Privacy Policy — How poku Protects Your Data

This Privacy Policy (hereinafter referred to as "Policy") sets out the practices of poku (hereinafter "poku", "we", "us", or "our") with respect to the collection, use, storage, disclosure, and protection of personal data belonging to users (hereinafter "you", "User", or "Player") of the poku platform, including the website at poku.club, all associated pages, mobile-optimised views, and related services (collectively the "Platform").

poku is operated as an offshore online casino and sports betting platform. We are committed to handling all personal data responsibly and in a manner consistent with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, and integrity and confidentiality.

By accessing the Platform, registering an account, or otherwise providing personal data to poku, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein. This Policy should be read alongside poku's Terms & Conditions and Responsible Gaming Policy.

If you have any questions about how poku processes your personal data, please contact our support team at [email protected] before registering or providing any personal information.

poku collects personal data in several categories. The specific data collected depends on how you interact with the Platform and the stage of your account lifecycle. The categories of personal data we may collect include:

poku does not collect sensitive personal data such as racial or ethnic origin, religious beliefs, health data, or political opinions unless specifically required by law or regulation and only with your explicit consent.

poku collects personal data through the following methods:

• Direct Interactions: Data you voluntarily provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. Please refer to Section 7 (Cookies & Tracking) for full details.
• Third-Party Sources: Identity and fraud-screening data received from KYC verification providers, payment processors (including bKash, Nagad, Rocket, Upay, Visa, and Mastercard), and anti-fraud intelligence services. poku only receives data from third parties where a legitimate basis exists for doing so.
• Publicly Available Sources: In limited circumstances, poku may supplement account records with information from publicly available sources to assist with fraud detection or regulatory compliance.

poku processes personal data only for specified, explicit, and legitimate purposes. The primary purposes for which your data is used are set out below:

• Account Management: To create, maintain, and administer your poku account, including authentication, password resets, and account security alerts.
• Service Delivery: To provide access to casino games, sports betting markets, live dealer tables, Aviator, slots, and all other Platform products and features.
• Payment Processing: To process deposits and withdrawals via your chosen payment method, and to maintain accurate transaction records.
• Identity Verification (KYC): To verify your identity and age in compliance with anti-money laundering (AML) obligations and to confirm that you meet the Platform's eligibility requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, collusion, bonus abuse, and other prohibited conduct on the Platform.
• Legal & Regulatory Compliance: To meet applicable legal, regulatory, and reporting obligations, and to respond to lawful requests from competent authorities.
• Customer Support: To respond to support queries, resolve disputes, and handle complaints efficiently and accurately.
• Responsible Gaming: To monitor gameplay patterns for indicators of problem gambling, to administer self-exclusion and limit-setting requests, and to proactively reach out to players who may need support.
• Marketing & Promotions: Where you have provided consent, to send you information about relevant promotions, bonuses, and platform updates. You may opt out of marketing communications at any time by contacting [email protected].
• Platform Improvement: To analyse aggregated usage data in order to improve the Platform's performance, design, and content offering.

poku processes personal data on one or more of the following legal bases, depending on the specific processing activity in question:

• Contractual Necessity: Processing required to perform the contract between you and poku — including account creation, service delivery, payment processing, and account management — is carried out on the basis that it is necessary for the performance of that contract.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC/AML requirements and responses to lawful authority requests, is carried out on the basis of legal obligation.
• Legitimate Interests: Processing carried out to pursue poku's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and service improvement — where those interests are not overridden by your rights and interests.
• Consent: Processing for marketing and promotional communications is conducted on the basis of your freely given, specific, and informed consent. You retain the right to withdraw consent at any time without detriment.

poku does not sell, rent, or trade your personal data to third parties for their own independent marketing or commercial purposes. Personal data is shared only in the following limited and controlled circumstances:

• Payment Service Providers: Financial data is shared with payment processors — including bKash, Nagad, Rocket, Upay, Visa, Mastercard, and Dutch-Bangla Bank — to the extent strictly necessary to process your transactions. These providers operate under their own privacy frameworks and are bound by appropriate data processing agreements with poku.
• Game Software Providers: Technical and gameplay data may be shared with licensed third-party game providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — to facilitate game delivery, ensure fair play, and handle game-related disputes.
• KYC & Fraud Screening Services: Identity and verification data is shared with specialist third-party KYC and anti-fraud service providers for the purpose of age verification, identity confirmation, and fraud risk assessment.
• Legal & Regulatory Authorities: Personal data may be disclosed to competent authorities — including law enforcement, financial intelligence units, or regulatory bodies — where required by applicable law or in response to a valid legal request. poku will, where legally permissible, notify you of such a request before complying.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of poku's business or assets, personal data held by poku may be transferred to the successor entity, subject to the same or equivalent privacy protections as set out in this Policy.
• Professional Advisors: Personal data may be shared with poku's legal advisors, auditors, and accountants where necessary for them to provide their professional services, subject to appropriate confidentiality obligations.

