Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how pr67 ("Platform", "we", "us", "our"), the operator of pr67.cam, collects, processes, stores, shares and protects personal information relating to registered users, visitors and prospective users ("you", "your") of the pr67 website and associated mobile interfaces.

By accessing or using the pr67 platform, creating an account, or interacting with any of our services, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you must discontinue use of the platform immediately.

pr67 is committed to handling your personal data responsibly, with transparency and in accordance with the data protection principles applicable under the operator's licence jurisdiction. We review and update this Policy periodically to reflect changes in our data practices, applicable law or platform functionality.

2 Definitions

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person — including name, email address, phone number, device identifiers and behavioural data — that is processed by pr67 in connection with the platform.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, alteration, retrieval, transmission or deletion.
• "Data Controller" means pr67 in its capacity as the entity that determines the purposes and means by which personal data is processed.
• "Data Processor" means any third-party service provider that processes personal data on pr67's behalf, under written agreement and subject to data processing obligations.
• "Consent" means a freely given, specific, informed and unambiguous indication of your agreement to the processing of your personal data for a stated purpose.
• "KYC Data" means identity and age verification documents submitted by a user — such as a CNIC, passport, or driver's licence — as part of the Know Your Customer process.
• "Cookie" means a small text file placed on your device by the platform's servers for purposes including session management, analytics and personalisation.
• "User Account" means the registered account held by a user on the pr67 platform through which services are accessed.

3 Data We Collect

pr67 collects personal data across several categories, depending on how you interact with the platform. The table below summarises the main categories of data we process:

We do not intentionally collect special category data (such as health information or biometric data) unless specifically required by a regulatory obligation and with your explicit consent where applicable.

4 How We Collect Data

pr67 collects personal data through several channels and mechanisms:

• Direct submission: Data you provide when registering an account, completing KYC verification, contacting customer support, setting responsible gambling limits, or updating account preferences.
• Automated technical collection: Data collected automatically when you visit or use the platform, including IP addresses, session data, device fingerprints and browsing behaviour, via server logs, cookies and similar tracking technologies.
• Transaction processing: Financial data generated when you make deposits or withdrawals through the platform's cashier. Note that pr67 does not store full payment card numbers — payment processing is handled by certified third-party payment processors.
• Third-party verification services: Identity and age verification data obtained through third-party KYC service providers who process your submitted documents on our behalf.
• Fraud and risk analytics: Behavioural and technical signals processed by anti-fraud systems to detect unusual activity, protect the integrity of the platform and comply with anti-money laundering (AML) obligations.

5 Data Processing Purposes

pr67 processes your personal data only for clearly defined and legitimate purposes. The primary purposes for which your data is used include:

• Account Management: Creating, maintaining and administering your pr67 user account, including authentication and access control.
• Identity & Age Verification (KYC): Confirming that you meet the minimum age requirement (18+, or the higher age required by the operator's licence jurisdiction) and verifying your identity to comply with regulatory obligations.
• Service Delivery: Processing bets, game activity, deposits and withdrawals, and delivering all platform features and services you use.
• Regulatory Compliance: Meeting anti-money laundering (AML), counter-terrorism financing (CTF) and responsible gambling obligations imposed by the operator's licence jurisdiction.
• Customer Support: Responding to your queries, resolving disputes, processing complaints and providing assistance through our support channels.
• Responsible Gambling Monitoring: Tracking your deposit and wagering activity to facilitate responsible gambling tools such as deposit limits, self-exclusion and reality checks, and to identify users who may need support.
• Marketing Communications: Sending promotional offers, bonus notifications and platform updates — only where you have opted in to receive such communications. You may withdraw consent at any time.
• Security & Fraud Prevention: Detecting, investigating and preventing fraudulent activity, money laundering, bonus abuse and security breaches.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve platform performance, user experience and product offerings.

6 Legal Basis for Processing

Where data protection law requires a legal basis for personal data processing, pr67 relies on the following bases depending on the purpose of processing:

• Contractual necessity: Processing required to fulfil our contractual obligations to you as a registered user — including account operation, bet settlement, transaction processing and customer support.
• Legal obligation: Processing necessary to comply with applicable legal and regulatory requirements, including KYC, AML and responsible gambling obligations under the operator's licence terms.
• Legitimate interests: Processing carried out for pr67's legitimate business interests where these are not overridden by your rights — including fraud prevention, platform security, analytics and product improvement. We conduct proportionality assessments before relying on this basis.
• Consent: Processing for purposes where you have given explicit consent — primarily for marketing communications and non-essential cookies. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

pr67 does not sell, rent or trade your personal data to any third party for their own marketing or commercial purposes. Your data may be shared only in the following circumstances and only to the extent necessary for the stated purpose:

• Service Providers & Data Processors: Trusted third-party vendors who provide services on our behalf — including KYC verification providers, payment processors, IT infrastructure providers, fraud detection services and customer support platforms. All processors operate under data processing agreements that impose confidentiality and security obligations.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order or regulatory instruction, pr67 may disclose personal data to competent authorities. We will disclose only the minimum data necessary to comply with such obligations.
• Responsible Gambling Organisations: In limited cases where a user's activity indicates a potential gambling problem, relevant data may be shared with licensed responsible gambling support services in accordance with regulatory requirements and platform policy.
• Corporate Transactions: In the event of a merger, acquisition, restructuring or sale of all or part of the platform's business, your personal data may be transferred to the relevant successor entity. Users will be notified of any such transfer in advance where reasonably practicable.
• With Your Explicit Consent: In any other circumstance where you have given specific, informed consent to the disclosure of your data to a named third party for a stated purpose.

