pkom Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal information collected by pkom through the website located at https://pkom.io, all associated subdomains, mobile-optimized interfaces, and any applications or services provided by pkom (collectively, the "Platform"). This Privacy Policy is incorporated into and forms part of the pkom Terms & Conditions.

pkom respects your right to privacy and is committed to protecting your personal information in accordance with applicable data protection laws. This Privacy Policy explains:

• What personal information we collect about you;
• How and why we collect and use your personal information;
• Who we share your personal information with and under what circumstances;
• How long we retain your personal information;
• The security measures we employ to protect your data;
• Your rights regarding your personal information and how to exercise them.

For purposes of this Privacy Policy, "personal information" or "personal data" means any information relating to an identified or identifiable natural person. The terms "we," "us," "our," and "pkom" refer to the pkom platform and its operating entity.

2. Information We Collect

2.1 Information You Provide Directly

When you register for a pkom account, we collect personal information that you provide directly to us, including:

• Identity Information: Your full legal name, date of birth, gender, and nationality as shown on your government-issued identification documents;
• Contact Information: Your mobile phone number, email address, and residential address;
• Account Credentials: Your chosen username and password (passwords are cryptographically hashed and never stored in plain text);
• Verification Documents: Copies of government-issued photo ID (National ID card, passport), proof of address documents, and selfie photographs submitted during KYC verification;
• Payment Information: Details of your bKash, Nagad, Rocket, Upay, or bank account used for deposits and withdrawals (we do not store full card numbers or CVV codes for card transactions);
• Communication Content: Messages, questions, and files you send to our customer support team via live chat, email, or other communication channels.

2.2 Information Collected Automatically

When you access or use the pkom platform, we automatically collect certain technical and usage information, including:

• Device Information: Your device type, operating system, browser type and version, screen resolution, device manufacturer and model;
• Connection Information: Your IP address, internet service provider, approximate geographic location based on IP address, and time zone;
• Usage Information: Pages you visit on the Platform, time and date of visits, time spent on pages, links clicked, games played, bets placed, search queries entered, and referral sources;
• Transaction Information: Complete history of deposits, withdrawals, bets placed, bet outcomes, bonus claims, and account balance changes;
• Cookies and Similar Technologies: Data collected through cookies, web beacons, local storage, and similar tracking technologies (see Section 7 for details).

2.3 Information from Third-Party Sources

We may receive personal information about you from third-party sources, including:

• Payment processors and financial institutions when processing your deposits and withdrawals;
• Identity verification services that confirm your age, identity, and address during KYC checks;
• Game providers that supply casino games and slots, who may provide game session data;
• Fraud prevention and anti-money-laundering service providers who help us detect suspicious activity;
• Marketing partners if you have chosen to participate in joint promotions or referral programs.

3. How We Use Your Information

pkom uses your personal information for the following purposes:

3.1 Account Management and Service Provision

• Creating and managing your pkom account;
• Verifying your identity and age to ensure compliance with our 21+ age requirement;
• Processing your deposits and withdrawals via bKash, Nagad, Rocket, Upay, and supported bank accounts;
• Providing access to casino games, slots, live dealer tables, and sports betting markets;
• Maintaining accurate records of your betting history, account balance, and transaction history;
• Responding to your customer support inquiries and resolving disputes;
• Sending transactional communications such as deposit confirmations, withdrawal notifications, and account alerts.

3.2 Security, Fraud Prevention, and Legal Compliance

• Detecting and preventing fraud, money laundering, and other financial crimes;
• Verifying the authenticity of payment methods and identifying unauthorized transactions;
• Monitoring for and investigating suspicious betting patterns or collusion;
• Enforcing our Terms & Conditions, including detecting duplicate accounts and bonus abuse;
• Complying with applicable legal and regulatory obligations, including anti-money-laundering (AML) requirements;
• Responding to law enforcement requests, court orders, or other lawful demands for information.

3.3 Platform Improvement and Analytics

• Analyzing usage patterns to improve the design, functionality, and content of the pkom platform;
• Conducting research and statistical analysis to understand player preferences and behavior;
• Testing new features, games, and promotions before full rollout;
• Diagnosing and resolving technical issues, bugs, and server performance problems;
• Measuring the effectiveness of marketing campaigns and promotions.

3.4 Responsible Gaming

• Monitoring gaming behavior to identify signs of problem gambling or excessive play;
• Enforcing self-exclusion requests and deposit limits set by players;
• Sending responsible gaming reminders and recommendations to players who exhibit at-risk behavior;
• Maintaining self-exclusion records to prevent re-registration by self-excluded players.

3.5 Marketing and Promotions

With your consent, we may use your contact information and usage data to send you personalized promotional offers, bonus notifications, and news about pkom's latest games and features. You may withdraw your consent to marketing communications at any time by contacting [email protected] or by using the unsubscribe link in any marketing email. Withdrawal of consent does not affect transactional communications, which are required for account management.

