33r Privacy Policy – How We Handle Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how 33r ("33r", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of users ("you", "your") who access or use the 33r platform located at 33r.bio, including all associated features such as account management, sports betting, casino games, and payment services.

33r is committed to protecting the privacy of all users and to handling personal data in a transparent, lawful, and secure manner. This Policy is intended to help you understand your privacy rights and how to exercise them.

By registering an account with 33r, accessing the platform, or using any of its services, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not register an account or use the 33r platform.

This Policy should be read together with the 33r Terms & Conditions. In the event of any conflict between the two documents in relation to data privacy matters, this Policy takes precedence.

2. Personal Data We Collect

33r collects personal data through several channels during the course of your use of the platform. The categories of data we collect include the following:

Registration Data: When you create a 33r account, we collect your name, date of birth, email address, username, password (stored as a salted cryptographic hash – never in plain text), and the country from which you are registering.

Identity Verification Data (KYC): Where required for account verification or withdrawal processing, we may collect copies of government-issued identification documents such as a Pakistani National Identity Card (CNIC), passport, or driving licence, along with proof of address and proof of payment method ownership. This data is collected to comply with anti-money laundering (AML) obligations and responsible gaming age verification requirements.

Financial Data: We collect records of deposits and withdrawals transacted through your 33r account, including amounts, timestamps, payment methods used (e.g., JazzCash, Easypaisa, bank transfer), and transaction reference numbers. We do not store payment credentials such as mobile wallet PINs, bank account passwords, or card numbers on 33r servers. All financial transactions are processed directly through the respective certified payment providers.

Betting & Gaming Activity Data: We maintain records of all bets placed, games played, wagers, outcomes, bonus activity, and account balance history. This data is used for account management, responsible gaming monitoring, and dispute resolution.

Technical & Device Data: We collect IP address, browser type and version, device type and operating system, screen resolution, time zone, referring URL, and session duration data when you access the 33r platform. This information is collected automatically via server logs and analytics tools.

Communications Data: If you contact 33r support via email or any other channel, we retain records of your communications, including the content of messages and any attachments provided, for the purpose of resolving your query and for quality assurance.

3. How We Use Your Personal Data

33r uses the personal data we collect for the following purposes:

• Account Creation and Management: To register, verify, and maintain your 33r account, including authenticating your identity at login and processing your account settings and preferences.
• Service Delivery: To provide you with access to the sports betting, casino, live dealer, and crash game features of the 33r platform, and to process your bets, deposits, withdrawals, and bonus claims.
• Age and Identity Verification: To confirm that you meet the minimum age requirement of 18 years and to verify your identity in accordance with our responsible gaming and AML obligations.
• Responsible Gaming: To monitor your account activity for indicators of problem gambling behaviour and to apply any deposit limits, loss limits, session restrictions, or self-exclusion measures you have set or that we are obligated to apply under our responsible gaming policies.
• Fraud Detection and Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other prohibited conduct through automated and manual monitoring of account activity.
• Customer Support: To respond to your queries, process complaints, and provide account assistance via [email protected].
• Platform Improvement: To analyse aggregated usage data, troubleshoot technical issues, and improve the functionality, layout, and performance of the 33r platform.
• Legal and Regulatory Compliance: To fulfil obligations arising from applicable laws, regulatory requirements, court orders, or lawful requests from government authorities.
• Marketing Communications: Where you have provided explicit consent, to send you promotional communications about bonuses, new games, PSL betting specials, and platform updates. You may withdraw consent to marketing communications at any time by contacting [email protected].

4. Legal Basis for Processing

33r processes your personal data on the following legal bases, depending on the specific purpose of processing:

• Contractual Necessity: Processing required to perform the contract between you and 33r, including operating your account, processing bets and transactions, and providing customer support.
• Legal Obligation: Processing required to comply with applicable legal obligations, including anti-money laundering verification, age verification, and responses to lawful government requests.
• Legitimate Interests: Processing carried out for 33r's legitimate business interests where those interests are not overridden by your rights and freedoms, including fraud detection, platform security, and analytics for service improvement.
• Consent: Processing based on your explicit prior consent, including marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

5. Cookies & Tracking Technologies

The 33r platform uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse usage patterns. A cookie is a small text file stored on your device by your web browser when you visit a website.

33r uses the following categories of cookies:

• Essential Cookies: Required for the platform to function correctly, including maintaining your login session and storing your account preferences. These cookies cannot be disabled without significantly impairing platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate the platform, which pages are visited most frequently, and where errors occur. This data is used exclusively to improve the 33r platform and is not linked to individual user identities.
• Functional Cookies: Used to remember your settings and preferences, such as your preferred language or game lobby view, to personalise your 33r experience.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from logging in or using core platform features. 33r does not use third-party advertising cookies or behavioural tracking cookies for the purpose of targeting advertisements on external websites.

