pl1947 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by pl1947 ("the Company", "we", "us", "our") and applies to all personal data collected from individuals ("Player", "User", "you") who access, register with, or use any service provided through the pl1947 website and mobile platform.

pl1947 is Pakistan's premier online casino and sports betting platform, serving players across the country — from Karachi and Lahore to Islamabad, Faisalabad, Rawalpindi, Multan, and beyond. We take our data protection responsibilities seriously and have designed our data practices to reflect the trust Pakistani players place in us.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference. By registering a pl1947 account or using any of our services, you acknowledge that you have read and understood this Policy.

2. Personal Data We Collect

pl1947 collects personal data in several categories, depending on how you interact with our platform. The table below summarises the main categories of data we collect and their purpose:

pl1947 does not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric identifiers, unless specifically required by applicable law or regulation and with appropriate safeguards in place.

3. How We Collect Your Data

pl1947 collects personal data through the following channels:

• Directly from you: When you complete the registration form, submit KYC documents, contact support, or update your account settings.
• Automatically during platform use: Technical data such as your IP address, device identifiers, and session logs are collected automatically when you access the pl1947 platform via browser or mobile device.
• From payment providers: When you deposit or withdraw via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or bank transfer, transaction reference information is shared with us by the payment provider to confirm the status of your transaction.
• From identity verification partners: Where pl1947 uses third-party KYC or fraud screening services, those providers may share data relevant to confirming your identity or flagging suspicious patterns.
• From cookies and tracking technologies: As detailed in Section 8 of this Policy, pl1947 uses cookies and similar technologies to collect information about how you browse and interact with our platform.

4. How We Use Your Personal Data

pl1947 uses the personal data we collect for the following purposes:

• Account administration: Creating, managing, and maintaining your pl1947 account, including processing your registration and verifying your eligibility to play.
• Service delivery: Operating casino games, sports betting markets, live dealer tables, and all other features available on the pl1947 platform.
• Financial processing: Processing PKR deposits and withdrawals through local payment methods, and maintaining accurate transaction records.
• Identity verification and KYC: Confirming your identity, age (21+), and location as required by our gaming licence framework and internal compliance policies.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, multi-accounting, money laundering, and other prohibited conduct.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour and providing appropriate interventions, including deposit limits, cooling-off periods, and self-exclusion.
• Legal compliance: Meeting our obligations under applicable anti-money laundering (AML), counter-terrorist financing (CTF), and gaming licence requirements.
• Customer support: Responding to your queries, resolving disputes, and improving the quality of our support service.
• Marketing (where consented): Sending you promotional offers, bonus notifications, and platform updates via email or SMS, only where you have opted in to receive such communications.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the performance, design, and content of the pl1947 platform.

pl1947 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing a separate lawful basis for doing so.

5. Legal Basis for Processing

pl1947 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing that is necessary to perform the contract between you and pl1947 — for example, processing your registration, operating your account, and facilitating transactions.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC, AML, and gaming licence compliance obligations.
• Legitimate interests: Processing carried out to pursue pl1947's legitimate business interests where those interests are not overridden by your rights — for example, fraud detection, platform security, and service improvement using anonymised analytics.
• Consent: Where pl1947 relies on your consent as the legal basis for processing — specifically for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

pl1947 does not sell, rent, or trade your personal data to any third party. We share personal data only in the following limited circumstances, and only to the extent necessary for each purpose:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment providers receive the transaction data necessary to process your PKR deposits and withdrawals. Each provider operates under its own privacy policy and data protection obligations.
• Identity verification providers: Third-party KYC and fraud screening partners receive identity documents and related data solely for the purpose of completing required verification checks.
• Game content providers: Casino game developers and live dealer studios may receive pseudonymised game session data (e.g., bet amounts and outcomes) for the purpose of game operation, RNG certification, and dispute resolution. No directly identifiable personal data is shared beyond what is required for these purposes.
• Regulatory and law enforcement authorities: pl1947 may be required to disclose personal data to gaming regulators, financial intelligence authorities, or law enforcement agencies in response to a lawful request. pl1947 will notify you of such disclosures unless legally prohibited from doing so.
• Professional advisers: Legal, financial, and compliance advisers engaged by pl1947 may access personal data on a confidential, need-to-know basis.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of pl1947's business, player data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

7. Payment Data & PKR Transactions

pl1947 takes particular care with financial data given the sensitivity of payment information. The following specific practices apply to PKR transaction data:

• pl1947 does not store full payment account credentials (e.g., full JazzCash wallet numbers or complete bank account details) on our own servers. Such credentials are tokenised or handled directly by our payment processing partners.
• Transaction records — including deposit and withdrawal amounts, timestamps, and reference numbers — are retained as part of your account history for the period required by our AML compliance obligations (see Section 9).
• All payment data in transit between pl1947 and payment processors is encrypted using industry-standard protocols.
• Deposits and withdrawals must be made from payment accounts registered in your own name. pl1947 will verify payment method ownership as part of the KYC process and may request supporting documentation before processing withdrawal requests.

8. Cookies & Tracking Technologies

pl1947 uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and collect anonymised usage analytics. The main categories of cookies we use are as follows:

• Strictly necessary cookies: Essential to the operation of the pl1947 platform, including maintaining your logged-in session and enabling core security features. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings and display options, so you do not need to reconfigure them on each visit.
• Analytics cookies: Collect anonymised information about how players use the platform — for example, which pages are visited most frequently and where players encounter errors. This data is used to improve platform performance and content.
• Marketing cookies: Where you have consented, these cookies enable pl1947 to deliver relevant promotional content. They may track your interaction with promotional materials across sessions.

You can manage your cookie preferences through your browser settings at any time. Disabling strictly necessary cookies may impair your ability to use the pl1947 platform. pl1947 does not use third-party advertising networks or cross-site tracking technologies for the purpose of selling advertising space.

9. Data Retention

pl1947 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by applicable law or regulation. The following general retention periods apply:

• Account data: Retained for the duration of your active account relationship with pl1947, and for a period of five (5) years following account closure, unless a longer period is required.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML and gaming regulatory requirements.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Customer support communications: Retained for up to three (3) years following the resolution of the relevant query or dispute.
• Marketing preference records: Consent records are retained for as long as marketing communications are sent to you and for one (1) year following any opt-out, to document compliance.

Following the expiry of the applicable retention period, pl1947 will securely delete or anonymise your personal data. Anonymised data may be retained indefinitely for aggregated analytics purposes.

10. Data Security

pl1947 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the pl1947 platform;
• Encryption of sensitive data fields at rest within our secure database infrastructure;
• Strict role-based access controls ensuring that only authorised personnel can access player data, and only to the extent required for their specific function;
• Regular internal and third-party security audits and penetration testing;
• Automated monitoring for unusual access patterns, potential breaches, and suspicious activity;
• Incident response procedures designed to detect, contain, and report data security incidents in a timely manner.

In the event of a data security incident that is likely to result in a risk to your rights and freedoms, pl1947 will notify affected players without undue delay and will take all reasonable steps to mitigate the impact of the incident.

While pl1947 employs industry-standard security practices, no online platform can guarantee absolute security. You are also responsible for keeping your pl1947 login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

11. Your Data Rights

As a pl1947 player, you have the following rights in relation to the personal data we hold about you. You may exercise any of these rights at any time by contacting our support team:

• Right of access: You have the right to request a copy of the personal data pl1947 holds about you, together with information about how it is being processed.
• Right to rectification: If any personal data pl1947 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to erasure: In certain circumstances, you have the right to request that pl1947 delete your personal data. This right is subject to overriding legal retention obligations (for example, AML requirements).
• Right to restriction of processing: In certain circumstances, you may request that pl1947 limit the way in which it processes your data, for example while a dispute about its accuracy is being resolved.
• Right to data portability: Where processing is based on your consent or a contract with you, you may request that pl1947 provide your personal data in a structured, machine-readable format.
• Right to object: You have the right to object to processing based on pl1947's legitimate interests. If you object to the processing of your data for direct marketing purposes, pl1947 will cease that processing immediately.

pl1947 will respond to all valid data subject requests within 30 calendar days. We may extend this period by a further 60 days where requests are complex or numerous, in which case we will notify you of the extension within the initial 30-day period.

We may ask you to verify your identity before processing a data rights request to ensure that we do not disclose personal data to an unauthorised person.

12. Minors & Age Policy

pl1947's services are strictly restricted to persons aged 21 years and over. pl1947 does not knowingly collect personal data from individuals under the age of 21.

If pl1947 becomes aware that it has inadvertently collected personal data from an individual who is under 21, the following steps will be taken without delay:

• The relevant account will be immediately suspended pending investigation;
• All personal data associated with the underage account will be securely deleted, subject only to any legally mandated retention requirements;
• Any real-money balance in the account, including any winnings, will be forfeited in accordance with our Terms and Conditions;
• The incident will be documented and, where appropriate, reported to the relevant authorities.

Parents and guardians who believe that a minor may have registered on the pl1947 platform are urged to contact our support team immediately. pl1947 takes underage gambling extremely seriously and cooperates fully with any related investigation.

13. International Data Transfers

pl1947 operates under an international gaming licence framework, and some of the third-party service providers we work with — including game developers, KYC providers, and technical infrastructure partners — may be located outside Pakistan.

Where personal data is transferred internationally, pl1947 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that applied within Pakistan. Such safeguards include:

• Contractual data protection clauses imposing equivalent obligations on the recipient of the data;
• Transfer to organisations operating in jurisdictions that maintain recognised data protection standards;
• Technical measures including encryption of data in transit and at rest.

You may request further information about the safeguards applicable to any specific international data transfer by contacting our support team.

14. Changes to This Privacy Policy

pl1947 reserves the right to update or amend this Privacy Policy at any time. Where changes are material — for example, a new category of data being collected or a change in the purposes for which data is used — pl1947 will provide advance notice to affected players via email or an in-platform notification, prior to the change taking effect.

For minor amendments, such as clarifications or corrections, the updated Policy will be published on this page and the "Effective Date" at the top of the document will be revised accordingly. Your continued use of the pl1947 platform following publication of an updated Policy constitutes your acceptance of the changes.

We recommend that you review this Policy periodically to stay informed about how pl1947 handles your personal data.

15. Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pl1947 handles your personal data, please contact our support team in the first instance:

pl1947 aims to resolve all privacy-related queries within 30 calendar days. If you are not satisfied with our response, you have the right to escalate your complaint to the relevant data protection authority or to the independent dispute resolution mechanism provided under our gaming licence framework.

For all formal written complaints, please include your full name, registered email address, a clear description of your concern, and any supporting documentation. This will help us resolve your query as efficiently as possible.