clupk Privacy Policy

1. Introduction

clupk ("we", "us", "our") is committed to protecting the privacy and personal data of every individual who registers, visits, or interacts with the clupk platform at clupk.com. This Privacy Policy describes the types of personal data clupk collects, the purposes for which that data is processed, the parties with whom it may be shared, the period for which it is retained, and the rights available to individuals in relation to their data.

This Policy applies to all Players registered on the clupk platform, including Players located in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, and all other parts of Pakistan, as well as visitors who browse the clupk website without registering an account.

By registering an account on clupk, completing the KYC verification process, making a deposit, or otherwise using clupk's services, you confirm that you have read this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you should not use the clupk platform.

2. Personal Data We Collect

clupk collects personal data through the account registration process, KYC verification, platform usage, and customer support interactions. The categories of personal data collected by clupk include:

• Identity Data: Full legal name, date of birth, gender, and nationality as provided during registration and as confirmed through KYC verification (including a copy of your Pakistani National Identity Card (CNIC) and a selfie photograph).
• Contact Data: Pakistani mobile number (including +92 prefix), email address, and any alternative contact information provided to clupk support.
• Financial Data: Deposit and withdrawal transaction records including amounts, dates, payment methods used (e.g., JazzCash account reference, Easypaisa mobile number, bank account details), and transaction identifiers. clupk does not store full payment card details on its servers.
• Gaming & Betting Data: Records of all bets placed, games played, bet amounts, win/loss outcomes, bonus usage, and account balance history within the clupk platform.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, session duration, pages visited within clupk, and referring URL.
• Communications Data: Records of support tickets, live chat transcripts, and email correspondence between you and clupk's support team.
• Responsible Gaming Data: Records of any deposit limits, loss limits, session time controls, cooling-off requests, or self-exclusion requests submitted through your clupk account settings.

3. How We Use Your Personal Data

clupk processes personal data for the following specific purposes:

• Account Management: To create, maintain, and administer your clupk account, verify your identity, and process your login and session activity.
• KYC & Compliance: To verify your identity and age (18+) in compliance with anti-money laundering (AML) and responsible gaming obligations applicable to online gaming platforms.
• Payment Processing: To process deposits, withdrawals, and refunds through your selected payment method (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, or USDT), and to maintain accurate financial records.
• Service Delivery: To provide access to clupk's betting and gaming services, calculate odds, settle bets, award bonus funds, and operate the clupk loyalty programme.
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account abuse, money laundering, underage gambling, and other prohibited conduct on the clupk platform.
• Responsible Gaming: To monitor for indicators of problem gambling behaviour and to administer responsible gaming tools including deposit limits and self-exclusion, in accordance with clupk's responsible gaming policy.
• Customer Support: To respond to support requests, resolve disputes, and communicate with you regarding your clupk account.
• Platform Improvement: To analyse aggregated, anonymised usage data for the purpose of improving the clupk platform's performance, usability, and game offering.
• Marketing Communications: To send promotional emails and in-platform notifications about clupk offers, bonuses, and new features, where you have consented to receive such communications. You may withdraw this consent at any time through your account notification settings.

4. Legal Basis for Processing

clupk processes personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil the agreement between clupk and the Player, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable legal obligations, including anti-money laundering regulations, age verification requirements, and responsible gaming mandates.
• Legitimate Interests: Processing undertaken for clupk's legitimate business interests, including fraud detection, platform security, and anonymised analytics, where such interests are not overridden by the Player's rights.
• Consent: Processing of data for marketing communications, where the Player has provided explicit consent. This consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

clupk does not sell, rent, or trade your personal data to third parties for their own marketing purposes. clupk may share your personal data with the following categories of third parties only to the extent necessary for the stated purpose:

• Payment Processors: JazzCash, Easypaisa, and banking partners (HBL, UBL, Meezan Bank, Bank Alfalah) receive transaction data necessary to process your deposits and withdrawals.
• KYC & Identity Verification Providers: clupk may use third-party identity verification services to assist in processing CNIC and selfie verification. These providers are contractually bound to process data solely for verification purposes.
• Game Software Providers: Game providers (including Evolution Gaming, Pragmatic Play, JILI, PG Soft) may receive session tokens and anonymised game-play data for the purpose of operating licensed games on the clupk platform.
• Regulatory & Law Enforcement Authorities: clupk will disclose personal data to competent authorities where required by law, court order, or regulatory instruction, or where disclosure is necessary to prevent or report suspected criminal activity including money laundering or fraud.
• IT Infrastructure Providers: Hosting, cloud storage, and cybersecurity service providers who process data on clupk's behalf under contractual data processing agreements that restrict use to the provision of those technical services.