All third parties with whom poku shares personal data are required to maintain the confidentiality and security of that data, and to use it only for the purposes for which it was shared.

poku uses cookies and similar tracking technologies to enhance your experience on the Platform, to maintain session continuity, and to collect analytical data about Platform usage. The categories of cookies used by poku are as follows:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as user authentication, session management, and security functions. These cookies cannot be disabled without impairing your ability to use the Platform.
• Analytical / Performance Cookies: These cookies collect aggregated and anonymised data about how users interact with the Platform — including which pages are visited most frequently and how users navigate between sections. This data is used solely to improve Platform performance and content. No personally identifiable information is collected by these cookies.
• Functional Cookies: These cookies remember your preferences — such as language settings, display options, and recent game selections — to provide a more personalised and convenient experience.
• Marketing / Targeting Cookies: Where you have provided consent, these cookies are used to deliver relevant promotional content and to measure the effectiveness of poku's marketing activities. You may withdraw consent for marketing cookies at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect your ability to access certain features of the Platform. For a full list of the specific cookies used by poku, please contact [email protected].

poku retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Active Account Data: Personal data associated with an active poku account is retained for the lifetime of the account and for a period of five (5) years following account closure, in order to meet AML/KYC record-keeping obligations.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years from the date of the transaction.
• KYC Documentation: Identity verification documents are retained for five (5) years following the date of verification or account closure, whichever is later.
• Support Communications: Support chat transcripts and email correspondence are retained for two (2) years from the date of the communication, unless they are relevant to an ongoing dispute or legal proceeding.
• Technical & Usage Data: Anonymised analytical data may be retained indefinitely for Platform improvement purposes. Identifiable technical data (e.g., IP address logs) is retained for twelve (12) months.
• Marketing Consent Records: Records of your marketing consent or opt-out are retained for the period necessary to demonstrate compliance, typically three (3) years from the date of the consent or withdrawal.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to any individual.

poku applies a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Key security measures include:

• 256-Bit SSL Encryption: All data transmitted between your device and the poku Platform is encrypted using 256-bit Secure Socket Layer (SSL) technology, the same standard used by major financial institutions worldwide.
• Encrypted Data Storage: Sensitive personal and financial data stored in poku's systems is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data within poku's internal systems is restricted on a strict need-to-know basis. Personnel with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Intrusion Detection: poku's infrastructure is monitored continuously for suspicious activity using automated intrusion detection and prevention systems.
• Regular Security Audits: poku conducts periodic security assessments and penetration tests to identify and remediate potential vulnerabilities in the Platform's infrastructure.

Notwithstanding these measures, no method of electronic transmission or storage is completely secure. poku cannot guarantee absolute security of your personal data. In the event of a data breach that poses a risk to your rights and interests, poku will notify affected users in accordance with applicable legal requirements and will take all reasonable steps to mitigate the impact of the breach.

You are also responsible for maintaining the security of your own account. Do not share your poku login credentials with anyone, and contact [email protected] immediately if you suspect unauthorised access to your account.

As a data subject whose personal information is processed by poku, you hold a number of rights in relation to your personal data. poku is committed to facilitating the exercise of these rights promptly and without undue delay. Your rights include:

• Right of Access: You have the right to request a copy of the personal data that poku holds about you, together with information about how it is being processed.
• Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data held by poku. You may update certain account details directly through your account profile, or by contacting support.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data. Please note that this right is subject to poku's legal data retention obligations — in particular, AML/KYC record-keeping requirements may necessitate the retention of certain data even after account closure.
• Right to Restrict Processing: You have the right to request that poku restricts the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to the basis on which it is being processed.
• Right to Data Portability: Where processing is based on your consent or on a contractual basis and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where it is based on poku's legitimate interests, including for direct marketing purposes. Where you object to marketing, poku will cease processing your data for that purpose immediately.
• 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.

To exercise any of the above rights, please submit a written request to [email protected]. poku will respond to all valid requests within thirty (30) days. In complex cases, an extension of up to a further sixty (60) days may apply, in which case you will be notified of the extension and the reason for it.

The poku Platform is strictly intended for persons aged 18 years or older. poku does not knowingly collect, process, or store personal data relating to children or minors under the age of 18. All registration processes include age verification steps, and poku may request documentary proof of age at any time.

If poku discovers or is notified that personal data belonging to a person under the age of 18 has been collected, the relevant account will be suspended immediately, all data will be deleted (subject to any mandatory legal retention requirements), and the matter will be escalated to poku's compliance team. Parents or guardians who believe that a minor has registered on the Platform should contact [email protected] without delay.

poku operates as an offshore platform, and your personal data may be transferred to and processed in countries outside your country of residence — including countries that may not provide the same level of data protection as your home jurisdiction. Such transfers may occur in connection with the provision of services by poku's third-party game providers, payment processors, KYC partners, and infrastructure service providers, who may operate data centres or process data in various international locations.

Where personal data is transferred internationally, poku takes appropriate safeguards to ensure that the transfer is carried out in a manner consistent with internationally recognised data protection standards. These safeguards may include contractual clauses, data processing agreements, or reliance on the data protection frameworks of the recipient country. By registering an account and using the Platform, you acknowledge and consent to the international transfer of your personal data as described in this section.

The poku Platform may contain references to third-party products, providers, or services — such as game software providers or payment partners — whose privacy practices are independent of poku. This Privacy Policy applies exclusively to poku's own data processing activities and does not extend to any third-party platforms, websites, or services.

poku encourages users to review the privacy policies of any third-party providers with whom they interact in connection with their use of the Platform. poku accepts no responsibility or liability for the privacy practices, data collection activities, or content of third-party entities.

poku reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or operational requirements. When material changes are made, the revised Policy will be published on this page with an updated "Last Updated" date. poku may also notify registered users of significant changes via email or an in-platform notification.

Continued use of the Platform following publication of an updated Privacy Policy constitutes your acknowledgement of and agreement to the revised terms. If you do not agree with any change to this Policy, you should discontinue use of the Platform and may request account closure by contacting [email protected]. It is your responsibility to review this Policy periodically to remain informed of how poku manages your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or poku's handling of your personal data, please contact our dedicated support team. All privacy-related enquiries should be submitted in English to ensure they are handled promptly and accurately.