Privacy Policy

Apkaka ("we", "us", "our") operates the online gaming platform accessible at https://apkaka.cam. As an English-language platform serving Pakistani users, we take our responsibility to protect your personal data seriously. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the rights you hold in relation to that data.

This Policy applies to all users of the Apkaka Platform, including registered account holders, visitors who browse without registration, and individuals who contact our support team. By accessing the Platform or submitting personal information to us, you confirm that you have read and understood this Privacy Policy.

This Policy should be read alongside our Terms & Conditions, which govern the overall relationship between you and Apkaka. In the event of any conflict between this Policy and the Terms, the Terms shall prevail except where this Policy provides greater protection to your privacy rights.

The following terms have the meanings set out below when used in this Privacy Policy:

Any information relating to an identified or identifiable natural person — meaning any data that can, on its own or in combination with other information, identify you directly or indirectly.

The entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Data Controller is the operator of the Apkaka Platform.

A third party that processes Personal Data on behalf of the Data Controller under a contractual obligation — for example, payment processors, KYC verification providers, or hosting services.

Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, transmission or deletion.

Identity and document verification procedures required to confirm a user's identity, age and, where relevant, source of funds — a regulatory and anti-money-laundering obligation.

Small text files placed on your device by a website to remember preferences, session states and analytical data over time.

Sensitive categories of personal data including health information, which may be relevant in the context of responsible gambling assessments, processed only with explicit consent or where legally required.

We collect personal data through your interactions with the Platform — including account registration, gameplay, payment transactions, KYC verification, support communications and general browsing activity. The categories of data we collect are summarised below:

We process your personal data only where we have a valid legal basis to do so. The legal bases we rely upon are as follows:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions — including account management, payment processing and game operation.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money-laundering (AML) laws, KYC requirements, gaming licence conditions and financial reporting obligations.
• Legitimate Interests: Processing carried out to pursue our legitimate business interests where these do not override your privacy rights — including fraud prevention, platform security, responsible gambling monitoring and analytics.
• Consent: Processing based on your explicit consent, where required — including the use of non-essential cookies, marketing communications and the collection of special category data in connection with responsible gambling assessments. You may withdraw consent at any time.

We use the personal data we collect for the following specific purposes:

• Account Creation & Management: To register your account, verify your identity and maintain your account settings, preferences and balance records.
• Transaction Processing: To process deposits and withdrawals, verify payment methods and maintain accurate financial records. This includes interactions with payment rails familiar to Pakistani users such as Easypaisa, JazzCash, Raast and bank transfers — referenced for transaction purposes only, without implying those providers support gambling.
• KYC & Compliance: To verify your identity and age, comply with AML obligations, detect suspicious activity and meet the requirements of our licensing authority.
• Platform Operations: To deliver the gaming, betting and live dealer services you access on the Platform, including odds calculation, game result settlement and session management.
• Responsible Gambling: To monitor gaming behaviour against your self-set limits, enforce self-exclusion requests, and identify patterns that may indicate problem gambling warranting intervention.
• Customer Support: To respond to your queries, resolve disputes, process complaints and maintain communication records.
• Security & Fraud Prevention: To detect, investigate and prevent fraudulent transactions, unauthorised access and prohibited conduct as defined in our Terms.
• Analytics & Improvement: To analyse platform usage patterns and improve the user experience, game selection and performance of the Platform.
• Legal & Regulatory: To comply with court orders, regulatory requests and applicable law, and to establish, exercise or defend legal claims.

We do not sell your personal data to third parties for commercial marketing purposes. We may share your data with the following categories of recipients where necessary and proportionate:

• Service Providers (Data Processors): Third-party providers contracted to support Platform operations — including KYC and identity verification providers, payment processors, IT infrastructure and hosting services, fraud detection tools and customer support platforms. All processors are bound by data protection agreements.
• Regulatory Authorities & Law Enforcement: Where required by applicable law, court order or legitimate request from competent authorities — including gaming regulators, financial intelligence units and law enforcement agencies.
• Licensing Authorities: Our gaming licence regulator may require access to specific account and transaction records as part of ongoing compliance monitoring.
• Group Companies: Where the Platform operator is part of a corporate group, data may be shared with affiliated entities for internal administrative and compliance purposes, subject to equivalent data protection standards.
• Business Transfers: In the event of a merger, acquisition or sale of all or part of the Platform operator's business, personal data may be transferred as part of that transaction. You will be notified of any such change and your rights will be maintained.

