33dd Privacy Policy

33dd ("we", "us", "our", "the Company") is committed to protecting and respecting the privacy of all users who register for, access, or otherwise interact with the 33dd platform. This Privacy Policy has been prepared to meet our obligations under applicable data protection legislation and the requirements of our international gaming licence, which mandates transparent data handling practices as a condition of continued operation.

As a Pakistani player using 33dd, you share certain personal and financial information with us in the course of creating an account, making deposits via JazzCash or other payment methods, placing bets, and communicating with our support team. This Policy sets out exactly what happens to that information — from the moment it is collected to the point at which it is deleted from our systems.

If at any point you have questions about how 33dd handles your personal data, or you wish to exercise any of the rights described in Section 11 of this Policy, you may contact us at the details provided in Section 16. We respond to all privacy-related queries within 30 calendar days of receipt.

For the purposes of this Privacy Policy, the data controller responsible for the processing of your personal information is the licensed operator of the 33dd platform. 33dd operates under an international gaming licence which mandates compliance with recognised data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

Enquiries regarding this Privacy Policy or requests to exercise your data subject rights should be directed to the 33dd Data Protection contact as specified in Section 16. All such communications will be handled with full confidentiality and in accordance with the timeframes stipulated by applicable law.

33dd collects the minimum personal data necessary to provide you with a safe, compliant, and functional gaming experience. The categories of personal data we may collect include:

3.1 Identity Data

• Full legal name as it appears on your CNIC or passport;
• Date of birth (used for mandatory 21+ age verification);
• CNIC number or passport number (provided during KYC verification);
• Copies of identity documents submitted for Know Your Customer (KYC) compliance.

3.2 Contact Data

• Pakistani mobile phone number (used for account verification and SMS-based two-factor authentication);
• Email address (where provided, used for account communications and promotional messaging);
• City of residence in Pakistan (e.g., Karachi, Lahore, Faisalabad, Islamabad — used for support localisation and fraud risk profiling).

3.3 Financial Data

• JazzCash mobile number or wallet identifier (for deposit and withdrawal processing);
• EasyPaisa account reference (where used as a payment method);
• Bank account name and partial account number for bank transfer verification (HBL, UBL, Allied Bank, Meezan Bank);
• Cryptocurrency wallet address (USDT TRC20, where used);
• Transaction history: deposit amounts, withdrawal requests, dates, and statuses;
• Account balance history in PKR.

3.4 Gameplay & Behavioural Data

• Game play history including titles played, bet amounts, outcomes, and session durations;
• Sports betting records including markets wagered, selections, odds accepted, and settlement outcomes;
• Active and expired bonus usage and wagering requirement completion data;
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion status).

3.5 Technical Data

• IP address at login and at time of each transaction;
• Device type, operating system, and browser version;
• Session timestamps and navigation logs within the 33dd platform;
• Cookie identifiers and associated tracking data (see Section 8).

33dd collects personal data through the following channels:

• Direct Registration: Information you provide when creating your 33dd account, including your name, mobile number, and date of birth;
• KYC Submission: Documents and information you upload during the identity verification process, including CNIC copies and proof of address;
• Payment Transactions: Data exchanged between 33dd and our payment processors (JazzCash, EasyPaisa, banking partners) during deposit and withdrawal processing;
• Platform Usage: Automatically collected data generated as you navigate and interact with the 33dd platform — game play records, betting activity, login events;
• Support Interactions: Records of live chat conversations, emails, and other support communications between you and the 33dd support team;
• Cookies and Analytics: Data collected via cookies, session storage, and analytics tools as described in Section 8;
• Third-Party Verification Services: Identity verification and fraud screening data received from our KYC service providers in the course of processing your account verification.

The personal data 33dd collects is used exclusively for the following purposes:

33dd does not use your personal data for automated decision-making that produces significant legal effects without human review. Responsible gaming alerts generated by automated monitoring are reviewed by trained 33dd support staff before any account-level action is taken.