6. Sharing Your Personal Data

33r does not sell, rent, or trade your personal data to any third party for marketing purposes. We share personal data with third parties only in the following circumstances:

• Payment Processors: We share transactional data necessary to process your deposits and withdrawals with our payment partners, including JazzCash, Easypaisa, and partner banks. These providers process data under their own privacy policies and are independently responsible for compliance with applicable data protection requirements.
• Game Content Providers: We share account session data (but not full identity information) with game providers such as Pragmatic Play, JILI, PG Soft, and Evolution as required to deliver their game content within the 33r platform. These providers are contractually bound to use such data only for the purpose of service delivery.
• Identity Verification Services: Where third-party KYC or AML screening services are used to verify your identity or screen your details against sanctions lists, we share the minimum data necessary to complete that verification.
• Legal and Regulatory Authorities: We will disclose personal data to government agencies, law enforcement bodies, regulators, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights, safety, or property of 33r or any third party.
• Business Succession: In the event of a merger, acquisition, restructuring, or sale of all or part of 33r's business, personal data held by 33r may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

7. Data Retention

33r retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention principles:

• Active Account Data: Retained for the full duration of your account with 33r.
• Transaction Records: Financial transaction records, including deposits and withdrawals, are retained for a minimum of five (5) years from the date of the transaction in accordance with AML and financial record-keeping obligations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years from account closure or the date of the last transaction, whichever is later.
• Support Communications: Records of support interactions are retained for a minimum of three (3) years from the date of the communication for quality assurance and dispute resolution purposes.
• Self-Exclusion Records: Where a self-exclusion request is made, we retain sufficient data to ensure that the exclusion remains effective and to prevent re-registration during the exclusion period, even after account closure.

When personal data is no longer required for any legitimate purpose and the applicable retention period has expired, it is securely deleted or anonymised.

8. Data Security

33r implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 33r platform;
• Cryptographic hashing with salt for all stored passwords – passwords are never stored in plain text;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Automated session expiry to protect accounts from unauthorised access following periods of inactivity;
• Regular security assessments and monitoring of the platform infrastructure;
• Contractual data protection obligations imposed on all third-party service providers who process personal data on 33r's behalf.

Despite these measures, no data transmission over the internet or storage system can be guaranteed as completely secure. If you have reason to believe that your 33r account has been compromised, please contact [email protected] immediately.

9. Your Privacy Rights

Subject to applicable law, you have the following rights in relation to the personal data that 33r holds about you:

• Right of Access: You may request a copy of the personal data 33r holds about you.
• Right to Rectification: You may request the correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal obligations (such as AML record-keeping requirements) that may require us to retain certain data.
• Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances, such as while a rectification request is under review.
• Right to Object: You may object to the processing of your personal data where that processing is based on legitimate interests. We will assess your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

To exercise any of these rights, please submit a written request to [email protected]. 33r will respond within a reasonable timeframe and in accordance with applicable law. We may require you to verify your identity before processing a data rights request.

10. Children's Privacy

The 33r platform is strictly for individuals aged 18 years and above. 33r does not knowingly collect, process, or retain personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered on the 33r platform or that 33r holds personal data relating to a minor, please contact us immediately at [email protected] with relevant details so that we can investigate and take appropriate action.

11. International Data Transfers

33r operates as an internationally hosted platform. As a result, your personal data may be processed or stored on servers located outside of Pakistan. Where personal data is transferred internationally, 33r takes steps to ensure that adequate protections are in place, including contractual data protection obligations with the relevant service providers and hosting partners.

By registering an account with 33r and using the platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions other than Pakistan. 33r will handle all such transfers in accordance with applicable data protection standards and the commitments set out in this Policy.

12. Updates to This Privacy Policy

33r reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or platform features. When material changes are made, 33r will update the "Last Updated" date at the top of this page. Where changes are significant, we may provide additional notice through a platform notification or email to your registered address.

Your continued use of the 33r platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you must cease using the platform and may request account closure in accordance with the Terms & Conditions.

13. Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 33r, please contact us using the details below:

• Email: [email protected]
• Response Language: English
• Response Time: Within 24 hours, 7 days a week

When submitting a privacy-related request, please include your registered 33r username and a clear description of your request or concern. For data rights requests (access, rectification, erasure, etc.), you will be required to verify your identity before we can process the request.

If you are not satisfied with 33r's response to a privacy complaint, you may have the right to escalate your complaint to the relevant data protection authority or regulatory body in your jurisdiction. 33r will cooperate fully with any such regulatory process.