4. Legal Basis for Processing

pkom processes your personal information on the following legal grounds:

• Contractual Necessity: Processing required to provide the services you have requested under our Terms & Conditions, including account creation, payment processing, and game access;
• Legal Obligation: Processing required to comply with applicable laws, including anti-money-laundering regulations, age verification requirements, and responding to lawful government requests;
• Legitimate Interests: Processing for purposes of fraud prevention, platform security, service improvement, and responsible gaming monitoring, where these interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent that can be withdrawn at any time.

5. Data Sharing and Third Parties

5.1 Service Providers

pkom shares personal information with third-party service providers who assist us in delivering the Platform and associated services. These providers are contractually obligated to process your data only as directed by pkom and for no other purpose. Our service providers include:

• Payment Processors: bKash, Nagad, Rocket, Upay, and supported Bangladeshi banks (Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank) receive transaction data necessary to process your deposits and withdrawals;
• Game Providers: Licensed game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive game session data to deliver their games within the pkom platform;
• Identity Verification Services: Third-party KYC providers receive copies of your identification documents and personal details to verify your identity and age;
• Fraud Prevention Services: Anti-fraud and AML service providers receive transaction and behavioral data to detect suspicious activity;
• Cloud Infrastructure: Hosting and cloud services providers store platform data on secure servers. All hosting partners are required to maintain appropriate security certifications;
• Customer Support Tools: Live chat and helpdesk platform providers process communication data when you contact our support team.

5.2 Legal Disclosures

pkom may disclose your personal information to government authorities, law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, judicial order, or legitimate regulatory request. We will notify you of such disclosures where legally permitted to do so. We do not voluntarily provide data to government authorities beyond what is legally required.

5.3 Business Transfers

In the event that pkom undergoes a merger, acquisition, restructuring, or sale of assets, your personal information may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the new entity before your data is transferred, and you will have the opportunity to request deletion of your data prior to the transfer taking effect.

5.4 What We Do Not Share

pkom will never: (a) sell, rent, or lease your personal information to any third party for commercial or marketing purposes; (b) share your personal information with advertisers or advertising networks; (c) share your data with other gambling operators or betting exchanges; (d) provide your information to data brokers or list aggregators.

6. International Data Transfers

The pkom platform primarily serves players in Bangladesh, and we endeavor to store and process personal data within secure server environments. Some of our third-party service providers, including game studios and cloud infrastructure partners, may process data on servers located outside Bangladesh. When such international transfers occur, pkom takes steps to ensure that your personal information receives an equivalent level of protection by:

• Entering into data processing agreements with all international service providers that include binding obligations to protect your data;
• Requiring that international partners maintain industry-standard security certifications and access controls;
• Conducting due diligence on the data protection practices of all third-party providers before engaging them;
• Limiting the categories of data transferred internationally to only what is strictly necessary for the relevant service.

7. Cookies and Tracking Technologies

7.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. They allow the website to remember your preferences, authenticate your session, and gather analytical information. pkom uses cookies and similar technologies including web beacons, pixel tags, and local storage to enhance your experience on the Platform.

7.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in, security cookies that protect against cross-site request forgery, and cookies that store your language and currency preferences. These cookies cannot be disabled without breaking core Platform functionality;
• Functional Cookies: Enhance your experience by remembering your preferences, such as your preferred game view, table limits, and notification settings. Disabling these cookies may reduce your experience but will not prevent you from using the Platform;
• Analytical Cookies: Help us understand how players use the Platform by collecting aggregated data on page visits, game session durations, feature usage, and navigation paths. This data is used to improve the Platform and is not linked to individual user identities in our analytics reports;
• Responsible Gaming Cookies: Track your session duration and deposit activity to support responsible gaming features such as session time reminders and limit enforcement.

7.3 Managing Cookies

You may control and delete cookies through your browser settings. Most web browsers allow you to refuse new cookies, delete existing cookies, and set preferences for specific websites. Please note that disabling strictly necessary cookies will prevent you from logging in to your pkom account and using core Platform features. Instructions for managing cookies in popular browsers are available in each browser's help documentation.

8. Data Security Measures

pkom implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encryption in Transit: All data transmitted between your browser and pkom servers is encrypted using 256-bit SSL/TLS protocols. Our platform enforces HTTPS on all pages and redirects any HTTP connections to HTTPS automatically;
• Encryption at Rest: Sensitive data stored in our databases, including personal identification information and financial records, is encrypted at rest using AES-256 encryption;
• Password Security: Account passwords are never stored in plain text. We use industry-standard cryptographic hashing with salt to protect credentials. pkom employees cannot view or recover your password;
• Access Controls: Access to systems containing personal data is restricted to authorized pkom personnel on a need-to-know basis. All access is authenticated using multi-factor authentication and logged for audit purposes;
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and regular vulnerability scanning. DDoS protection is in place to ensure platform availability;
• Security Audits: We conduct regular internal security reviews and periodic third-party penetration testing to identify and remediate vulnerabilities before they can be exploited;
• Incident Response: pkom maintains a documented security incident response plan. In the event of a data breach that poses a risk to your rights and freedoms, we will notify affected users promptly.