The Apkaka Platform uses cookies and similar tracking technologies to operate core platform functions, maintain your session state and analyse usage. We categorise cookies as follows:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, login state management and security tokens. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your language preferences, display settings and responsible gambling tool configurations between sessions.
• Analytical / Performance Cookies: Collect aggregated data about how users interact with the Platform — page visit frequency, session duration, error reports — to help us improve the experience. These are set only with your consent.
• Marketing / Targeting Cookies: May be used to deliver relevant promotional content within the Platform. These are set only with your explicit consent and you may withdraw consent at any time via your account settings or browser controls.

You may manage your cookie preferences through your browser settings. Disabling certain cookies may impact the availability and functionality of some Platform features.

We retain your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and our licensing obligations. Key retention periods include:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, to meet AML and regulatory record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction in accordance with standard AML requirements.
• KYC Documentation: Identity verification documents are retained for a minimum of five (5) years following account closure or the end of the business relationship.
• Support Communications: Chat transcripts and email records are retained for a minimum of two (2) years to support dispute resolution and quality assurance.
• Responsible Gambling Records: Self-exclusion records and responsible gambling limit history are retained for the duration of the exclusion period and for a minimum of five (5) years thereafter.
• Technical / Analytical Data: Aggregated and anonymised analytical data may be retained indefinitely; identifiable technical logs are typically retained for twelve (12) months.

After applicable retention periods expire, your data is securely deleted or irreversibly anonymised. Where deletion is not immediately possible due to backup systems, data will be isolated and protected until deletion can be executed.

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

• TLS / SSL encryption for all data transmitted between your device and our Platform servers.
• Encryption at rest for sensitive data fields including financial data and identity records.
• Role-based access controls ensuring that staff access to personal data is limited to what is required for their specific function.
• Multi-factor authentication requirements for internal systems and privileged account access.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures with defined notification timelines in the event of a data breach affecting your rights.

While we implement robust security measures, no digital platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials. If you suspect unauthorised access to your account, contact our support team immediately at [email protected].

The Apkaka Platform is operated under an international gaming licence and uses service providers located in various jurisdictions. As a result, your personal data may be transferred to and processed in countries outside your country of residence, including countries that may have different data protection standards.

Where personal data is transferred internationally, we ensure appropriate safeguards are in place, including contractual data protection clauses, processor agreements and — where applicable — adequacy decisions by relevant data protection authorities.

Subject to applicable law and the exceptions noted below, you have the following rights in relation to your personal data held by Apkaka:

To exercise any of these rights, contact our data protection team at [email protected] with your account username and a clear description of your request. We will respond within the timeframe required by applicable law.

Please note that certain rights may be limited where processing is required to comply with legal obligations — for example, AML record-keeping requirements may prevent immediate deletion of financial records within the mandatory retention period.

The Apkaka Platform is strictly for adults aged 18 and above, or the higher minimum age required by the operator's licence jurisdiction. We do not knowingly collect or process personal data of individuals below this age threshold.

Age verification is a mandatory component of the KYC process. All players are required to confirm their age at registration and provide documentary evidence of age prior to the processing of any withdrawal. Where we suspect or discover that an account holder is below the minimum eligible age, the account will be immediately suspended, all funds will be frozen pending investigation, and any winnings will be voided in accordance with our Terms & Conditions.

The Platform may include integrations with or references to third-party services, including payment processors and identity verification providers. These third parties operate under their own privacy policies and data protection standards, for which Apkaka is not responsible.

Payment processing involves third-party providers. Where familiar Pakistani payment rails such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah are used for transactions, your interactions with those providers are governed by their own privacy policies and terms of service. Apkaka does not control and is not responsible for the data practices of those providers.

We encourage you to review the privacy policies of any third-party services you interact with in connection with Platform use. Our responsibility is limited to how we handle your data within the Platform environment.

We may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law or Platform functionality. Material updates will be communicated to registered users via email or a prominent Platform notice prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Policy periodically. Your continued use of the Platform following a notified change constitutes your acknowledgement of the revised Policy.

Where a proposed amendment materially affects your rights or the basis on which we process your data, we will request fresh consent where required by applicable law.

For all privacy-related queries, data subject access requests, rectification requests, erasure requests or concerns about how we handle your personal data, please contact us through the following channels:

• Data / Privacy Queries — Email: [email protected]
  • Target response time: within 12 hours for support queries
  • For formal data subject rights requests, we will acknowledge within 5 business days and respond within the timeframe required by applicable law
  • Please include your registered username and the specific nature of your request
• Live Chat: Available 24/7 via the Platform live chat widget as provided by the operator. Suitable for general privacy questions and support.
• Language: Support is provided in English. Urdu-language assistance may be available upon request.