Privacy Policy — WinPK

1 Introduction

WinPK ("we", "us", "our") operates the online information and entertainment platform accessible at https://winpk.cam ("the Platform"). WinPK is an English-language content site targeting users in the Pakistan market, providing educational guides, game information and platform reviews relating to online sports betting and casino gaming.

This Privacy Policy describes how WinPK collects, uses, discloses, stores and protects personal data obtained from individuals ("Users", "you") who visit, register on or otherwise interact with the Platform. It applies to all personal data processed by WinPK in connection with the operation of the Platform, regardless of whether the User is located in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or any other location.

This Privacy Policy should be read in conjunction with our Terms & Conditions, which govern the overall use of the Platform and are incorporated herein by reference.

2 Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers and usage data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data. WinPK is the Data Controller for Personal Data collected via the Platform.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a binding agreement.
• "Cookies" means small text files stored on your device by a web browser when you visit a website, used to retain session information and preferences.
• "KYC" means Know Your Customer — the identity verification process applied to registered users.
• "Platform" means the WinPK website at https://winpk.cam and all associated pages and services.

3 Data Controller

WinPK is the Data Controller for all Personal Data collected through the Platform. As Data Controller, WinPK determines the purposes for which your Personal Data is processed and the means by which that processing occurs.

WinPK is not a licensed gambling operator and does not process financial transaction data on behalf of any third-party operator. Any Personal Data you provide directly to an operator referenced on the Platform is governed by that operator's own privacy policy, not this one. WinPK has no visibility into or control over data submitted to third-party operators.

For all data-related queries, please contact us using the details provided in Section 17 of this Policy.

4 Personal Data We Collect

WinPK collects the following categories of Personal Data:

4.1 Registration & Account Data

• Full name
• Email address
• Username and password (stored in hashed form — never in plain text)
• Date of birth (for age verification purposes)
• City or region of residence (e.g., Karachi, Lahore, Islamabad)

4.2 Identity Verification (KYC) Data

• Government-issued identification number (e.g., CNIC)
• Copies of identity documents where required for account verification
• Selfie or proof-of-identity photographs where applicable

4.3 Technical & Usage Data

• IP address and approximate geolocation
• Browser type and version
• Device type, operating system and screen resolution
• Pages visited, time spent on page and navigation path
• Referring URL and exit URL
• Session identifiers and Cookie data

4.4 Communication Data

• Email correspondence with WinPK support
• Live chat transcripts
• Feedback and survey responses

5 How We Collect Personal Data

WinPK collects Personal Data through the following channels:

• Direct collection: When you register an account, complete a contact form, subscribe to notifications or correspond with our support team.
• Automated collection: Through server logs, Cookies and analytics tools as you browse the Platform.
• KYC submissions: When you submit identity documents as part of the verification process.
• Third-party sources: In limited circumstances, we may receive data from identity verification service providers used to complete KYC checks, subject to those providers' own data-sharing terms.

6 Legal Basis for Processing

WinPK processes your Personal Data on the following legal bases:

7 Data Processing & Use

WinPK uses your Personal Data for the following purposes:

• Creating and managing your registered WinPK account;
• Verifying your identity and age to ensure compliance with the 18+ (or higher) access requirement;
• Personalising content and recommendations to your preferences and location within Pakistan;
• Communicating with you in response to support queries, feedback or account notifications;
• Sending marketing emails or platform updates where you have provided explicit consent;
• Analysing aggregate usage patterns to improve Platform performance and content quality;
• Detecting, investigating and preventing fraudulent, abusive or unlawful activity;
• Complying with applicable legal, regulatory and anti-money laundering obligations;
• Enforcing the Terms & Conditions and other applicable policies.

WinPK does not use your Personal Data to make fully automated decisions that produce legal or similarly significant effects on you without human oversight. Where automated profiling is used for content personalisation, you have the right to request human review.

8 Cookies & Tracking Technologies

WinPK uses Cookies and similar tracking technologies to operate the Platform, analyse usage and improve the user experience. The following Cookie categories are used:

You may manage or withdraw Cookie consent at any time through your browser settings. Disabling strictly necessary Cookies may impair Platform functionality. Disabling analytics or marketing Cookies will not affect your ability to browse the Platform.