8 International Data Transfers

pr67 operates internationally, and your personal data may be processed, stored or accessed in countries outside Pakistan. This includes the operator's licence jurisdiction and the locations of our third-party service providers, which may span multiple regions.

Where personal data is transferred internationally, pr67 takes steps to ensure that appropriate safeguards are in place to protect your data in accordance with the data protection standards applicable under the operator's licence regime. These safeguards may include:

• Standard contractual clauses or equivalent mechanisms with data processors located in third countries.
• Transfers to jurisdictions that maintain an adequate level of data protection as recognised by the relevant licensing authority.
• Technical and organisational security measures proportionate to the sensitivity of the data being transferred.

By using the pr67 platform, Pakistani users acknowledge and accept that their personal data may be transferred and processed outside Pakistan, where local data protection laws may differ from those applicable domestically.

9 Data Retention

pr67 retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, including compliance with applicable legal, regulatory, tax and accounting requirements.

The following general retention principles apply:

• Active accounts: Personal data associated with an active user account is retained for the duration of the account relationship and for a defined period thereafter.
• Closed accounts: Following voluntary or enforced account closure, pr67 typically retains core account and transaction records for a minimum of five years to satisfy AML and regulatory record-keeping requirements. The precise retention period depends on the applicable licence jurisdiction's requirements.
• KYC documents: Identity verification documents are retained for the period required by applicable AML legislation — typically a minimum of five years from the end of the customer relationship.
• Marketing data: Data used for marketing purposes is retained until you withdraw consent or opt out of communications, after which it is removed from active marketing lists within a reasonable timeframe.
• Technical/log data: Server logs and technical data are typically retained for a shorter period, sufficient for security monitoring and platform diagnostics, unless longer retention is required for an ongoing investigation.

When personal data is no longer required, it is securely deleted or anonymised in a manner that prevents re-identification.

10 Cookies & Tracking Technologies

pr67 uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate, maintain and improve the platform. Cookies are small text files stored on your device that allow the platform to recognise you across sessions and provide a personalised, functional experience.

The following categories of cookies are used on the pr67 platform:

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect the functionality or performance of the platform. pr67 does not use cookies to collect sensitive personal or financial data beyond what is described above.

11 Your Rights

Depending on the data protection laws applicable in the operator's licence jurisdiction, you may have some or all of the following rights in relation to your personal data held by pr67:

• Right of Access: You may request confirmation of whether pr67 holds personal data about you, and a copy of that data along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: In certain circumstances, you may request the deletion of your personal data. This right is subject to overriding legal retention obligations — for example, AML record-keeping requirements may prevent immediate erasure of certain account data.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in defined circumstances, such as when the accuracy of the data is contested or where processing is unlawful but you prefer restriction over deletion.
• Right to Data Portability: Where technically feasible and where processing is based on consent or contract, you may request your personal data in a structured, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Where you object to marketing, we will cease processing your data for that purpose promptly.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact the pr67 support team at the address provided in Section 16. We will respond to verified data subject requests within a reasonable timeframe. We may ask you to confirm your identity before processing a request, to protect against fraudulent or unauthorised access to another person's data.

12 Children & Minors

The pr67 platform is strictly intended for adults only. The minimum age to register and use our services is 18 years, or the higher minimum age required by the operator's licence jurisdiction. We do not knowingly collect, process or retain personal data relating to individuals under the applicable minimum age.

pr67 employs age verification measures — including KYC document checks — at the registration stage to prevent underage users from accessing the platform. Where we discover, or have reason to believe, that personal data belonging to a minor has been collected, we will take immediate steps to delete that data and close the associated account.

13 Data Security

pr67 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, disclosure or alteration. Our security practices include:

• Encryption: Data transmitted between your device and our servers is protected using Transport Layer Security (TLS) encryption. Sensitive stored data is encrypted at rest using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorised personnel who have a legitimate need-to-know basis. Role-based access controls and multi-factor authentication are applied to internal systems.
• Intrusion Detection: Continuous monitoring and intrusion detection systems are in place to identify and respond to suspicious activity or potential security incidents.
• Incident Response: pr67 maintains a data breach response procedure. In the event of a confirmed data breach that poses a risk to users' rights, we will notify affected users and relevant authorities in accordance with applicable requirements.
• Third-Party Security: All third-party data processors engaged by pr67 are required to demonstrate adequate security standards. We conduct due diligence on processors prior to engagement.

While pr67 takes all reasonable precautions, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your account credentials. If you suspect that your account has been compromised, please contact support immediately and change your password without delay.

14 Third-Party Links

The pr67 platform may contain references to third-party services, payment providers or content. These references do not constitute links to or endorsements of external websites. pr67 does not control and is not responsible for the privacy practices of any third-party platforms or services you may access independently.

This Policy applies solely to data collected and processed by pr67 through the pr67.cam platform. If you access any external service — for example, a payment processor's own interface during a transaction — that service's privacy policy will govern the handling of any data you provide to them directly. We encourage you to review the privacy policies of any third-party services you use.

15 Policy Amendments

pr67 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, regulatory requirements or platform functionality. When material changes are made, we will update the "Last updated" date at the top of this page and, where appropriate, notify registered users via a platform notice or email to the address on file.

It is your responsibility to review this Policy periodically. Continued use of the pr67 platform following any published amendment constitutes your acceptance of the revised Policy. If you do not agree with any amendment, you should cease using the platform and contact support to discuss account closure.

16 Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or want to raise a privacy-related concern, please contact the pr67 support team. We aim to acknowledge all privacy enquiries within two business days and resolve them within a reasonable timeframe.

Support is available in English. Urdu-language assistance may be available upon request.