Privacy Policy — 3patty

3patty ("we", "us", "our") operates the online casino and sports betting platform accessible at https://3patty.org (the "Platform"). We are committed to protecting and respecting the privacy of all players and users who interact with our Platform, including players based in Pakistan and other markets we serve.

This Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By registering an account or using any feature of the 3patty Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree to this Privacy Policy, you must not use the Platform.

3patty collects personal data through several means, including data you provide directly during registration, data generated automatically through your use of the Platform, and data received from payment processors and identity verification partners. The categories of personal data we collect are as follows:

2.1 Registration & Account Data

• Full legal name as it appears on your CNIC, passport, or driving licence
• Date of birth (used to verify that you meet our strict 21+ age requirement)
• Residential address, including city (Karachi, Lahore, Islamabad, Faisalabad, or otherwise)
• Email address and mobile phone number
• Username and encrypted account password
• Account preferences and responsible gaming settings

2.2 Identity Verification (KYC) Data

• Copies of government-issued photographic identification (CNIC, passport, driving licence)
• Proof of address documentation (utility bill, bank statement dated within three months)
• Proof of payment method ownership (JazzCash, EasyPaisa, HBL, UBL, or Meezan Bank account screenshots)
• Source of funds documentation where transaction volumes require enhanced due diligence
• Facial verification images where liveness checks are required

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records in PKR
• Payment method identifiers (masked JazzCash/EasyPaisa numbers, bank account references)
• Wallet balance history and transaction timestamps
• Betting history, game session records, and win/loss data

2.4 Technical & Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session duration, pages visited, and feature interactions
• Referral source and marketing attribution data (where applicable)
• Error logs and technical diagnostic data

2.5 Communications Data

• Customer support chat logs, email correspondence, and ticket histories
• Feedback and survey responses
• Marketing preference records (opt-in/opt-out status)

3patty uses the personal data we collect for the following specific purposes:

• Account management: To create, maintain, and administer your player account, process your login, and manage your wallet and preferences.
• Identity and age verification: To verify that you are who you say you are and that you meet our 21+ age requirement before real-money gaming is enabled on your account.
• Payment processing: To facilitate PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to reconcile transaction records.
• Gaming and betting services: To operate casino games, live dealer tables, slot machines, and PSL cricket betting markets, and to settle bets accurately.
• Regulatory compliance: To comply with anti-money laundering (AML) obligations, gaming licence requirements, and international financial compliance standards applicable to our operations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeover attempts, bot activity, and other prohibited conduct.
• Responsible gaming: To monitor gaming patterns that may indicate problematic gambling behaviour and to apply the responsible gaming tools you have configured on your account.
• Customer support: To respond to your queries, resolve disputes, and process account closure or self-exclusion requests.
• Service improvement: To analyse usage patterns and improve the performance, stability, and feature set of the 3patty Platform.
• Marketing communications: To send you promotional offers and bonuses where you have given explicit consent to receive such communications. You may withdraw consent at any time.

3patty processes your personal data on the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing required to perform the contract between you and 3patty — including account creation, payment processing, game operation, and KYC verification — is carried out on the basis that it is necessary to deliver the services you have requested.
• Legal obligation: Processing necessary to comply with our AML obligations, gaming licence conditions, and international financial compliance requirements is carried out on the basis of legal obligation.
• Legitimate interests: Processing for fraud prevention, platform security, analytics, and service improvement is carried out on the basis of 3patty's legitimate interest in operating a secure and well-functioning platform, balanced against your privacy rights.
• Consent: Processing for direct marketing communications is carried out only where you have given explicit, informed consent. You may withdraw this consent at any time by updating your communication preferences in your account settings or by contacting [email protected].

3patty does not sell your personal data. We share your personal data only with the following categories of third-party recipients, and only to the extent necessary for the stated purpose:

5.1 Payment Processors

We share transaction data with JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank as required to process your PKR deposits and withdrawals. Each payment processor is subject to its own privacy policy and financial data protection obligations.

5.2 Identity Verification Providers

We use third-party KYC service providers to verify identity documents and, where applicable, conduct liveness checks. These providers process only the identity data necessary for verification and are contractually prohibited from using your data for any other purpose.

5.3 Game Content Providers

Third-party game studios whose content is available on 3patty (slots, live dealer tables, sports data feeds) receive only the session and stake data necessary to operate their games and return results. They do not receive your full account or identity data.

5.4 Regulatory & Law Enforcement Authorities

We may disclose personal data to regulatory bodies, gaming licence authorities, or law enforcement agencies where we are legally obligated to do so, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or other illegal activity.

5.5 Professional Advisors

We may share data with legal counsel, auditors, or compliance consultants under confidentiality obligations where required to obtain professional advice or to conduct audits of our operations.