33dd processes your personal data on the following legal grounds, which are recognised under internationally accepted data protection frameworks:

• Contract Performance: Processing that is necessary to provide the 33dd gaming and payment services you have requested by creating an account — including deposits, withdrawals, and game access;
• Legal Obligation: Processing required to comply with 33dd's obligations under its international gaming licence — including KYC, anti-money laundering (AML) checks, and regulatory reporting;
• Legitimate Interest: Processing that serves 33dd's legitimate interests and does not override your fundamental privacy rights — including fraud prevention, platform security monitoring, and responsible gaming analysis;
• Consent: Processing for purposes that are not strictly necessary for contract delivery or legal compliance — primarily direct marketing communications. You may withdraw your consent at any time by contacting 33dd support.

33dd does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the specific, limited circumstances described below:

7.1 Payment Processors

To facilitate deposits and withdrawals, 33dd shares the minimum necessary financial and identity data with our regulated payment processing partners — including JazzCash, EasyPaisa, and our banking partners (HBL, UBL, Allied Bank, Meezan Bank, SadaPay). These processors are bound by their own data protection obligations and use your data solely for transaction processing.

7.2 KYC and Identity Verification Providers

To comply with our legal obligation to verify player identity and age, 33dd engages regulated third-party KYC verification services. Your identity documents and personal data submitted during verification may be shared with these providers solely for verification purposes. All KYC partners are contractually bound to data protection standards consistent with this Policy.

7.3 Regulatory and Law Enforcement Authorities

33dd may disclose personal data to competent regulatory authorities, law enforcement agencies, or other governmental bodies where we are legally required to do so — including under the terms of our gaming licence, anti-money laundering regulations, or a valid court order or statutory demand. We will notify affected Players of such disclosure where we are legally permitted to do so.

7.4 Responsible Gaming Service Providers

Where you initiate a self-exclusion request at 33dd, limited identity data (name, mobile number, date of birth) may be shared with responsible gaming exclusion registries to prevent re-registration on the 33dd platform and, where applicable, on partner platforms that participate in shared exclusion schemes.

7.5 Professional Advisors

33dd's legal counsel, auditors, and compliance consultants may access personal data in the course of providing professional services. All such advisors are bound by professional duties of confidentiality.

The 33dd platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure user experience. A cookie is a small text file stored on your device by your browser when you visit a website. 33dd uses the following categories of cookies:

8.1 Strictly Necessary Cookies

These cookies are essential for the operation of the 33dd platform. They maintain your login session, preserve your account preferences, enable secure page navigation, and support the functioning of the payment interface. These cookies cannot be disabled without significantly impairing platform functionality.

8.2 Functional Cookies

Functional cookies allow 33dd to remember your language preference, device type, and customisation settings so that you receive a consistent experience each time you log into your 33dd account — particularly relevant for Pakistani players who may switch between mobile data and WiFi connections during extended gaming sessions.

8.3 Analytical Cookies

33dd uses privacy-respecting analytics tools to understand aggregate patterns in platform usage — such as which game categories are most popular among Pakistani players and which sections of the platform generate the most support enquiries. This data is anonymised and used solely to improve the 33dd product. Individual players are not identified in analytical reporting.

8.4 Managing Cookies

You can control cookie settings through your browser's privacy or settings menu. Disabling certain categories of cookies may affect your 33dd experience — in particular, disabling session cookies will prevent you from staying logged into your account across pages. Instructions for managing cookies are available in your browser's help documentation.

33dd implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and 33dd servers is encrypted using industry-standard SSL/TLS protocols. The same standard applied by Pakistan's major commercial banks for online banking portals;
• Encrypted Data Storage: Sensitive data fields — including identity document copies, payment method references, and KYC records — are stored using encryption at rest;
• Access Controls: Access to personal data within 33dd's systems is restricted on a need-to-know basis. Team members can only access the data necessary for their specific role — support agents see account and transaction data; they cannot access raw KYC documents unless handling a verification request;
• Two-Factor Authentication: 33dd offers SMS-based two-factor authentication for Player account login. We strongly recommend all 33dd account holders enable this feature to protect their account from unauthorised access;
• Regular Security Assessments: 33dd's technical infrastructure undergoes periodic independent security assessments to identify and remediate vulnerabilities;
• Incident Response: 33dd maintains a documented data breach response plan. In the event of a security incident that may affect Player data, we will notify affected Players and relevant authorities within the timeframes required by applicable law.