9. Data Retention and Deletion

9.1 Retention Periods

pkom retains your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, and resolve disputes. Our standard retention periods are:

• Active Account Data: Retained for the duration of your account and for 5 years following account closure, to comply with anti-money-laundering record-keeping requirements;
• Transaction Records: Full transaction history is retained for 7 years from the date of each transaction to meet financial record-keeping and tax compliance obligations;
• KYC Documents: Identity verification documents are retained for 5 years following account closure in accordance with AML regulations;
• Customer Support Communications: Support tickets and chat logs are retained for 3 years from the date of the interaction;
• Marketing Consent Records: Records of marketing consent and withdrawal are retained for 3 years from the date of consent or withdrawal;
• Analytical Data: Anonymized and aggregated analytical data may be retained indefinitely as it cannot be linked to individual users.

9.2 Account Closure and Data Deletion

When you request closure of your pkom account, we will delete or anonymize your personal information within 90 days, except where retention is required by law. Certain data categories — particularly transaction records, KYC documents, and self-exclusion records — must be retained for the regulatory periods specified above regardless of account closure. Self-exclusion records are retained indefinitely to prevent re-registration attempts.

10. Your Privacy Rights

You have the following rights with respect to your personal information held by pkom:

• Right of Access: You may request a copy of all personal information we hold about you, including the categories of data, purposes of processing, and any third parties with whom it has been shared. We will respond to access requests within 30 days;
• Right to Rectification: If any personal information we hold about you is inaccurate or incomplete, you may request that it be corrected or updated. You may update most account information directly through your account settings;
• Right to Erasure: You may request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to our legal retention obligations;
• Right to Restrict Processing: You may request that we restrict processing of your personal data in certain circumstances, such as while you contest the accuracy of the data or while we investigate a complaint;
• Right to Data Portability: Where processing is based on consent or contractual necessity, you may request that we provide your personal data in a structured, machine-readable format that can be transferred to another service provider;
• Right to Object: You may object to processing of your personal data based on our legitimate interests or for marketing purposes. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our data protection team at [email protected] with the subject line "Privacy Rights Request." We may require proof of identity before processing your request to prevent unauthorized disclosure or deletion of data. We will respond to all privacy rights requests within 30 days of receipt.

11. Children's Privacy

The pkom platform is strictly for adults aged 21 years and above. We do not knowingly collect personal information from individuals under the age of 21. If you are under 21 years of age, you must not use the pkom platform or provide any personal information to us.

If pkom discovers that personal information has been collected from a person under the age of 21, we will immediately close the account, void all bets and bonuses, and delete all personal information associated with that account. We may retain records sufficient to prevent future registration attempts by that individual. If you believe that a person under 21 has registered for a pkom account, please contact us immediately at [email protected].

12. Marketing Communications

pkom may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, seasonal promotions, and platform updates. We will only send marketing communications where you have provided explicit consent at the time of registration or subsequently opted in through your account settings.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link in any promotional email;
• Adjusting your notification preferences in your pkom account settings;
• Contacting [email protected] with the subject line "Unsubscribe from Marketing."

Opting out of marketing communications will not affect your receipt of transactional messages such as deposit confirmations, withdrawal notifications, password reset emails, or important account security alerts. These service messages are sent regardless of marketing preferences as they are necessary for account management.

13. Changes to This Policy

pkom reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will update the effective date at the top of this document and notify registered users via email to the address associated with their account. The updated Privacy Policy will also be posted prominently on the pkom website.

Your continued use of the pkom platform after notification of any changes constitutes acceptance of the revised Privacy Policy. If you do not accept the revised terms, you may request closure of your account and deletion of your personal data in accordance with Section 9 of this policy. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

14. Contact and Data Protection Officer

If you have any questions, concerns, or complaints about this Privacy Policy or our handling of your personal data, please contact pkom's data protection team using the following details:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Protection Request"
• Live Chat: Available 24/7 within the pkom platform after logging in
• Website: https://pkom.io

We aim to respond to all privacy-related inquiries within 5 business days. For formal data rights requests (access, rectification, erasure, portability), we will respond within 30 days of receipt and may request proof of identity before processing your request.

If you are not satisfied with our response to a privacy concern, you may escalate your complaint through appropriate consumer protection channels available in Bangladesh. pkom is committed to resolving all privacy complaints fairly and transparently.