Popzar Privacy Policy

Introduction

Popzar ("we", "us", "our" or the "Platform") is an English-language online gaming information platform available at https://popzar.cam, designed and operated primarily for Pakistani users and others who access the Platform from jurisdictions where such content is accessible.

We are committed to protecting your personal data and handling it with transparency, care and respect. This Privacy Policy (the "Policy") describes the types of personal data we collect from users of the Platform, the purposes for which we process it, the legal basis for that processing, the circumstances in which we may share it, how long we retain it, the security measures we apply to protect it, and the rights you have in relation to your data.

This Policy is intended to comply with applicable data protection principles and should be read together with Popzar's Terms and Conditions, which govern the overall use of this Platform. Where this Policy uses terms not defined here, those terms carry the meaning assigned in the Terms and Conditions.

Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person (a "Data Subject"). An identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• "Processing" means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure or destruction.
• "Data Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Policy, Popzar is the Data Controller.
• "Data Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the Data Controller.
• "User" means any individual who accesses or uses the Popzar Platform.
• "Cookies" means small text files stored on a User's device by a website, used to store information about that User's session or preferences.
• "Third-Party Service Providers" means external companies or individuals engaged by Popzar to perform functions in connection with the Platform, such as analytics services, hosting providers or support tools.

Personal Data We Collect

Popzar collects personal data through a number of channels. The categories of personal data we collect are described below.

3.1 Data You Provide Directly

When you interact with the Platform — for example, by submitting a support enquiry or completing a contact form — you may provide us with the following types of personal data:

• Your name;
• Your email address;
• Your message or query content;
• Any other information you voluntarily include in your communication.

3.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically by our infrastructure, including:

• IP address and approximate geographic location (country/city level — for example, Karachi, Lahore or Islamabad);
• Browser type and version;
• Device type (desktop, mobile or tablet), operating system and screen resolution;
• Pages visited, time spent on pages and navigation paths;
• Referring URLs (the page that directed you to our Platform);
• Date and time of access;
• Cookie identifiers and session tokens as described in Section 7.

3.3 Data from Analytics Providers

We may use third-party analytics services to help us understand how users interact with the Platform. These services may collect and process data about your usage patterns in aggregated or pseudonymised form. We do not use analytics data to identify you personally.

How We Use Your Personal Data

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

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects on you.

Legal Basis for Processing

Where data protection law requires us to have a legal basis for processing your personal data, we rely on one or more of the following:

• Consent: Where you have given us clear and informed consent to process your personal data for a specific purpose, such as accepting non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Contract Performance: Where processing is necessary to provide you with a service you have requested, or to take steps at your request prior to entering into a contract — for example, responding to a support enquiry.
• Legitimate Interests: Where processing is necessary for our legitimate interests (or those of a third party), provided those interests are not overridden by your data protection rights. Our legitimate interests include operating a secure, functional and improved Platform and communicating with users who have contacted us.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which Popzar is subject, including applicable laws in the jurisdiction in which we operate.

Data Sharing and Disclosure

Popzar does not sell, rent or trade your personal data to third parties. We may, however, share personal data in the following limited circumstances:

• Service Providers and Data Processors: We engage third-party service providers to assist in operating the Platform, such as web hosting providers, cloud storage services, analytics platforms and customer support tools. These providers process personal data only on our instruction and in accordance with written data processing agreements. They are not permitted to use your data for their own purposes.
• Legal and Regulatory Disclosures: We may disclose personal data where required to do so by applicable law, court order, regulatory authority or government body. We will notify you of such a requirement where legally permissible to do so.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or substantially all of Popzar's assets, personal data held by us may be transferred to the acquiring or successor entity. We will notify users of any such transfer and the applicable privacy arrangements.
• Protection of Rights: We may disclose personal data where necessary to protect the legal rights, property or safety of Popzar, its users or others, and where doing so is consistent with applicable law.

Cookies and Similar Technologies

Popzar uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by a website when you visit it. Cookies are widely used to make websites function efficiently and to provide information to the site operators.

We use the following categories of cookies:

You can control and manage cookies through your browser settings. Most browsers allow you to refuse, delete or be notified when cookies are set. Please note that disabling essential cookies may affect the functionality of the Platform.

Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, consistent with our legal obligations and legitimate business needs. The following general retention principles apply:

• Support Enquiry Data: Name, email address and message content submitted via support enquiries are retained for up to 12 months following resolution of the enquiry, after which they are securely deleted unless a longer retention period is required for legal or compliance purposes.
• Technical and Analytics Data: IP addresses and automatically collected device/usage data are retained in anonymised or aggregated form. Raw IP logs are retained for no more than 90 days unless required by law enforcement or legal process.
• Cookie Data: Session cookies expire when you close your browser. Persistent cookies expire according to the timeframe set in your browser or as defined in the cookie itself — typically between 30 days and 12 months for non-essential cookies.
• Legal Compliance Data: Where we are required by applicable law to retain data for a specific period (e.g., for tax, audit or regulatory purposes), we will retain data for the minimum period required and no longer.

When the applicable retention period expires, personal data is securely deleted, anonymised or rendered irreversibly inaccessible in a manner consistent with industry standards.

Data Security

Popzar takes the security of your personal data seriously. We implement a range of technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure or destruction. These measures include:

• Encryption of personal data in transit using TLS (Transport Layer Security);
• Encryption of personal data at rest where technically practicable;
• Restricted access controls — personal data is accessible only to authorised personnel who require it for legitimate operational purposes;
• Regular review of our security practices and vendor security posture;
• Incident response procedures for identifying, reporting and responding to data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Popzar will take all steps required under applicable law, including notifying affected individuals where the circumstances require it.

Your Data Protection Rights

Subject to applicable data protection law and any exemptions that may apply, you have the following rights in relation to your personal data held by Popzar:

To exercise any of these rights, please contact us using the details set out in Section 14. We will respond to your request within 30 days of receipt, and may request verification of your identity before acting on your request. Where requests are complex or numerous, this period may be extended by a further two months, and we will notify you accordingly.

We do not charge a fee for exercising your rights unless your request is manifestly unfounded or excessive, in which case we reserve the right to charge a reasonable administrative fee.

Children and Minors

The Popzar Platform is strictly intended for adults aged 18 years or older (or the higher minimum age required by the applicable operator or license jurisdiction). We do not knowingly collect, solicit or process personal data from individuals under the age of 18.

If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us immediately at the details in Section 14. We will take prompt steps to delete such data from our systems.

International Data Transfers

Popzar operates under an international framework and may use service providers, hosting infrastructure and technology platforms located outside of Pakistan. This means that personal data collected from Pakistani users may be transferred to, stored in and processed in countries other than Pakistan.

Where personal data is transferred outside the jurisdiction in which it was collected, we take steps to ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection principles. Such safeguards may include:

• Standard contractual clauses or equivalent data transfer mechanisms approved by the relevant supervisory authority;
• Transfers to processors in jurisdictions that provide an adequate level of data protection as determined by applicable law;
• Binding corporate rules where applicable.

You may request further information about the specific safeguards applicable to cross-border transfers of your personal data by contacting us at the details in Section 14.

Updates to This Privacy Policy

Popzar reserves the right to update, modify or replace this Privacy Policy at any time, in response to changes in applicable law, our data processing practices, the services we offer or other operational reasons. When material changes are made, we will update the "Effective Date" and "Last Reviewed" dates displayed at the top of this page.

Where changes are significant, we may notify users through a prominent notice on the Platform. We encourage you to review this Policy periodically to stay informed about how we handle your personal data. The most current version of this Policy will always be available at https://popzar.cam/privacy-policy.

Your continued use of the Platform after the posting of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you should cease using the Platform.

Contact Us — Data Rights and Privacy Enquiries

If you have any questions, concerns or requests relating to this Privacy Policy or the way Popzar processes your personal data, or if you wish to exercise any of your data protection rights as described in Section 10, please contact us in writing.

All privacy-related correspondence should be directed to our support team by email. We acknowledge data rights requests within 3 business days and respond in full within 30 days of receipt, operating in Pakistan Standard Time (PKT, UTC+5).