All third parties who receive personal data from clupk are required to handle that data in accordance with applicable data protection requirements and are prohibited from using it for any purpose beyond the specific function for which it was shared.

6. Cookies & Tracking Technologies

clupk uses cookies and similar tracking technologies to operate and improve the clupk platform. The categories of cookies used include:

• Essential Cookies: Necessary for the clupk platform to function correctly, including session management, login state maintenance, and security tokens. These cannot be disabled.
• Functional Cookies: Store your preferences such as language settings, preferred game categories, and remembered login details (where you have selected the "Remember Me" option).
• Analytics Cookies: Collect anonymised data about how Players navigate the clupk platform, which pages are visited most frequently, and where technical errors are encountered. This data is used exclusively to improve platform performance.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent access to clupk's core services, though some preferences and features may not function as expected.

7. Data Retention

clupk retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Specifically:

• Account and KYC data is retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years for audit and compliance purposes.
• Gaming and betting history is retained for five (5) years following the relevant activity for dispute resolution and regulatory purposes.
• Support communications are retained for two (2) years following resolution of the relevant enquiry.
• Marketing consent records are retained for the duration of the consent and for a reasonable period following withdrawal to evidence the consent history.

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

8. Your Rights Regarding Personal Data

clupk respects your rights in relation to your personal data. You have the right to:

• Access: Request a copy of the personal data clupk holds about you.
• Rectification: Request correction of inaccurate or incomplete personal data held by clupk.
• Erasure: Request deletion of your personal data, where no legal obligation requires its continued retention.
• Restriction: Request that clupk restrict the processing of your personal data in certain circumstances, for example while the accuracy of data is under dispute.
• Objection: Object to the processing of your personal data for direct marketing purposes. Such objections will be honoured immediately.
• Data Portability: Request a structured, machine-readable copy of the personal data you have provided to clupk, where processing is based on consent or contractual necessity.
• Withdraw Consent: Withdraw consent for any processing based on consent (including marketing communications) at any time, without affecting the lawfulness of processing that occurred prior to withdrawal.

To exercise any of these rights, please contact clupk support at [email protected]. clupk will respond to valid requests within thirty (30) calendar days. In some cases, identity verification may be required before a request can be fulfilled.

9. Data Security

clupk implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include SSL/TLS encryption for all data in transit, password hashing, two-factor authentication availability, role-based server access controls, regular security assessments, and contractual security obligations imposed on all third-party data processors.

While clupk takes reasonable precautions to protect your data, no online platform can guarantee absolute security against all possible threats. In the event of a data security incident that is likely to result in a risk to your rights, clupk will notify affected individuals in accordance with its incident response procedures and applicable notification requirements.

10. Children's Privacy

The clupk platform is not directed at individuals under the age of eighteen (18). clupk does not knowingly collect personal data from minors. If clupk discovers or has reason to believe that a registered account belongs to an individual under 18, that account will be immediately suspended, all associated data will be reviewed, and any funds held in the account will be handled in accordance with clupk's underage gambling policy. Parents or guardians who believe a minor has registered on clupk should contact clupk support immediately at [email protected].

11. Third-Party Services & Links

The clupk platform may reference third-party game providers whose software powers specific games on the platform. clupk is not responsible for the privacy practices of third-party software providers operating within the clupk platform environment. Game providers operating on clupk are required under their licensing and operational agreements to comply with applicable data protection standards. clupk does not control any independent websites that may link to or from clupk.com and is not responsible for their privacy practices.

12. Changes to This Privacy Policy

clupk reserves the right to update this Privacy Policy at any time. The "Last Updated" date at the top of this page will be revised accordingly. For material changes that significantly affect how personal data is processed, clupk will notify registered Players by email to their registered address prior to the change taking effect. Continued use of the clupk platform following publication of a revised Privacy Policy constitutes your acceptance of the updated terms.

13. Contact & Data Enquiries

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by clupk, please contact the clupk support team. All privacy-related correspondence should be clearly marked as a privacy enquiry to ensure prompt routing to the appropriate team.

Contact email: [email protected] (plain text — not a clickable link)

clupk aims to respond to all privacy-related requests within thirty (30) calendar days of receipt. For complex requests, clupk may extend this period by a further thirty (30) days and will notify you of the extension within the initial period.