Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 33dcom ("we", "us", "our", "the Operator"), the operator of the website located at https://33dcom.cam ("the Platform"), collects, processes, stores, uses and protects personal information relating to users ("you", "User") of the Platform.

33dcom is committed to handling personal data responsibly, transparently and in accordance with applicable data protection laws. This Policy is designed to give you a clear, honest account of our data practices so that you can make informed decisions about your use of the Platform.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy, which together form part of the overall agreement governing your use of 33dcom.

2. Definitions

The following definitions apply throughout this Privacy Policy:

3. Personal Data We Collect

We collect personal data in the following categories, depending on how you use the Platform:

3.1 Registration and Account Data

• Full legal name
• Date of birth (for age verification)
• Email address
• Username and hashed password credentials
• Country of residence and, where voluntarily provided, city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Contact telephone number
• Currency preference (e.g., PKR)

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., CNIC, passport)
• Proof of residential address (e.g., utility bill, bank statement)
• Source of funds documentation where required for AML compliance
• Selfie or liveness check images where required by our verification provider

3.3 Financial and Transaction Data

• Deposit and withdrawal amounts, dates and methods
• Payment method references (e.g., last four digits of a card, wallet account identifiers)
• Account balance history
• Wagering transaction records, including bet type, market, odds and outcome

3.4 Technical and Usage Data

• IP address and approximate geolocation derived from IP
• Device type, operating system and browser information
• Session duration and pages visited
• Click-stream and interaction data
• Cookie identifiers and similar tracking technologies

3.5 Communications Data

• Customer support chat transcripts and email correspondence
• Survey and feedback responses
• Complaint and dispute records

3.6 Responsible Gambling Data

• Self-exclusion requests and status
• Deposit, loss and session limit settings
• Cooling-off and break-from-play records

4. Legal Basis for Processing

We process your personal data under one or more of the following legal bases, depending on the nature of the processing activity:

5. How We Use Your Personal Data

33dcom uses personal data collected from Users for the following purposes:

• Account Services: Creating and managing your Account, processing transactions, applying bonus credits and communicating account status updates.
• Identity and Age Verification: Confirming that Users meet the minimum age requirement (18+ or higher as required) and verifying identity in accordance with KYC obligations.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, money laundering, account takeovers and other forms of abuse or platform manipulation.
• Regulatory Compliance: Meeting AML, responsible gambling and other regulatory obligations applicable to the Operator's licensing framework.
• Customer Support: Responding to enquiries, resolving complaints and providing technical assistance to registered Users.
• Product Improvement: Analysing aggregated usage data to improve Platform performance, user experience and content quality.
• Responsible Gambling: Monitoring wagering patterns to identify indicators of potential problem gambling and to apply limits or interventions where appropriate.
• Marketing Communications: Sending promotional offers and platform updates where you have provided consent and not subsequently opted out.

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

We share personal data with carefully selected third-party service providers who process data on our behalf as Data Processors. These include identity verification providers, payment processing intermediaries, fraud detection services, analytics platforms, customer support tools and cloud infrastructure providers. All third-party processors are bound by data processing agreements that restrict their use of your data to the purposes for which it was shared.

6.2 Legal and Regulatory Disclosure

We may disclose personal data to competent authorities, regulators, law enforcement agencies or courts where we are legally obliged to do so — for example, in response to a court order, regulatory request or legal investigation into fraud or financial crime. Such disclosures are made only to the extent required by applicable law.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of the Operator's business or assets, personal data held on the Platform may be transferred to a successor entity. Users will be notified of any such transfer and of any resulting changes to data controller status via this Policy or by direct communication.

6.4 No Sale of Personal Data

33dcom does not sell, rent, trade or otherwise commercially transfer your personal data to third parties for their own marketing or commercial purposes. This applies without exception.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Account Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, to satisfy regulatory record-keeping obligations.
• KYC and AML Records: Retained for a minimum period as required by the Operator's licensing obligations, typically five (5) years from the date of the last transaction or account activity.
• Transaction Records: Retained for a minimum of five (5) years to support financial auditing and regulatory compliance.
• Support Communications: Retained for a minimum of two (2) years from the date of the interaction, unless longer retention is required for dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of the consent and for a reasonable period thereafter as evidence of the consent given.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

8. Cookies and Tracking Technologies

The 33dcom Platform uses cookies and similar tracking technologies to operate core Platform functions, analyse usage patterns and, where consent has been given, deliver relevant content. The categories of cookies used are as follows:

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair Platform functionality. Consent-based cookies may be withdrawn at any time without affecting the lawfulness of prior processing.

9. Data Security

33dcom implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration or disclosure. Key security measures include:

• HTTPS/TLS encryption for all data transmitted between your browser and the Platform.
• Encryption of sensitive data fields at rest within our database infrastructure.
• Access controls restricting personal data to authorised personnel on a need-to-know basis.
• Regular security assessments and internal review processes.
• Incident response procedures for the detection, containment and reporting of data security events.

10. Your Data Rights

Subject to applicable data protection law, verification of your identity and any overriding legal obligations (such as AML record-keeping requirements), you hold the following rights in respect of your personal data:

To exercise any of the above rights, please contact us using the details in Section 14 of this Policy. We will respond within a reasonable timeframe and, in any event, within any period required by applicable law. Where a request cannot be fulfilled due to a legal obligation (such as AML record retention), we will explain the reason clearly.

11. International Data Transfers

As an internationally operated platform, 33dcom may transfer personal data to service providers located in countries outside your country of residence. Where such transfers occur, we take steps to ensure that adequate safeguards are in place — including contractual clauses, data processing agreements and, where applicable, transfers to countries recognised as providing an adequate level of data protection.

Users accessing the Platform from Pakistan should be aware that data may be processed outside Pakistan. Pakistan's Personal Data Protection Bill (and any enacted data protection legislation) may afford specific protections in relation to international transfers; users with concerns about cross-border data flows are encouraged to seek independent legal advice.

12. Minors and Age Verification

The 33dcom Platform is strictly for use by adults aged 18 years or older — or the higher minimum age required by the Operator's licensing jurisdiction. We do not knowingly collect personal data from individuals under the minimum age requirement.

Age verification is conducted as part of the account registration and KYC process. Where we have reason to believe that a User is under the required minimum age, the account will be immediately suspended, wagering activity will be cancelled, and any funds will be returned to the depositing payment method following verification, in accordance with our regulatory obligations.

If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

13. Amendments to This Policy

33dcom reserves the right to update or amend this Privacy Policy from time to time. Where changes are material — meaning they affect how your data is used in a way you may not reasonably expect based on the prior version — we will notify registered Users by email or by prominent notice on the Platform, with a minimum notice period of seven (7) days before changes take effect, except where immediate amendment is required by applicable law.

Your continued use of the Platform following the effective date of an amended Policy constitutes acceptance of the revised terms. We recommend reviewing this Policy periodically. The "Last Updated" date at the top of this document indicates when the most recent version was published.

14. Contact Us & Data Complaints

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by 33dcom, please contact our support team. We aim to respond to all data-related enquiries within ten (10) business days.

If you are dissatisfied with our response to a data-related complaint, you may have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction governing this Platform's operations. We will always direct you to the appropriate authority if asked.