WinkPKR Privacy Policy – How We Handle Your Personal Information

WinkPKR ("the Platform", "we", "us", "our") operates the online gaming platform at winkpkr.biz, serving players across Pakistan. For the purposes of this Privacy Policy, WinkPKR is the data controller — meaning we are the entity responsible for determining how and why your personal data is processed.

This Privacy Policy applies to all personal data collected through the WinkPKR website, any mobile-optimised version of the platform, and any direct communications between you and our support team. It applies to registered players, former players whose accounts have been closed, and visitors who browse the platform without registering.

This policy is to be read alongside the WinkPKR Terms and Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and WinkPKR. If you have questions about this policy, the contact details in Section 14 are always available.

WinkPKR collects personal data through three routes: information you provide directly when registering and using the platform, information generated automatically by your use of the platform, and information received from third parties such as payment processors.

WinkPKR does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required by law enforcement or regulatory authorities. We do not collect biometric data for routine account purposes.

WinkPKR uses your personal data only for the specific purposes set out below. We do not use personal data for any purpose that is incompatible with the reason it was collected, and we do not share it for commercial purposes with third-party organisations.

• Account operation: Creating and maintaining your WinkPKR account, processing logins, managing your account balance, and handling account-level settings including responsible gaming tools.
• Payment processing: Handling deposits and withdrawals in PKR via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, and Visa/Mastercard. Verifying that payment accounts belong to you.
• Identity verification: Confirming you meet the age requirement (18+) and that your registration details are accurate, including KYC checks before significant withdrawals.
• Legal compliance: Meeting anti-money laundering (AML) obligations, responding to lawful requests from Pakistani regulatory and law enforcement authorities, and maintaining records required by applicable law.
• Fraud prevention and security: Detecting and preventing fraudulent activity, multiple-account creation, bonus abuse, and unauthorised access to accounts.
• Customer support: Responding to queries, resolving disputes, processing complaints, and maintaining records of support interactions.
• Platform improvement: Analysing aggregated, anonymised usage data to improve platform performance, game selection, and the overall player experience.
• Responsible gaming: Monitoring for indicators of problem gambling behaviour and applying responsible gaming tools when requested or required.
• Marketing communications: Sending you information about promotions, new games, and platform updates — but only if you have opted in to receive such communications. See Section 12 for opt-out information.

WinkPKR processes your personal data on one or more of the following legal grounds, depending on the specific data and purpose involved:

• Contract performance: Processing your identity data, contact data, and financial data is necessary to operate your WinkPKR account and fulfil the Terms and Conditions you agreed to on registration.
• Legal obligation: Processing for KYC, AML compliance, fraud investigation, and regulatory reporting is required by law. We have no discretion to opt out of these obligations.
• Legitimate interests: Processing technical and transaction data for fraud prevention, platform security, and aggregated analytics serves the legitimate interests of WinkPKR and its players, without overriding your individual privacy rights.
• Consent: Marketing communications and optional cookies are processed only with your explicit consent, which you may withdraw at any time without affecting any other aspect of your account or our service to you.

WinkPKR does not sell, rent, or trade your personal data to third parties for their own commercial use. Data sharing is limited to the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment service providers: Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT networks, and Visa/Mastercard processing networks receive the transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable Pakistani financial regulations.
• Identity verification providers: Third-party KYC service providers who verify CNIC documents and other identity materials. These providers are contractually bound to use your data only for the verification purpose specified by WinkPKR.
• Game software providers: Game providers whose software runs on the WinkPKR platform receive anonymised or pseudonymised session data for technical operation purposes. They do not receive your name, payment details, or contact information.
• IT infrastructure providers: Cloud hosting, data backup, and cybersecurity service providers who process data on WinkPKR's behalf under data processing agreements with strict confidentiality and security requirements.
• Legal and regulatory authorities: Pakistani law enforcement, financial intelligence authorities, and regulatory bodies when required by law or court order. WinkPKR will notify you of such disclosures where legally permitted to do so.
• Fraud prevention networks: Shared fraud databases used to identify and prevent multi-accounting, payment fraud, and identity theft across the online gaming industry.

WinkPKR retains personal data for as long as it is needed for the purpose for which it was collected, subject to legal minimum retention requirements. The following retention periods apply:

After the applicable retention period, data is permanently deleted or irreversibly anonymised. Anonymised data (which cannot be linked back to an individual) may be retained indefinitely for statistical and analytical purposes.

WinkPKR uses cookies and similar tracking technologies on its platform. A cookie is a small text file stored on your device when you visit a website. We use cookies to keep you logged in, remember your preferences, analyse platform usage, and protect against fraud and session hijacking.

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, though blocking essential cookies will prevent you from logging in and using the WinkPKR platform. WinkPKR does not use advertising cookies or place cookies on behalf of any advertising network.

