Privacy Policy — 3patty Platform

This Privacy Policy ("Policy") sets out how 3patty ("we", "us", "our", "the Platform"), operating the online gaming information and navigation platform accessible at https://3patty.cam, collects, uses, stores, shares and protects the personal data of individuals ("Users", "you") who access or use the Platform.

3patty is an English-language online gaming information and navigation platform serving Pakistani users. We are committed to handling all personal data with care, transparency and respect for applicable data protection principles. We do not claim any affiliation with Pakistani financial institutions, the State Bank of Pakistan (SBP), the Pakistan Telecommunication Authority (PTA) or any other government body of Pakistan.

By accessing or using 3patty, you acknowledge that you have read, understood and accepted the data practices described in this Policy. If you do not agree with any aspect of this Policy, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information that identifies or could reasonably identify a living individual, directly or in combination with other data.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" means 3patty, the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party that processes personal data on behalf of 3patty under a contractual obligation and subject to our instructions.
• "User" means any individual who accesses, registers on or uses the Platform, including visitors who have not created an Account.
• "Account" means a registered user profile created on the Platform.
• "KYC" means Know Your Customer — identity and age verification procedures.
• "AML" means Anti-Money Laundering — compliance procedures relating to financial crime prevention.
• "Cookies" means small text files placed on a user's device by a web browser for the purpose of storing session or preference data.
• "Sensitive Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, health data, biometric or financial data, which is subject to heightened protection.

We collect personal data from Users through various means, including directly from you during registration and account use, automatically through your interaction with the Platform, and from third parties such as payment processors and KYC verification providers.

3.1 Data Provided by You

• Full legal name and date of birth (for identity and age verification)
• Email address and contact number
• City and country of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Government-issued identification documents (CNIC, passport, driving licence) submitted for KYC purposes
• Payment information — including payment method identifiers provided during deposit or withdrawal transactions
• Communications sent to us via support channels, including emails and chat transcripts
• Responsible gambling self-declarations, including self-exclusion requests and limit preferences

3.2 Data Collected Automatically

• IP address and approximate geographic location derived therefrom
• Device type, operating system, browser version and screen resolution
• Session data: pages visited, time on site, click-through paths and referral URLs
• Cookie and similar tracking technology data (see Section 9)
• Transaction history: deposit amounts, withdrawal requests, bonus claims and wagering records
• Login timestamps and account activity logs for security and fraud prevention purposes

3.3 Data from Third Parties

We may receive personal data about you from third parties in limited circumstances, including:

• KYC/AML verification providers who validate the identity documents you submit
• Payment processors who confirm transaction completion (note: full card or account numbers are not stored by 3patty)
• Fraud detection and risk assessment services
• Regulatory bodies or law enforcement agencies, where legally required

3patty processes your personal data only where a legitimate legal basis exists. The primary legal bases on which we rely are:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under our Terms & Conditions, including account registration, payment processing and service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements, tax reporting obligations and responses to regulatory enquiries or court orders.
• Legitimate Interests: Processing that is necessary for 3patty's legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring and service improvement, where those interests are not overridden by your fundamental rights.
• Consent: Where you have provided explicit consent to specific processing activities — such as receiving marketing communications or allowing the use of non-essential cookies — we will process data on that basis. You may withdraw consent at any time without affecting the lawfulness of prior processing.

We use the personal data we collect for the following specific and limited purposes:

5.1 Account Management

To create, maintain and administer your user Account on 3patty, including processing registrations, managing profile updates, verifying your identity for security purposes and responding to account-related queries.

5.2 Payment Processing

To facilitate deposits and withdrawals through payment methods available in the Platform cashier. Transaction data is shared with payment processors strictly for the purpose of executing the requested financial transaction. Payment method references familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are noted for contextual familiarity; these providers operate under their own independent privacy frameworks.

5.3 KYC and AML Compliance

To verify your identity and age before processing withdrawals and as required by anti-money laundering obligations. KYC data is processed by authorised verification partners subject to strict confidentiality obligations and is not used for any other purpose.

5.4 Fraud Prevention and Security

To detect, investigate and prevent fraudulent activity, account takeovers, multiple account abuse and any other prohibited conduct as defined in our Terms & Conditions. Security logs and device data are retained for this purpose within defined retention periods.

5.5 Responsible Gambling Monitoring

To operate responsible gambling tools, including deposit limits, loss limits, session time limits and self-exclusion functionality. Usage and behavioural data may be analysed to identify patterns that may indicate problem gambling, enabling us to proactively contact at-risk users or enforce protective restrictions. Please see our Responsible Gambling page for full details.

5.6 Platform Improvement and Analytics

To understand how Users interact with the Platform, identify areas for improvement, test new features and measure the effectiveness of content. Where analytics tools are used, data is processed in an aggregated or pseudonymised form wherever practicable.

5.7 Marketing Communications (Consent-Based)

Where you have explicitly opted in to receive marketing communications, we may contact you with relevant promotional offers, bonus updates and platform news. You may opt out of marketing communications at any time by contacting support or using an unsubscribe mechanism where provided.