3patty uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Required for the Platform to function correctly. These include session authentication cookies, wallet state cookies, and security tokens. They cannot be disabled without breaking core Platform functionality.
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits you have configured, and your preferred payment method to streamline your experience.
• Analytics cookies: Help us understand how players navigate the Platform, which features are most used, and where technical errors occur. This data is aggregated and anonymised where possible.
• Marketing cookies: Track whether you arrived at 3patty via a specific promotional campaign so that we can attribute registrations and deposits correctly. These are only placed with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling cookies beyond strictly necessary ones may affect the functionality of certain Platform features. A cookie preference centre is accessible from the footer of every page on the Platform.

3patty retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, subject to the overriding obligation to retain certain categories of data for the minimum periods required by applicable gaming licence conditions and financial compliance regulations.

As a general rule:

• Account and registration data is retained for the duration of your active account plus a minimum of five (5) years following account closure.
• KYC and identity verification documents are retained for the duration of your account plus a minimum of seven (7) years, in accordance with AML record-keeping requirements.
• Financial transaction records are retained for a minimum of seven (7) years from the date of each transaction.
• Technical and usage data (IP logs, session data) is retained on a rolling basis of up to thirteen (13) months.
• Customer support communications are retained for three (3) years from the date of the interaction, or longer where the communication relates to an unresolved dispute.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual player.

3patty takes the security of your personal data seriously. We have implemented the following technical and organisational measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure:

• TLS 1.2 or higher encryption for all data in transit between your device and our servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and payment identifiers
• Multi-factor authentication options for player accounts and mandatory MFA for all internal administrative access
• Role-based access controls ensuring that 3patty staff access only the data necessary for their specific job function
• Regular penetration testing and vulnerability scanning of the Platform infrastructure
• Intrusion detection systems monitoring for unusual access patterns or data exfiltration attempts
• Secure, geographically redundant data centre facilities with physical access controls

Subject to applicable law and any overriding retention obligations, you have the following rights in relation to your personal data held by 3patty:

• Right of access: You may request a copy of all personal data we hold about you. We will provide this within 14 business days of receiving a verified request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You can update many account details directly from your account settings dashboard.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been unlawfully processed. Note that this right is subject to our overriding legal obligation to retain certain data for minimum regulatory periods.
• Right to restrict processing: You may request that we restrict processing of your data in certain circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to data portability: Where processing is based on your consent or on a contract, you may request that we provide your personal data in a structured, machine-readable format.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including profiling. You may also object to direct marketing at any time, and we will cease that processing immediately.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

To exercise any of these rights, please contact our data team at [email protected] with the subject line "Data Rights Request" and we will respond within 14 business days. We may ask you to verify your identity before processing the request.

The 3patty Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from any person under the age of 21. Age verification is a mandatory step in the registration process and is enforced again at the point of first withdrawal.

If we discover or have reason to believe that a person under the age of 21 has provided personal data to us and created an account, we will take the following immediate steps:

• Suspend the account with immediate effect
• Delete all personal data associated with the underage account from our active systems
• Return any deposited funds to the originating payment method after deducting any amounts already withdrawn
• Retain a minimum record of the incident as required for regulatory compliance and to prevent re-registration

The 3patty Platform integrates third-party services including payment gateways, game content providers, and analytics tools. Each of these third parties operates under its own privacy policy. 3patty is not responsible for the privacy practices of third-party services beyond the contractual data processing agreements we maintain with them.

The 3patty website does not contain external links to third-party websites beyond those integral to Platform functionality. If you navigate to any external site from your browser independently of 3patty, this Privacy Policy does not apply to data collected by those external sites.

3patty is operated under an international gaming licence, and certain aspects of our infrastructure, including server hosting, KYC processing, and game content delivery, may involve the transfer of personal data to jurisdictions outside Pakistan.

Where such transfers occur, 3patty ensures that appropriate safeguards are in place to protect your data, including:

• Data processing agreements with standard contractual clauses obligating receiving parties to maintain equivalent data protection standards
• Transfer only to jurisdictions or entities that provide an adequate level of data protection as determined by our compliance assessment
• Encryption of all data in transit regardless of the jurisdiction to which it is transferred

3patty reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes to this Policy, we will notify registered players via email to their registered address and display a prominent notice on the Platform for a minimum of 14 days following the change.

The "Last Updated" date displayed at the top of this page reflects the date of the most recent revision. We encourage you to review this Privacy Policy periodically. Your continued use of the Platform following notification of any update constitutes your acceptance of the revised Policy.

If a proposed update would represent a material reduction in your privacy protections, we will provide a minimum of 30 days' advance notice and allow you to close your account and withdraw your real money balance before the changes take effect.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 3patty processes your personal data, please contact us using the details below. All privacy-related correspondence will be handled by our data protection team.

• Data Rights & Privacy Queries: [email protected] — Subject line: "Privacy Policy Query"
• General & Legal Inquiries: [email protected] — Subject line: "Data Protection"

We aim to acknowledge all privacy-related correspondence within 2 business days and to resolve requests within 14 business days of receipt of all relevant information. For complex data rights requests requiring identity verification, we will notify you of any necessary extension to this timeline.