clupk Privacy Policy

1Who We Are and Scope of This Policy

This Privacy Policy applies to the clupk website at https://clupk.net and all associated services, mobile interfaces and platform features operated under the clupk brand ("clupk", "we", "us", "our"). clupk is an online casino and sports betting platform serving English-speaking players in Pakistan.

This Policy applies to all personal data processed by clupk in connection with your use of the platform, whether you are a registered account holder, a visitor browsing the site without registering, or a player who has closed their account but whose data we are required to retain for legal or regulatory compliance purposes.

2Personal Data We Collect

2.1 Registration Data

When you create a clupk account, we collect the information you provide directly, including:

• Full legal name
• Date of birth (to verify you are 18 or older)
• Residential address (including city, for example Karachi, Lahore or Islamabad)
• Email address
• Mobile phone number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer obligations, clupk may collect copies of government-issued identification (such as your National Identity Card), proof of address documents, and proof of payment method ownership (such as a JazzCash or Easypaisa account screenshot or a bank statement from HBL, UBL or Bank Alfalah).

2.3 Financial and Transaction Data

We collect records of all deposits, withdrawals, bonus claims, bet placements and game activity on your clupk account. This includes PKR transaction amounts, payment method references, timestamps and any relevant transaction identifiers.

2.4 Technical and Usage Data

When you access clupk, we automatically collect certain technical data including your IP address, browser type and version, operating system, device identifiers, session duration, pages visited and the referring URL. This data is collected via standard server logs and, where applicable, cookies.

2.5 Communications Data

If you contact clupk support by email or live chat, we retain records of those communications to maintain an accurate support history and to improve the quality of our service.

3How We Use Your Personal Data

clupk uses the personal data we collect for the following specific purposes:

• Account management: To create and maintain your clupk account, verify your identity, and manage your login sessions securely.
• Payment processing: To facilitate PKR deposits via JazzCash, Easypaisa, HBL, UBL and Bank Alfalah, and to process withdrawal requests to the same verified payment methods.
• Legal and regulatory compliance: To meet our obligations under applicable anti-money laundering, counter-terrorism financing and responsible gaming requirements, including KYC verification and age checks.
• Fraud and security: To detect and prevent unauthorised account access, bonus abuse, collusion, money laundering and other prohibited activities on clupk.
• Customer support: To respond to your queries, investigate complaints and maintain an accurate communication history between you and the clupk support team.
• Service improvement: To analyse usage patterns on clupk in aggregate, anonymised form to improve game selection, payment flows and overall platform performance.
• Responsible gaming: To monitor gameplay patterns that may indicate problem gambling behaviour and, where applicable, to contact you with responsible gaming information or to enforce self-exclusion requests.
• Promotional communications: Where you have opted in, to send you information about clupk bonuses and offers relevant to your gaming activity. You may opt out at any time by contacting clupk support.

4Legal Bases for Processing

clupk processes your personal data on the following legal bases:

• Performance of contract: Processing necessary to provide you with the clupk platform services you have agreed to use, including account management, payments and gameplay.
• Legal obligation: Processing required to comply with applicable AML, KYC, age verification and responsible gaming regulations.
• Legitimate interests: Processing for fraud prevention, security monitoring and platform improvement, where these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where you have explicitly opted in to receive promotional communications from clupk. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5Cookies and Tracking Technologies

clupk uses cookies and similar tracking technologies to operate the platform, maintain your login session, remember your preferences and analyse aggregate usage patterns. The following categories of cookies are used:

• Essential cookies: Required for the clupk platform to function. These include session authentication cookies and security tokens. These cannot be disabled without breaking platform functionality.
• Functional cookies: Used to remember your language preferences, display settings and region (for example, recognising that you are a Pakistani player accessing the platform in PKR).
• Analytics cookies: Used by clupk to understand how players interact with the platform in aggregate and anonymised form. Individual player data is not extracted from analytics cookies for marketing purposes.