3patty does not sell, rent or trade your personal data to third parties. We share personal data only in the specific circumstances described below:

6.1 Service Providers (Data Processors)

We engage third-party service providers who process personal data on our behalf under contractual obligations that require them to protect your data and use it only for the purposes we specify. Categories of data processors include:

• KYC and identity verification providers
• Payment processing platforms and gateway operators
• Cloud hosting and data storage providers
• Fraud detection and risk management services
• Customer support software providers
• Platform analytics and performance monitoring tools

6.2 Legal and Regulatory Disclosure

We may disclose personal data to regulatory authorities, law enforcement agencies, courts or other government bodies where we are legally required to do so, or where we believe disclosure is necessary to: (a) comply with a legal obligation; (b) protect the rights, property or safety of 3patty, its users or the public; or (c) detect, prevent or address fraud, security vulnerabilities or technical issues.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of 3patty's business, personal data held by the Platform may be transferred to the successor entity as part of that transaction, subject to equivalent data protection obligations. Users will be notified of any material change in data ownership.

As an online platform, 3patty may store or process personal data on servers located outside Pakistan. Where personal data is transferred to a country that does not provide an equivalent level of data protection, we apply appropriate safeguards to ensure your data remains protected. These safeguards may include standard contractual clauses, binding corporate rules or other mechanisms recognised under applicable data protection frameworks.

By using 3patty, you acknowledge that your personal data may be transferred to and processed in countries outside Pakistan. We take reasonable steps to ensure that such transfers are conducted securely and in accordance with the principles set out in this Policy.

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

• Account Data: Retained for the duration of your Account's active status and for a defined period after closure, typically no less than five years, to comply with AML and regulatory record-keeping requirements.
• KYC Documents: Retained in accordance with applicable AML retention obligations, generally for a minimum of five years following the end of the business relationship.
• Transaction Records: Retained for a minimum of five years from the date of the transaction for financial compliance purposes.
• Support Communications: Retained for the duration of the Account relationship and for a reasonable period thereafter for dispute resolution and quality assurance purposes.
• Technical and Log Data: Retained for shorter periods, typically 12 to 24 months, sufficient for security and fraud prevention purposes.
• Marketing Consent Records: Retained until consent is withdrawn 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 a manner that prevents its recovery.

3patty uses cookies and similar technologies (including web beacons and local storage) to operate, improve and secure the Platform. Cookies are small text files stored on your device by your web browser when you visit a website. They do not contain executable code and cannot be used to access files on your device.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies, security tokens and responsible gambling tool cookies. They cannot be disabled without affecting your ability to use the Platform.
• Functional Cookies: Remember your preferences such as language settings, display preferences and last-visited sections to personalise your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how users navigate the Platform, helping us identify performance issues and improve content. Where third-party analytics tools are used, personal identifiers are not shared with those providers where avoidable.
• Marketing Cookies: Used only where you have provided explicit consent to receive targeted promotional content. You may withdraw consent for marketing cookies at any time.

9.2 Managing Cookies

You can manage and delete cookies through your browser settings. Most modern browsers allow you to: (a) block all cookies; (b) accept only first-party cookies; or (c) delete existing cookies. Please note that disabling strictly necessary cookies may impair the functionality of the Platform. Instructions for managing cookies are available in the help section of your browser.

3patty applies appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers
• Encryption of sensitive stored data, including KYC documents and financial records
• Strict access controls limiting personal data access to authorised personnel on a need-to-know basis
• Regular security assessments and vulnerability testing of platform infrastructure
• Two-factor authentication options for user accounts to reduce the risk of unauthorised access
• Incident response procedures for detecting, reporting and managing personal data breaches

The 3patty Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's licence jurisdiction. We do not knowingly collect, store or process personal data from persons under the minimum age requirement.

If we become aware that personal data has been collected from a person below the minimum eligible age, we will take immediate steps to delete that data and close the associated Account. Any funds associated with an underage Account will be handled in accordance with our Terms & Conditions.

If you believe a minor has provided us with personal data, please contact us immediately at [email protected] so that we may take appropriate action.

The 3patty Platform may contain references or contextual mentions of third-party services — including payment method names such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — that are referenced for user familiarity only. These providers operate under their own independent privacy policies and terms of service, over which 3patty has no control.

We do not accept responsibility for the privacy practices, data handling or content of any third-party service. We encourage you to review the privacy policy of any payment provider or third-party service you interact with independently of the 3patty Platform.

To exercise any of the data rights described in this Policy — including rights of access, rectification, erasure, restriction, portability or objection — please submit a written request to our support team:

• Contact us at [email protected] with the subject line "Data Rights Request"
• Include your registered full name and email address to enable identity verification
• Specify clearly the right you wish to exercise and the data to which it relates

We will acknowledge receipt of your request promptly and aim to fulfil verified requests within 30 days. Complex or high-volume requests may require additional time, in which case we will notify you of the expected timeline.

Please note that certain data rights may be subject to limitations where processing is required by legal obligation (for example, AML record-keeping requirements) or where restriction would impair our ability to detect fraud or protect other users.

If you are dissatisfied with our response to a data rights request, you may have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction.

3patty reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable law or platform functionality. Where amendments are material, we will notify registered Users by email to the address on file or through an in-platform notification prior to the changes taking effect.

Non-material clarifications or administrative updates may be made without prior individual notification. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision.

Your continued use of the Platform following the effective date of any amendments to this Policy constitutes acceptance of the revised terms. If you do not agree with the amended Policy, you must cease using the Platform and may request account closure.

The current version of this Privacy Policy is always accessible at https://3patty.cam/privacy-policy.

For all privacy-related enquiries, data rights requests or concerns regarding our data handling practices, please contact the 3patty privacy team through the following channel: