btrpkr Privacy Policy — How We Protect Your Personal Data

1 Introduction

This Privacy Policy (the "Policy") describes how btrpkr ("btrpkr", "We", "Us", "Our"), the operator of the online gaming platform accessible at btrpkr.net, collects, uses, stores, discloses, and protects the personal data of individuals ("Player", "User", "You") who register for or use the btrpkr platform.

btrpkr is committed to protecting the privacy of all players, including those accessing the platform from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Multan, and all other cities across Pakistan. This Policy is written in accordance with the data protection principles applicable under btrpkr's international gaming licence and relevant data protection frameworks.

This Policy should be read in conjunction with the btrpkr Terms & Conditions, which govern the overall contractual relationship between btrpkr and its players. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2 Data Controller

For the purposes of this Policy, btrpkr is the Data Controller — meaning btrpkr determines the purposes for which, and the manner in which, your personal data is processed. btrpkr operates under an international gaming licence which imposes mandatory obligations with respect to the collection, processing, and retention of player personal data.

Where btrpkr engages third-party service providers to process data on its behalf (for example, payment processors, KYC verification providers, or analytics services), those parties act as Data Processors and are contractually bound to process personal data only in accordance with btrpkr's instructions and under confidentiality obligations consistent with this Policy.

3 Personal Data We Collect

btrpkr collects the following categories of personal data from players:

4 How We Collect Your Data

btrpkr collects personal data through the following channels:

• Direct provision by you: During account registration, KYC verification submission, deposit and withdrawal requests, form completions, live chat interactions, and email correspondence with btrpkr support;
• Automated technical collection: Through server logs, cookies, and platform analytics tools as you navigate and use the btrpkr website and gaming interface;
• Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank integrations following a deposit or withdrawal initiated by you;
• Third-party KYC and fraud detection services: Identity verification results and risk scoring data returned by licensed KYC service providers used to validate player identities and comply with anti-money laundering obligations;
• Game suppliers: Gaming session data, round results, and RTP-relevant activity records transmitted by btrpkr's licensed game content providers as part of normal platform operation.

5 How We Use Your Personal Data

btrpkr uses the personal data collected for the following purposes:

• Account management: Creating, maintaining, and administering your btrpkr Player Account, including processing login authentication and account security measures;
• Identity and age verification: Confirming that you meet the minimum age requirement of 21 years and validating your identity in accordance with KYC obligations under btrpkr's gaming licence;
• Payment processing: Facilitating PKR deposits via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and processing withdrawal requests to verified payment methods;
• Responsible gaming monitoring: Detecting patterns of gaming behaviour that may indicate problem gambling and, where required, proactively applying responsible gaming interventions in accordance with btrpkr's licence obligations;
• Fraud prevention and anti-money laundering: Detecting, investigating, and preventing fraudulent activity, bonus abuse, duplicate accounts, and money laundering on the btrpkr platform;
• Customer support: Responding to account queries, deposit/withdrawal issues, complaints, and dispute resolution requests;
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. Players may withdraw consent at any time;
• Platform improvement: Analysing anonymised and aggregated usage data to improve the btrpkr platform's performance, game library, and user experience;
• Regulatory compliance: Meeting all obligations imposed by btrpkr's international gaming licence, including record-keeping, player protection reporting, and audit requirements.

6 Legal Basis for Processing

btrpkr processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil btrpkr's obligations under the Player Account agreement — including account operation, payment processing, and game provision;
• Legal obligation: Processing required to comply with anti-money laundering (AML) regulations, age verification mandates, gaming licence conditions, and tax or audit requirements;
• Legitimate interests: Processing carried out in the legitimate interests of btrpkr and its players — including fraud prevention, platform security, and responsible gaming monitoring — provided that such processing does not override your fundamental privacy rights;
• Consent: Processing of personal data for optional purposes such as marketing communications, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing and Disclosure

btrpkr does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Your data may be shared in the following limited and controlled circumstances:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank integrations receive only the minimum transaction data required to process deposits and withdrawals on your behalf;
• KYC and identity verification providers: Licensed KYC service providers receive identity documents you submit for age and identity verification. These providers are contractually prohibited from using your data for any purpose beyond verification;
• Game content suppliers: Licensed game studios receive anonymised session and bet data for the purpose of game round validation and RTP auditing. No personally identifiable data beyond a pseudonymous player reference is transmitted;
• Fraud and AML detection services: Risk intelligence providers may receive transaction and behavioural data for the purpose of detecting suspicious activity on the platform. All such providers are subject to data processing agreements;
• Regulatory and gaming licence authorities: btrpkr's licensing body may require access to player records as part of compliance audits or investigation of complaints. btrpkr is legally obligated to co-operate with such requests;
• Law enforcement and legal process: Where required by applicable law, court order, or governmental authority, btrpkr will disclose personal data as legally compelled. btrpkr will, where permitted, notify the affected player before disclosing.

8 Data Retention

btrpkr retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following general retention guidelines apply:

• Active Account data: Retained for the duration of your active btrpkr Account plus a minimum of five (5) years following account closure, in accordance with standard gaming licence AML record-keeping requirements;
• KYC documentation: Retained for a minimum of five (5) years from the date of verification, or longer if required by applicable AML or gaming licence obligations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Support communications: Retained for a minimum of two (2) years from the date of the last interaction;
• Marketing consent records: Retained for the duration of your Account, plus a reasonable period to demonstrate historical consent status in the event of a regulatory enquiry;
• Technical and usage data: Retained in anonymised or aggregated form for platform analytics purposes; identifiable technical data is retained for a maximum of twelve (12) months.

Following the expiry of the applicable retention period, personal data will be securely deleted or permanently anonymised so that it can no longer be attributed to you as an identified individual.

9 Data Security

btrpkr implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the btrpkr platform;
• Encrypted storage of all personal data at rest on btrpkr's secured server infrastructure;
• Role-based access controls ensuring that employee access to player data is restricted strictly to those with a legitimate operational need;
• Two-factor authentication options for Player Accounts, and mandatory 2FA for all btrpkr staff accessing backend systems containing personal data;
• Regular security assessments and penetration testing of btrpkr's platform infrastructure;
• Data breach response procedures, including notification obligations to affected players and relevant authorities in the event of a confirmed breach involving personal data.

10 Cookies and Tracking Technologies

btrpkr uses cookies and similar tracking technologies (such as web beacons and local storage) on its platform. Cookies are small data files stored on your device by your browser. btrpkr uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the btrpkr platform to function correctly — including session management, login authentication, and security token validation. These cookies cannot be disabled without preventing use of the platform;
• Functional Cookies: Used to remember your platform preferences, such as language settings and game lobby layout choices, so that your experience is consistent across sessions;
• Analytics Cookies: Used to collect anonymised and aggregated data about how players navigate the btrpkr platform, which game categories are most visited, and where usability issues occur. This data is used solely to improve the platform and is not linked to your personal identity;
• Marketing Cookies: Used only where you have explicitly opted in to receive personalised promotional communications from btrpkr. These cookies track which promotions you have been shown to avoid duplication.

You may manage or disable non-essential cookies through your browser settings at any time. Disabling analytics or functional cookies will not prevent you from using the btrpkr platform but may affect your experience.

11 Your Data Rights

Subject to applicable law and btrpkr's legal and regulatory obligations, you hold the following rights with respect to your personal data:

• Right of Access: You may request a copy of the personal data btrpkr holds about you. btrpkr will respond to verified access requests within 30 days;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held about you. Certain data (such as your registered name) may require KYC documentation to amend;
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data. Note that btrpkr may be unable to delete certain data where retention is required by gaming licence, AML, or other legal obligations. In such cases, btrpkr will inform you of the specific data categories that cannot be deleted and the applicable retention basis;
• Right to Restriction of Processing: You may request that btrpkr restricts processing of your personal data in specific circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of btrpkr's legitimate interests;
• Right to Data Portability: Where processing is based on your consent or on a contract, you may request that btrpkr provides your personal data in a structured, commonly used, machine-readable format;
• Right to Object: You may object at any time to processing of your personal data for direct marketing purposes. Upon receipt of such an objection, btrpkr will cease processing your data for marketing immediately;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please contact btrpkr via the live chat channel within your Account dashboard or by email at [email protected]. btrpkr may require identity verification before processing certain requests to protect against unauthorised data access.

12 Children's Privacy and the 21+ Requirement

btrpkr implements mandatory age verification as part of the account registration and KYC process. In the event that an account is found to belong to an individual under the age of 21, the account will be immediately closed, all funds will be handled in accordance with btrpkr's underage gaming policy (as set out in the Terms & Conditions), and all associated personal data will be deleted except where retention is legally required for AML or regulatory purposes.

If you are a parent or guardian and believe that a minor may have registered on the btrpkr platform, please contact btrpkr support immediately via live chat or at [email protected].

13 Third-Party Links and Services

The btrpkr platform may contain references to third-party services (such as licensed game studios or payment providers) that operate under their own privacy policies. btrpkr's Privacy Policy does not extend to the data practices of those third parties. Players who interact directly with third-party interfaces (for example, a game lobby launched from a third-party studio) should review the applicable privacy documentation of that third party.

btrpkr is not responsible for the privacy practices, content, or data security standards of third-party services, and the inclusion of any third-party service on the btrpkr platform does not constitute an endorsement of that party's privacy practices.

14 Changes to This Privacy Policy

btrpkr reserves the right to update or amend this Privacy Policy at any time. Material changes — for example, changes to the categories of data collected, the purposes of processing, or the parties with whom data is shared — will be communicated to all registered players via email notification to the address on file and/or by a notice displayed upon login to the btrpkr platform.

The effective date of the current version of this Privacy Policy is displayed at the top of this page. Your continued use of the btrpkr platform following notification of a material change constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the platform and may request Account closure in accordance with the btrpkr Terms & Conditions.

Players are encouraged to review this page periodically to remain informed of how btrpkr handles their personal data.

15 Contact Us — Privacy Enquiries

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a complaint about how btrpkr has handled your personal data, please use the following contact channels:

• Live Chat: Available 24/7 within your btrpkr Account dashboard after login — the fastest method for most enquiries;
• Email: [email protected] — for formal data access requests, erasure requests, or written privacy complaints. Please include "Privacy Request" in the subject line;
• Players Served: Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Multan, Peshawar, and all other cities across Pakistan.

btrpkr will acknowledge privacy-related requests within 48 hours and provide a substantive response within 30 days. Where a request is complex or involves a high volume of data, btrpkr may extend this period by a further 30 days with prior notice.