9 Data Sharing & Disclosure

WinPK does not sell, rent or trade your Personal Data to third parties for their own marketing purposes. We may share Personal Data with the following categories of recipient, strictly on a need-to-know basis and subject to binding data-processing agreements:

• Identity verification providers: To perform KYC and AML checks on registered users.
• Cloud hosting and infrastructure providers: To store and serve Platform content and user data securely.
• Analytics providers: To receive aggregated, anonymised usage statistics for Platform improvement.
• Email and communication service providers: To deliver transactional and marketing communications where consent is given.
• Legal and regulatory authorities: Where required by law, court order or regulatory directive applicable to WinPK's operations.

10 Data Retention

WinPK retains Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal obligations. The following indicative retention periods apply:

• Account registration data: Retained for the duration of the account relationship, plus up to 5 years following account closure for legal and compliance purposes.
• KYC / identity verification data: Retained for a minimum of 5 years from the date of verification, in line with anti-money laundering record-keeping requirements.
• Technical and usage data: Typically aggregated and anonymised within 13 months; raw log data deleted within 90 days.
• Support correspondence: Retained for up to 3 years from the date of the last communication.
• Marketing consent records: Retained for the period of consent plus sufficient time to demonstrate compliance in the event of a dispute.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents re-identification.

11 Data Security

WinPK implements appropriate technical and organisational measures to protect Personal Data against unauthorised access, accidental loss, destruction or alteration. Security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your browser and our servers;
• Encryption at rest for sensitive data fields including passwords (stored as salted hashes) and identity document data;
• Role-based access controls ensuring that only authorised personnel can access specific categories of Personal Data;
• Regular security audits and vulnerability assessments of Platform infrastructure;
• Two-factor authentication available for all registered accounts;
• Incident response procedures to detect, contain and report data breaches within required timeframes.

While WinPK takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. We encourage you to use a strong, unique password for your WinPK account and to enable two-factor authentication where available.

12 Your Rights

Subject to applicable law, you have the following rights with respect to your Personal Data held by WinPK. To exercise any of these rights, contact us using the details in Section 17.

We will respond to all valid rights requests within 30 days. Where a request is complex or numerous, we may extend this period by a further 30 days, in which case we will notify you. We will not charge a fee for most requests unless they are manifestly unfounded, repetitive or excessive.

13 Children's Privacy

As part of the account registration process, WinPK requires users to confirm their date of birth. Where discrepancies are detected, we may request KYC documentation to verify age before granting full account access.

14 International Data Transfers

WinPK may transfer your Personal Data to service providers or infrastructure partners located outside Pakistan. Where such transfers occur, WinPK takes appropriate safeguards to ensure that your data receives a level of protection consistent with the principles set out in this Privacy Policy.

Safeguards may include contractual clauses binding the recipient to adequate data-protection standards, or selection of processors in jurisdictions with recognised data-protection frameworks. You may request information about the specific safeguards in place for any international transfer by contacting us.

15 Pakistan Context & Legal Disclaimer

WinPK acknowledges that users accessing the Platform from Pakistan are subject to Pakistani law, including the Prevention of Electronic Crimes Act 2016 (PECA), the Pakistan Telecommunication (Re-organisation) Act 1996 and the Prevention of Gambling Act 1977, among other applicable statutes.

WinPK does not claim that operation of this Platform or processing of your data has been approved by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan or any provincial authority. This Privacy Policy is not legal advice. Users are solely responsible for understanding and complying with all applicable Pakistani laws in connection with their use of the Platform and any gambling-related activities.

References to payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are made solely as contextual references familiar to Pakistani users. WinPK does not process payments through any of these providers and makes no representation regarding their policies on gambling-related transactions.

16 Policy Amendments

WinPK reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users by email or through a prominent Platform notice.

Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised Policy, please discontinue use of the Platform and request account closure. We recommend reviewing this page periodically to stay informed.

17 Contact Us

For all privacy-related queries, data subject rights requests or complaints, please contact the WinPK Data Privacy team. We aim to acknowledge all requests within 5 business days and resolve them within 30 days.