures where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of WinPKS or its assets, your personal data may be transferred to the acquiring or successor entity. You will be notified of any such transfer and the applicable privacy terms will be updated accordingly.

Cookies & Tracking Technologies

WinPKS uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files placed on your device when you visit the Platform. They do not contain personally identifiable information on their own but may be combined with other data to identify you.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies — Essential for the Platform to function. These include session authentication cookies, security tokens and load-balancing cookies. You cannot opt out of these while using the Platform.
• Analytics Cookies — Help us understand how users interact with WinPKS — which pages are visited most frequently, where users drop off and how the platform can be improved. These use aggregated, anonymised data.
• Preference Cookies — Remember your settings and preferences (such as language and display options) to provide a more personalised experience.
• Marketing Cookies — Where you have provided consent, these cookies may be used to present relevant content or offers based on your browsing behaviour. You may withdraw consent at any time.

8.2 Managing Cookies

You may control and delete cookies through your browser settings. Most browsers allow you to refuse cookies entirely, delete existing cookies or alert you before a cookie is placed. Please note that disabling certain cookies may affect Platform functionality. For guidance on managing cookies in your specific browser, consult your browser's help documentation.

Data Retention

WinPKS retains personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, resolve disputes and enforce our agreements.

The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with WinPKS, plus a period of up to five (5) years following account closure to satisfy potential legal and regulatory requirements.
• KYC / Identity Documents: Retained for the period required by the Operator's licensing jurisdiction anti-money laundering regulations — typically five (5) years from the date of the last transaction or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years in accordance with standard AML and financial record-keeping requirements.
• Customer Support Communications: Retained for up to three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or regulatory compliance.
• Cookie and Analytics Data: Retained in accordance with the applicable cookie policy, typically for no more than thirteen (13) months from the date of collection.

At the end of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

Data Security

WinPKS implements appropriate technical and organisational 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 device and the WinPKS Platform is encrypted in transit using industry-standard SSL/TLS protocols. Our HTTPS connection is enforced across all pages.
• Encrypted Data Storage: Sensitive data, including identity documents and financial records, is stored using encryption at rest.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All personnel with access to personal data are subject to confidentiality obligations.
• Password Security: User passwords are stored as one-way cryptographic hashes — we cannot retrieve your original password, only reset it.
• Monitoring and Incident Response: WinPKS operates security monitoring to detect anomalous activity. In the event of a data breach that poses a risk to users, we will notify affected individuals and relevant authorities in accordance with applicable requirements.

User Rights

As a data subject, you have the following rights in relation to your personal data held by WinPKS. You may exercise these rights by contacting us at [email protected]:

• Right of Access: You have the right to request a copy of the personal data we hold about you and information about how it is processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose it was collected, or where you withdraw consent. Note that certain data may be retained where we have a legal obligation to do so (e.g., AML record-keeping requirements).
• Right to Restriction of Processing: You may request that we restrict processing of your data in certain circumstances, for example while a dispute about its accuracy is resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity, you have the right to receive your data in a structured, commonly used and machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling, where you believe your rights and freedoms override those interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

All data subject requests will be acknowledged within a reasonable timeframe and resolved as quickly as practicable, subject to any identity verification required to protect your data from unauthorised access.

Children's Privacy

WinPKS is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 18 — or the higher minimum age required by the Operator's license jurisdiction. The Platform is not directed at, marketed to or intended for use by minors.

If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on WinPKS, please contact us at [email protected] immediately.

International Data Transfers

WinPKS operates internationally and may transfer your personal data to countries outside of Pakistan for processing and storage. Where such transfers occur, we ensure that appropriate safeguards are in place to protect your data, such as standard contractual clauses or equivalent mechanisms.

Personal data transferred to our service providers (including KYC verification services, payment processors and cloud hosting providers) is subject to contractual obligations that require those providers to maintain data protection standards equivalent to those described in this Policy.

Pakistan does not currently have a comprehensive data protection law equivalent to the GDPR; however, WinPKS is committed to applying robust data protection standards regardless of the jurisdiction in which your data is processed.

Changes to This Privacy Policy

WinPKS reserves the right to update or amend this Privacy Policy at any time. When we make material changes, we will update the "Last Reviewed" date at the top of this page and, where appropriate, notify registered users via the Platform or by email.

Your continued use of WinPKS after the effective date of any revised Privacy Policy constitutes your acceptance of the changes. We encourage you to review this page periodically to stay informed about how we protect your personal data.

If you have any objection to changes in this Policy, you must discontinue your use of the Platform and, if applicable, request account closure by contacting [email protected].

Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the manner in which WinPKS handles your personal data, please contact our Data Protection team using the details below. We aim to acknowledge all enquiries promptly and respond fully within a reasonable timeframe.

English and Urdu language support is available via live chat during business hours. For responsible gambling concerns or self-exclusion requests, please visit our dedicated Responsible Gambling page.