You may manage cookie preferences through your browser settings. Disabling essential cookies will prevent you from logging into clupk. Analytics cookies can typically be disabled without affecting your ability to use the platform.

6Sharing of Personal Data

clupk does not sell your personal data. We share personal data only with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Bank Alfalah and other payment service providers receive the minimum transactional data necessary to process your PKR deposits and withdrawals.
• Game software providers: Certified game studios receive session-level data to operate games within the clupk lobby. They do not receive your full profile, identity documents or financial transaction history.
• KYC and identity verification services: Third-party identity verification providers may process copies of your identification documents to assist clupk in meeting its KYC obligations.
• Regulatory and law enforcement authorities: Where required by applicable law, regulation or a valid legal process (such as a court order), clupk may disclose personal data to competent authorities.
• Fraud prevention services: clupk may share limited data with fraud detection and AML screening services to protect the platform and its players from financial crime.

7Data Retention

clupk retains personal data for as long as necessary to fulfil the purposes described in this Privacy Policy, including legal and regulatory requirements. The following general retention periods apply:

• Active account data is retained for the lifetime of your clupk account plus a minimum of five (5) years following account closure, to comply with AML and financial record-keeping requirements.
• KYC and identity verification documents are retained for the period required by applicable regulations, typically a minimum of five (5) years from the date of verification.
• Customer support communications are retained for a minimum of three (3) years from the date of the last interaction.
• Technical and usage logs are retained for up to twelve (12) months for security monitoring and fraud prevention purposes, after which they are anonymised or deleted.

8Security of Your Data

clupk implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration or destruction. These measures include:

• HTTPS encryption for all data transmitted between your device and the clupk platform
• Cryptographic hashing of all stored passwords – clupk staff cannot retrieve your password in plain text
• Access controls limiting clupk staff access to personal data to those with a demonstrated need
• Regular security assessments and monitoring of the clupk platform for vulnerabilities
• Incident response procedures to detect, contain and report any data breach affecting your personal information

While clupk takes reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your clupk account credentials and for notifying clupk support immediately if you suspect unauthorised access to your account.

9Your Rights as a Data Subject

Subject to applicable data protection law, you have the following rights in relation to your personal data held by clupk:

• Right of access: You may request a copy of the personal data clupk holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data in your clupk account.
• Right to erasure: You may request deletion of your personal data where clupk no longer has a legal basis to retain it. Note that certain data must be retained for legal compliance purposes even after account closure.
• Right to restriction of processing: You may request that clupk restrict the processing of your data in certain circumstances, for example while a data accuracy dispute is resolved.
• Right to data portability: Where technically feasible and legally applicable, you may request your personal data in a structured, machine-readable format.
• Right to object: You may object to the processing of your data on the basis of legitimate interests, including profiling for marketing purposes.
• Right to withdraw consent: Where processing is based on consent (such as marketing communications), you may withdraw that consent at any time without affecting prior lawful processing.

To exercise any of the above rights, please contact clupk using the details in Section 12. We will respond to all verified data requests within thirty (30) calendar days.

10Children and Minors

clupk is strictly an 18+ platform. We do not knowingly collect personal data from individuals under the age of 18. If clupk becomes aware that personal data has been submitted by a minor, the relevant account will be closed immediately, all associated balances will be voided in accordance with our Terms & Conditions, and the personal data will be securely deleted.

Parents and guardians who believe a minor has registered a clupk account should contact clupk support immediately. We take the protection of minors extremely seriously and will investigate all such reports with priority.

11Changes to This Privacy Policy

clupk may update this Privacy Policy from time to time to reflect changes in applicable laws, platform features, or our data practices. Material changes will be communicated to registered players via email with a minimum of seven (7) calendar days' notice prior to the effective date. The updated policy will be published at https://clupk.net/privacy-policy. Continued use of the clupk platform after the stated effective date constitutes your acceptance of the revised Privacy Policy.

12Contact and Data Enquiries

For all privacy-related requests, data subject rights exercises, or general questions about how clupk handles your personal data, please contact our support and data team: