3pati Privacy Policy

01 Who We Are

3pati is an internationally licensed online gaming platform operating at 3pati.club. We provide cricket betting, live dealer casino games, premium slots, sportsbook markets, and instant games to English-speaking players across Pakistan. For the purposes of this Privacy Policy, "3pati", "we", "us", and "our" refer to the operator of the 3pati platform.

3pati acts as the data controller in respect of personal data collected through the Platform. This means we determine the purposes for which your personal data is collected and the manner in which it is processed. Where we engage third-party service providers to process data on our behalf, those parties act as data processors under contractual obligations consistent with this Privacy Policy.

02 Data We Collect

3pati collects personal data in several categories depending on how you interact with the Platform. The categories of data we collect are as follows:

2.1 Registration Data

When you create a 3pati Account, we collect your full legal name, date of birth, email address, mobile number, and residential address. This information is required to open and maintain your Account and to verify that you meet the minimum age requirement of 21 years.

2.2 Identity Verification (KYC) Data

To comply with our obligations under our international gaming licence, we may collect copies of government-issued identity documents (such as your CNIC or passport), proof of address documentation, and proof of payment method ownership. KYC documents are processed in accordance with applicable anti-money laundering and know-your-customer regulations.

2.3 Financial Data

We collect transaction records associated with your Account, including deposit amounts, withdrawal requests, payment method identifiers (such as your JazzCash or EasyPaisa account reference), and bonus transaction history. We do not store full payment card numbers or full bank account numbers on our servers.

2.4 Gaming Activity Data

We record your gaming activity on the Platform, including game sessions, bet amounts, wagering history, cricket betting markets accessed, slots played, and live casino participation. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance purposes.

2.5 Technical & Device Data

When you access 3pati.club, we automatically collect certain technical data including your IP address, browser type and version, device type and operating system, referring URL, pages visited, session duration, and click-stream data. This data is collected through cookies and server logs.

2.6 Communications Data

If you contact our customer support team via live chat or email, we retain records of those communications including the content of messages, timestamps, and any attachments submitted as part of a support or dispute resolution process.

03 How We Use Your Data

3pati uses your personal data solely for the purposes described below. We do not use your data for any purpose that is incompatible with the original purpose for which it was collected without first obtaining your consent or identifying a separate legal basis.

• Account Management: Creating, maintaining, and administering your 3pati Account, including processing login authentication and account settings changes.
• Payment Processing: Facilitating deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT, and maintaining accurate transaction records in PKR.
• Identity Verification: Conducting KYC checks to confirm your identity, age (21+), and payment method ownership as required under our international gaming licence.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, account compromises, multi-accounting, bonus abuse, and money laundering on the Platform.
• Regulatory Compliance: Meeting our obligations under applicable anti-money laundering regulations, reporting requirements, and the terms of our international gaming licence.
• Responsible Gaming: Monitoring gaming patterns to identify potentially problematic behaviour, administering self-exclusion and deposit limit tools, and contacting you if concerns arise about your gaming activity.
• Customer Support: Responding to your queries, complaints, and requests submitted via live chat or email.
• Marketing (where consented): Sending promotional emails, bonus offers, and platform updates where you have opted in to marketing communications. You may withdraw this consent at any time.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform features, game selection, and user experience.

04 Legal Basis for Processing

3pati processes your personal data on the following legal grounds, depending on the specific processing activity involved:

• Contractual Necessity: Processing required to perform our contractual obligations to you as an Account holder — including account creation, payment processing, and game delivery — is carried out on the basis that it is necessary for the performance of our contract with you.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements — including KYC verification, AML reporting, and licence compliance — is carried out on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection, and internal analytics is carried out on the basis of 3pati's legitimate interests, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications is carried out on the basis of your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing carried out prior to withdrawal.

05 Cookies & Tracking Technologies

3pati uses cookies and similar tracking technologies on 3pati.club to deliver a functional, secure, and personalised experience. Cookies are small text files stored on your device when you visit our Platform.

5.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential to the operation of the Platform. These enable core functions such as session authentication, secure login persistence, and cashier functionality. These cookies cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised data on how visitors interact with 3pati.club, including page views, session duration, and navigation paths. This data helps us improve Platform performance and user experience.
• Functional Cookies: Store your preferences such as language settings and last-visited game categories, so the Platform remembers your choices between sessions.
• Marketing Cookies: Where you have consented to marketing, these cookies may be used to track the effectiveness of promotional campaigns and deliver relevant content. These are only activated upon your consent.

5.2 Managing Cookies

You may control or disable non-essential cookies through your browser settings. Please be aware that disabling certain cookies may affect the functionality of the Platform. For most browsers, cookie management settings are found under Privacy, Security, or Advanced settings menus.

06 Data Sharing

3pati does not sell, rent, or commercially exchange your personal data with any third party. We share your data only in the following limited and necessary circumstances:

• KYC & Identity Verification Partners: We share identity documents and registration data with licensed KYC verification service providers to fulfil our age verification and identity confirmation obligations under our gaming licence.
• Payment Processors: Transaction data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT processing partners to the extent required to complete your deposit or withdrawal request.
• Fraud Prevention & Security Services: We may share IP addresses, device fingerprints, and behavioural data with fraud detection partners to protect the integrity of the Platform and other players.
• Gaming Software Providers: Where you participate in games delivered by third-party software providers, limited session and wagering data may be shared with those providers to deliver the game service and settle outcomes.
• Regulatory & Law Enforcement Bodies: Where we are legally required to do so under applicable law, court order, or the terms of our international gaming licence, we may disclose your personal data to regulatory authorities or law enforcement agencies.
• Group Companies: We may share data with affiliated entities within the 3pati corporate group for internal administrative, compliance, and risk management purposes, subject to equivalent data protection obligations.