WinkPKR does not use cross-site tracking technologies that follow you to other websites after you leave the platform. Our tracking is limited to activity within winkpkr.biz itself.

WinkPKR takes the security of your personal data seriously and implements industry-standard technical and organisational measures to protect it against unauthorised access, disclosure, alteration, and destruction.

• Encryption in transit: All data transmitted between your device and WinkPKR servers is encrypted using TLS (Transport Layer Security). The WinkPKR platform is only accessible over HTTPS.
• Encryption at rest: Sensitive personal data stored on WinkPKR servers — including identity documents and financial account references — is encrypted using AES-256 encryption.
• Access controls: Access to systems containing personal data is restricted on a strict need-to-know basis. All staff with access to personal data undergo security training and are bound by confidentiality obligations.
• Two-factor authentication: WinkPKR accounts support two-factor authentication (2FA). We strongly recommend enabling 2FA to protect your account from unauthorised access.
• Penetration testing: WinkPKR's platform undergoes regular independent security testing to identify and remediate vulnerabilities.
• Incident response: In the event of a data security incident that poses a risk to player data, WinkPKR will notify affected players and relevant authorities without undue delay as required by applicable law.

As a WinkPKR player, you have the following rights over your personal data. To exercise any of these rights, contact us at privacy@winkpkr.biz. WinkPKR will respond to all valid requests within 30 days and will not charge a fee for handling your request unless it is clearly unfounded or excessive.

WinkPKR is strictly an adult platform. No person under the age of 18 is permitted to register an account, make a deposit, or participate in any game on the platform. WinkPKR does not knowingly collect personal data from anyone under 18.

If WinkPKR discovers that an account has been registered by or on behalf of a minor, the account will be immediately and permanently closed, all deposits will be returned to the originating payment account, and any winnings will be forfeited. If you believe that a minor has registered or is using a WinkPKR account, please notify us immediately at support@winkpkr.biz.

Parents and guardians are encouraged to use parental control software on shared devices to prevent minors from accessing online gaming platforms. WinkPKR supports the use of such tools and cooperates with any third-party filtering services that request our platform's categorisation data.

Some of WinkPKR's technical infrastructure — including cloud hosting, backup systems, and game software servers — may be located outside Pakistan. Where your personal data is transferred internationally, WinkPKR ensures that appropriate safeguards are in place to protect it to a standard equivalent to that required within Pakistan.

Safeguards used for international transfers include:

• Contractual clauses requiring the recipient to maintain equivalent data protection standards.
• Transfers only to service providers located in jurisdictions with adequate data protection frameworks.
• Technical safeguards including end-to-end encryption for data in transit across borders.

WinkPKR does not transfer personal data to countries that lack adequate data protection frameworks without ensuring that additional safeguards are in place. If you would like more information about the specific safeguards applicable to any particular transfer, contact privacy@winkpkr.biz.

WinkPKR will only send you promotional communications — such as information about new games, bonus offers, and platform updates — if you have given your explicit consent during registration or subsequently through your account notification settings.

You can opt out of marketing communications at any time through any of the following methods:

• Updating your notification preferences in the Communications section of your WinkPKR account settings.
• Clicking the unsubscribe link in any marketing email sent by WinkPKR.
• Contacting the support team by live chat, email at support@winkpkr.biz, or WhatsApp and requesting removal from the marketing list.

Opting out of marketing communications does not affect your ability to use the WinkPKR platform, nor will it prevent WinkPKR from sending you transactional communications that are necessary for the operation of your account — such as deposit confirmations, withdrawal notifications, and security alerts. These communications are sent regardless of marketing preferences because they relate directly to your account activity.

WinkPKR reviews and updates this Privacy Policy periodically to reflect changes in our data practices, new legal requirements, or improvements in how we explain our approach to privacy. The "Last Updated" date at the top of this page reflects when the most recent changes were made.

When material changes are made to this policy — changes that affect how we collect, use, or share your data in a meaningful way — WinkPKR will notify registered players by email and by displaying a notice on the platform before the changes take effect, giving you an opportunity to review the updated policy before it applies to your data.

Minor changes — such as clarifications, corrections to formatting, or updates that do not change the substance of our data practices — may be made without prior notice and will be effective immediately upon publication. The current version of this policy is always available at winkpkr.biz/privacy-policy.

For any questions, concerns, or requests relating to your personal data and this Privacy Policy, please contact the WinkPKR privacy team through the following channels:

• Privacy enquiries: privacy@winkpkr.biz — for data access requests, deletion requests, and privacy-specific questions.
• General support: support@winkpkr.biz — for account-related data queries and general privacy questions.
• Live chat: Available on the WinkPKR platform 24 hours a day for immediate assistance.

WinkPKR will acknowledge all privacy requests within 5 business days and provide a substantive response within 30 calendar days. In complex cases we may request an extension of up to a further 60 days — if this is necessary, we will notify you and explain why.