clupk Privacy Policy

clupk ("we", "us", "our") is committed to protecting the personal data of all individuals who interact with our platform. This Privacy Policy applies to all users of the clupk website at clupk.vip, including registered Players, prospective members, and general visitors — whether browsing from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, or anywhere else across Pakistan.

This Policy describes the personal information clupk collects, the purposes for which it is processed, the legal basis on which such processing rests, the parties with whom data may be shared, and the rights you hold as a data subject. It should be read in conjunction with our Terms & Conditions and Responsible Gaming policy, both of which form part of the overall agreement between you and clupk.

By accessing the clupk platform, completing our registration process, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of it, you should discontinue use of the platform immediately.

clupk collects personal data through a number of channels including account registration, identity verification, deposits and withdrawals, gameplay activity, customer support interactions, and general platform usage. The categories of personal data we may collect include, but are not limited to, the following:

We do not collect any special categories of sensitive personal data (such as health data, racial or ethnic origin, religious beliefs, or political opinions) unless specifically required to fulfil a legal obligation — for example, processing a self-exclusion request linked to a medical gambling disorder declaration.

clupk uses your personal data only for the purposes described in this Policy. We do not sell personal data to third parties, and we do not use your information to build profiles for unrelated advertising purposes. The specific ways we use your data are as follows:

• Account Management: To create, maintain, and administer your Player Account, including verifying your identity and age (21+), managing your preferences, and communicating important account updates.
• Payment Processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard — ensuring funds are credited or returned to the correct verified account holder.
• Regulatory Compliance: To meet our obligations under anti-money laundering (AML) laws, Know Your Customer (KYC) requirements, and the conditions of our international gaming licence — including filing mandatory reports where required by law.
• Responsible Gaming: To monitor gameplay patterns for signs of problem gambling behaviour, enforce self-exclusion and deposit limits, and contact Players where we have a duty of care concern.
• Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, bonus abuse, multi-accounting, and other prohibited conduct that could harm the integrity of the platform.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance through live chat and email support channels.
• Marketing Communications: To send you promotional offers, bonus alerts, and platform news — only where you have opted in to receive such communications and subject to your right to withdraw consent at any time.
• Platform Improvement: To analyse aggregated and anonymised usage data to improve the performance, design, and content of the clupk platform for all Pakistani players.

Where data protection law requires a legal basis for processing personal data, clupk relies on one or more of the following grounds, depending on the context and purpose of each processing activity:

• Contractual Necessity: Processing is necessary to perform the contract between you and clupk — including managing your account, processing transactions, and delivering gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable laws and regulatory requirements, including AML legislation, KYC obligations, and the terms of our international gaming licence.
• Legitimate Interests: Processing is necessary for our legitimate interests — such as detecting fraud, ensuring platform security, and improving our services — provided these interests are not overridden by your data protection rights.
• Consent: Where we process data for marketing communications or optional features, we rely on your explicit, freely given, and withdrawable consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

clupk uses cookies, pixel tags, local storage, and similar tracking technologies to operate and improve the platform. Cookies are small text files placed on your device when you visit our site. They allow us to remember your session, recognise returning users, and understand how the platform is being used.

The types of cookies we use are categorised as follows:

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication tokens and security cookies. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, last visited game category, and responsible gaming limit configurations. Disabling these may reduce your personalised experience.
• Analytics Cookies: Collect aggregated, anonymised data about how Players navigate the platform — which pages are most visited, how long sessions last, and where technical errors occur. This helps us improve clupk's performance and layout.
• Marketing Cookies: Where you have consented, these cookies track your engagement with clupk promotional content and enable us to show you relevant offers. These are not used to track your activity on third-party websites.

You may manage your cookie preferences through the Cookie Settings panel available on the platform, or through your browser's built-in settings. Please note that disabling strictly necessary cookies will impair your ability to log in and use core features of the clupk platform.

clupk does not sell, rent, or trade your personal data with third parties for their own commercial purposes. However, we may share your data with carefully selected third parties in the following limited circumstances:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card networks (Visa/Mastercard) receive the minimum data necessary to process your transactions securely. These parties are contractually bound to use your data solely for payment processing purposes.
• Identity Verification Partners: Licensed KYC and AML service providers who assist us in verifying your identity and screening against sanctions and politically exposed persons (PEP) lists, as required by our regulatory obligations.
• Game Software Providers: Third-party game studios and live casino operators whose software is integrated into the clupk platform may receive pseudonymised gameplay data necessary to deliver the game experience and settle outcomes.
• Regulatory Authorities: We may be required to disclose personal data to governmental bodies, financial intelligence units, or our licensing authority where we have a legal obligation to do so — for example, in connection with AML reporting or regulatory audits.
• Legal Proceedings: Where required by a valid court order, law enforcement request, or other binding legal process, clupk will disclose the minimum amount of personal data necessary to comply with that requirement.
• Corporate Transactions: In the event of a merger, acquisition, restructuring, or sale of all or part of clupk's business assets, your personal data may be transferred to the successor entity — subject to the same privacy protections set out in this Policy.

All third parties with whom we share personal data are required to maintain appropriate technical and organisational security measures and to process your data only in accordance with our written instructions and this Privacy Policy.

clupk retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our retention periods are guided by the following principles:

• Active Accounts: Personal data associated with an active Player Account is retained for the full duration of the account's existence and for a minimum period following account closure as required by AML and gaming regulations.
• Transaction Records: Financial transaction data, including deposit and withdrawal records, is retained for a minimum of five (5) years from the date of the transaction in accordance with anti-money laundering legislation.
• KYC Documentation: Identity verification documents (such as CNIC copies) are retained for a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Support Communications: Customer support records are retained for a period of three (3) years following resolution of the relevant query, to enable dispute resolution and audit purposes.
• Self-Exclusion Records: Where a Player has requested self-exclusion, a record of that exclusion is retained indefinitely to prevent re-registration attempts in breach of the exclusion period.

Once the applicable retention period has expired and there is no overriding legal basis for continued storage, your personal data will be securely deleted or anonymised in accordance with our internal data destruction procedures.

Subject to applicable law and the limitations described in this Policy, you have the following rights in relation to your personal data held by clupk. You may exercise any of these rights by contacting our support team using the details provided in Section 14.

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed. We will respond to verified access requests within thirty (30) days.
• Right to Rectification: If you believe any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You may also update certain account information directly through your Player Account profile.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right is not absolute — where we are legally required to retain data (e.g., for AML compliance), we may be unable to fulfil an erasure request in its entirety.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on consent or contractual necessity and carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling. You also have an absolute right to object to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

clupk implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes, among other controls:

• TLS Encryption: All data transmitted between your device and the clupk platform is encrypted in transit using Transport Layer Security (TLS) protocol.
• Encryption at Rest: Sensitive personal data stored in our systems — including financial data and identity documents — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within clupk's internal systems is restricted on a strict need-to-know basis. Staff with access to Player data are subject to confidentiality obligations and undergo regular data security training.
• Two-Factor Authentication: clupk supports two-factor authentication (2FA) on Player Accounts to provide an additional layer of protection against unauthorised login attempts.
• Penetration Testing: Our platform infrastructure is subject to regular third-party penetration testing and vulnerability assessments to identify and remediate security weaknesses proactively.
• Incident Response: In the event of a confirmed personal data breach that poses a risk to your rights and freedoms, clupk will notify the relevant supervisory authority and affected Players in accordance with applicable legal timeframes.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

The clupk platform is strictly for adults aged 21 and above. We do not knowingly collect, process, or store personal data from any person under the age of 21 under any circumstances. Our registration process includes mandatory age verification steps designed to prevent underage access.

Parents and guardians are encouraged to make use of parental control software to prevent minors from accessing online gambling platforms. clupk actively supports responsible gaming initiatives and cooperates with child protection organisations where appropriate.

The clupk platform may contain links to third-party websites or services — for example, payment processor portals or licensing authority websites. This Privacy Policy applies solely to the clupk platform and does not cover the privacy practices of any third-party site.

We have no control over and accept no responsibility for the content, privacy policies, or practices of third-party websites. We recommend that you review the privacy policy of any third-party site you visit. Visiting a third-party website via a link on clupk is entirely at your own risk.

As an internationally operated platform, clupk may transfer your personal data to servers or third-party service providers located outside Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy.

Such safeguards may include standard contractual clauses approved by relevant data protection authorities, binding corporate rules, or transfers to countries that have been assessed as providing an adequate level of data protection. By using the clupk platform, you acknowledge and consent to the transfer of your personal data as described in this section.

clupk reserves the right to update or amend this Privacy Policy at any time. When we make a material change to the way in which we process your personal data, we will notify registered Players via email and/or a prominent notice on the platform prior to the change taking effect. The updated Policy will be identified by a revised effective date at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how clupk protects your data. Your continued use of the platform following the publication of any revision constitutes your acceptance of the updated Policy. If you do not agree with any amendment, you should discontinue use of the platform and may request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way clupk handles your personal data, please reach out to our Data Privacy team using the details below. We are committed to addressing all privacy-related enquiries promptly and transparently.

• Email: [email protected] (plain text — not a clickable link)
• 24/7 Live Chat: Available on the clupk platform after logging into your Player Account.
• Serving players across Pakistan — Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and beyond.

For formal data rights requests (access, erasure, portability, etc.), please include "Data Rights Request" in the subject line of your email and provide sufficient information to allow us to verify your identity. We aim to respond to all privacy-related requests within thirty (30) calendar days.

This Privacy Policy was last updated and is effective as of 1 January 2026. clupk reserves all rights not expressly granted herein.