All third parties with whom 3pati shares personal data are required to process that data in accordance with applicable data protection standards and are prohibited from using it for any purpose beyond those specified in their contractual agreement with 3pati.

07 International Data Transfers

3pati operates under an international gaming licence and, as a result, your personal data may be transferred to and processed in countries outside of Pakistan. Where such transfers occur, 3pati takes steps to ensure that your data receives an adequate level of protection consistent with this Privacy Policy.

These steps may include relying on standard contractual clauses, adequacy decisions applicable to the destination country, or other legally recognised transfer mechanisms. If you have questions about the specific safeguards applied to any international transfer of your data, please contact us at [email protected].

08 Data Retention

3pati retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, subject to the following minimum retention periods:

• Active Account Data: Retained for the full duration that your Account remains open and active on the Platform.
• Post-Closure Retention: Following Account closure, your personal data is retained for a minimum period of five years to comply with our obligations under our international gaming licence and applicable anti-money laundering regulations.
• KYC & Identity Documents: Retained for a minimum of five years from the date of verification, or longer if required by applicable AML legislation.
• Transaction Records: Financial transaction records are retained for a minimum of seven years to satisfy accounting, tax, and regulatory audit requirements.
• Support Communications: Customer support chat logs and email correspondence are retained for three years from the date of the interaction, or longer if the communication relates to an unresolved dispute or regulatory matter.
• Marketing Preferences: Records of your marketing consent or opt-out are retained indefinitely to demonstrate compliance with your stated preferences.

When personal data is no longer required, it is securely deleted or anonymised in accordance with 3pati's internal data lifecycle procedures.

09 Your Rights

As a 3pati Platform user, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our support team via live chat or at [email protected]. We will respond to all verified requests within 30 days.

• Right of Access: You have the right to request confirmation of whether 3pati holds personal data about you, and to receive a copy of that data along with information about how it is being processed.
• Right to Rectification: You have the right to request that inaccurate or incomplete personal data held by 3pati be corrected or updated without undue delay.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing was unlawful. This right is subject to 3pati's legal obligations to retain certain data categories.
• Right to Restriction: You have the right to request that 3pati restricts the processing of your personal data in certain circumstances, such as while a dispute about data accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling, at any time. You also have an absolute right to object to processing of your data for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

10 Security Measures

3pati implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS Encryption: All data transmitted between your device and 3pati.club is encrypted in transit using industry-standard Transport Layer Security (TLS) protocols.
• Data Encryption at Rest: Sensitive personal data — including KYC documents and financial records — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within 3pati's systems is restricted to authorised personnel only, based on the principle of least privilege. Access is logged and regularly reviewed.
• Two-Factor Authentication: 3pati supports two-factor authentication for player Accounts and enforces multi-factor authentication for all administrative system access.
• Regular Security Audits: 3pati's Platform and infrastructure are subject to regular independent security audits and penetration testing by qualified third-party security specialists.
• Incident Response: 3pati maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and relevant regulatory authorities within the timeframes required under applicable law.

Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. While 3pati takes every reasonable precaution to protect your data, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your 3pati login credentials.

11 Children & Minors

The 3pati Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or store personal data belonging to individuals under the age of 21. The Platform incorporates age verification procedures at registration specifically to prevent underage access.

Parents and guardians are encouraged to make use of parental control tools available on devices and internet services to prevent access to online gaming platforms by minors. Further guidance on responsible gaming tools and protections for vulnerable users is available on our Responsible Gaming page.

12 Third-Party Links

The 3pati Platform may contain references to third-party game providers and services. Where you access any third-party service through the Platform, please be aware that those services operate under their own independent privacy policies. 3pati has no control over and accepts no responsibility for the privacy practices of third-party services, and this Privacy Policy does not apply to your interactions with those services.

We encourage you to review the privacy policy of any third-party service before providing personal data to that service. If you have concerns about a third-party provider's data practices in connection with games offered on the 3pati Platform, please contact us at [email protected] and we will investigate the matter.

13 Policy Updates

3pati reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the terms of our international gaming licence. When material changes are made, we will notify registered Account holders via email or a prominent in-Platform notice at least 7 days before the changes take effect, except where immediate implementation is required for legal or security reasons.

The effective date at the top of this page indicates when the current version of the Privacy Policy was last reviewed and updated. We encourage you to review this Policy periodically to stay informed about how 3pati protects your personal information. Continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms.

Previous versions of this Privacy Policy are available upon request by contacting 3pati customer support via live chat or at [email protected].

14 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how 3pati processes your personal data, please contact our team through the following channels:

• Live Chat: Available 24/7 directly within the Platform after 3pati login. This is the fastest way to reach our support team for urgent privacy matters.
• Email: [email protected] — please use the subject line "Privacy Policy Query" or "Data Privacy Request" so your message is routed to the appropriate team.

We aim to respond to all privacy-related enquiries within 5 business days and to complete all formal data rights requests within 30 days of identity verification. If you are not satisfied with our response to a privacy concern, you may escalate the matter to the applicable supervisory authority under 3pati's international gaming licence.