33rcom Privacy
Policy

1 Who We Are

33rcom is an online casino and sports betting platform operated at 33rcom.app. 33rcom operates under an international gaming licence and provides services to players in Pakistan and other eligible jurisdictions. For the purposes of this Privacy Policy, 33rcom is the data controller in respect of all personal data collected through the platform.

If you have any questions about this Privacy Policy or about how 33rcom processes your personal data, please contact our Data Protection team using the contact information provided in Section 13 of this document.

2 Data We Collect

33rcom collects personal data in two ways: directly from you when you register, use the platform, or contact support; and automatically through the operation of the platform. The categories of personal data 33rcom collects are set out below.

2.1 Registration Data

When you create a 33rcom account, we collect:

• Full legal name
• Date of birth (to verify you are 21 or above)
• Pakistani mobile number (used for account security and two-factor authentication)
• Email address
• Residential address in Pakistan
• Username and encrypted password

2.2 Identity Verification Data

To comply with our international gaming licence requirements and anti-money laundering obligations, 33rcom may request:

• National Identity Card (CNIC) number and copy
• Passport or other government-issued photographic identification
• Proof of residential address (utility bill, bank statement)
• Source of funds documentation for withdrawals above applicable thresholds

2.3 Payment Data

33rcom processes all transactions in Pakistani Rupees (PKR). When you make a deposit or request a withdrawal, we collect the information necessary to process the transaction, including your JazzCash or EasyPaisa mobile number, or bank account details. Full payment card numbers are never stored on 33rcom's servers; card processing is handled by our licensed payment service providers.

2.4 Transaction & Gaming Data

33rcom maintains records of all deposits, withdrawals, bets, game results, bonus activity, and account balance changes. This data is retained for regulatory compliance, dispute resolution, and responsible gaming monitoring purposes.

2.5 Technical & Device Data

When you access 33rcom, we automatically collect technical data including:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session timestamps and duration
• Pages and features accessed within the platform
• Referring URL (the page you visited before arriving at 33rcom)

2.6 Communications Data

When you contact 33rcom's support team via live chat or email, we retain records of those communications for quality assurance, training, and dispute resolution purposes.

3 How We Use Your Data

33rcom uses the personal data it collects for the following purposes:

4 Legal Basis for Processing

33rcom processes personal data on the following legal bases, as indicated in the table in Section 3:

• Contract Performance: Processing necessary to fulfil our contractual obligations to you under the 33rcom Terms and Conditions, including account management, game provision, and payment processing.
• Legal Obligation: Processing required to comply with our international gaming licence conditions, anti-money laundering regulations, and age verification requirements.
• Legitimate Interest: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing for marketing and promotional communications. You may withdraw consent at any time by updating your communication preferences in your 33rcom account settings.

5 Cookies & Tracking Technologies

33rcom uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse how the platform is used. The categories of cookies we use are:

• Strictly Necessary Cookies: Required for the platform to function. These include session cookies that maintain your 33rcom login state and security cookies that prevent cross-site request forgery. These cookies cannot be disabled.
• Functional Cookies: Store your preferences such as language settings, preferred payment method, and display preferences. Disabling these cookies may affect platform functionality.
• Analytics Cookies: Collect anonymised data about how players use 33rcom — which pages are visited, how long sessions last, and which features are used most. This data is used to improve the platform.
• Responsible Gaming Cookies: Track session duration to support the platform's responsible gaming features, including session time alerts.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from accessing the 33rcom platform. A cookie preference centre is accessible from the footer of the 33rcom platform.

6 Data Sharing

33rcom does not sell your personal data. We share personal data only in the following limited circumstances:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other licensed payment processors receive the minimum data necessary to process your transactions.
• Game Providers: Third-party game suppliers integrated into the 33rcom lobby may receive anonymised session data for game certification and RNG auditing purposes. They do not receive identifiable personal data about individual players.
• Identity Verification Providers: Regulated identity and document verification services used to fulfil 33rcom's KYC obligations under its international gaming licence.
• Regulatory Authorities: 33rcom will share personal data with its licensing authority, relevant law enforcement agencies, or financial intelligence units where required by applicable law or court order.
• Fraud Prevention Networks: Where 33rcom has reasonable grounds to suspect fraudulent activity, relevant data may be shared with industry fraud prevention organisations.

7 International Data Transfers

As an internationally licensed platform, 33rcom's servers and some of its service providers may be located outside Pakistan. Where personal data is transferred to a country that does not provide an equivalent level of data protection, 33rcom implements appropriate safeguards to protect your data. These safeguards include standard contractual clauses approved by relevant data protection authorities, binding corporate rules where applicable, and technical encryption measures applied to data in transit and at rest.

By using 33rcom, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside Pakistan for the purposes described in this Privacy Policy.

8 Data Retention

33rcom retains personal data for as long as is necessary for the purposes set out in this Privacy Policy, and in accordance with the following minimum retention periods imposed by our international gaming licence:

• Account data and identity documents: Retained for a minimum of 5 years following account closure, or longer where required by applicable anti-money laundering regulations.
• Transaction and gaming records: Retained for a minimum of 5 years following the date of each transaction, in compliance with financial record-keeping requirements.
• Communications data (support interactions): Retained for 2 years following the date of each interaction, unless a longer period is required for dispute resolution purposes.
• Technical and device data: Retained for 12 months from collection, after which it is anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent and for 2 years following withdrawal of consent.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data may be retained indefinitely for statistical and platform improvement purposes.

9 Your Data Rights

Subject to applicable law and the limitations imposed by 33rcom's regulatory obligations, you have the following rights in respect of your personal data:

• Right of Access: You may request a copy of the personal data that 33rcom holds about you. 33rcom will provide this within 30 calendar days of a valid request.
• Right to Rectification: You may request the correction of inaccurate or incomplete personal data. Many account details can be updated directly from your 33rcom account settings without contacting support.
• Right to Erasure: In certain circumstances, you may request the deletion of your personal data. Note that 33rcom's regulatory obligations may require retention of certain data for minimum periods even following an erasure request.
• Right to Restrict Processing: You may request that 33rcom restricts the processing of your personal data in specified circumstances, such as where you contest the accuracy of the data.
• Right to Data Portability: Where processing is based on your consent or on contract performance, you may request a machine-readable copy of your personal data.
• Right to Object: You may object to processing based on legitimate interest, including profiling for marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent (such as marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of the above rights, please contact 33rcom's Data Protection team using the contact details in Section 13. We will acknowledge your request within 5 business days and provide a full response within 30 calendar days.

10 Children's Privacy

33rcom is strictly for individuals aged 21 and above. 33rcom does not knowingly collect personal data from anyone under the age of 21. Age verification is part of the account registration process, and 33rcom may request identity documentation at any time to confirm age compliance.

If 33rcom becomes aware that it has inadvertently collected personal data from an individual under the age of 21, the relevant account will be closed immediately, all associated funds will be dealt with in accordance with 33rcom's Terms and Conditions, and the personal data will be deleted as promptly as regulatory retention obligations permit.

11 Security Measures

33rcom implements a range of technical and organisational security measures to protect the personal data it holds against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• TLS 1.3 encryption for all data in transit between your device and 33rcom's servers.
• AES-256 encryption for sensitive personal data stored at rest, including identity documents and payment data.
• Role-based access controls that restrict internal access to personal data on a strict need-to-know basis.
• Multi-factor authentication for all internal staff systems that process personal data.
• Regular penetration testing and independent security audits of the 33rcom platform.
• A formal data breach response procedure, including notification obligations where a breach is likely to result in risk to affected individuals.

While 33rcom takes all reasonable steps to protect your personal data, no digital platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 33rcom login credentials and for notifying us immediately if you suspect unauthorised access to your account.

12 Updates to This Privacy Policy

33rcom reviews and updates this Privacy Policy periodically to reflect changes in our data practices, the services we offer, or applicable data protection law. The "Effective Date" at the top of this document indicates when the current version came into force.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how your data is used — 33rcom will notify registered players via their registered email address or via a prominent notice on the platform, at least 14 days before the changes take effect.

Your continued use of 33rcom after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated terms, you should discontinue use and may request account closure in accordance with the 33rcom Terms and Conditions.

13 Contact & Complaints

If you have questions about this Privacy Policy or wish to exercise any of your data rights, please contact 33rcom's Data Protection team. Our support team is available 24 hours a day, 7 days a week via live chat on the platform. For formal data rights requests and complaints, please contact us in writing using the email address displayed in the footer of this page. Formal requests will be acknowledged within 5 business days and resolved within 30 calendar days.

If you are not satisfied with 33rcom's response to your data rights request or privacy complaint, you may escalate your complaint to the data protection supervisory authority in the jurisdiction of 33rcom's international gaming licence, or to a relevant consumer protection body available to Pakistani players.