While 33dd takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. Players should also take responsibility for their own account security — use a strong, unique password for your 33dd account, enable two-factor authentication, and never share your login credentials with others.

33dd retains personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods which are driven by our regulatory obligations:

• Account Data and KYC Records: Retained for a minimum of five (5) years following account closure, as required by our gaming licence anti-money laundering conditions;
• Financial Transaction Records: Retained for a minimum of seven (7) years following the date of the transaction, in accordance with financial record-keeping requirements;
• Gameplay and Betting Records: Retained for a minimum of five (5) years following the relevant session or wager, to support dispute resolution and regulatory audit;
• Support Communication Records: Retained for three (3) years following the closure of the relevant support ticket;
• Marketing Consent Records: Retained for the duration of active consent plus three (3) years following withdrawal of consent, to demonstrate compliance with consent obligations;
• Self-Exclusion Records: Retained for the full duration of the exclusion period plus five (5) years following expiry, to prevent circumvention of responsible gaming measures.

When retention periods expire and there is no other legal basis requiring continued storage, 33dd will securely delete or irreversibly anonymise the relevant personal data.

As a registered 33dd user, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us as described in Section 16. We will respond within 30 calendar days:

The 33dd platform is strictly intended for adults aged 21 years and over. 33dd does not knowingly collect personal data from any person under the age of 21. If 33dd becomes aware that personal data has been collected from an individual who does not meet our minimum age requirement, we will take immediate steps to delete that data and close the associated account.

Age verification is a mandatory step in the 33dd KYC process. All players are required to provide proof of age before withdrawal access is granted, and 33dd reserves the right to request age verification at any point during the account lifecycle. If you believe that a person under 21 has registered a 33dd account, please notify us immediately at the contact details in Section 16.

As an internationally licensed online gaming operator, 33dd may transfer your personal data to servers or third-party service providers located in jurisdictions outside Pakistan. Where such transfers occur, 33dd takes appropriate steps to ensure that your data receives a level of protection consistent with the principles set out in this Privacy Policy.

These steps may include: implementing contractual clauses that bind the recipient to equivalent data protection standards; transferring data only to jurisdictions that maintain recognised adequacy frameworks; and conducting due diligence on third-party recipients to verify their data security practices prior to engagement.

Key categories of international transfers at 33dd include: payment processing data transmitted to our banking and mobile money partners' infrastructure; KYC verification data processed by our third-party identity verification service; and analytics data processed on cloud infrastructure that may operate across multiple geographic regions.

The 33dd platform may contain references to third-party services — such as game providers, payment processors, or responsible gaming organisations. While 33dd takes care in selecting reputable partners, once you navigate away from the 33dd platform to a third-party service, this Privacy Policy no longer applies. The privacy practices of third-party services are governed by their own respective privacy policies, which 33dd has no control over.

Players are encouraged to review the privacy policies of any third-party services they engage with in connection with their 33dd account — including their JazzCash and EasyPaisa accounts, which process transaction data under Jazz's and Telenor's own privacy frameworks respectively.

33dd reviews this Privacy Policy on a quarterly basis and updates it as necessary to reflect changes in our data processing practices, regulatory requirements, or applicable laws. The effective date and version number shown at the top of this document will be updated each time a material change is made.

Where we make material changes to this Privacy Policy — particularly changes that may affect your rights or the way we use your data — we will provide advance notice through the 33dd platform and, where we hold your email address, via direct communication. The updated Policy will take effect 14 days following such notification, unless a shorter notice period is required by legal obligation.

Continued use of the 33dd platform after the effective date of any updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with any changes, you have the right to close your 33dd account and request deletion of your data where retention obligations permit.

For all privacy-related enquiries, requests to exercise your data subject rights, or concerns regarding 33dd's handling of your personal information, please contact our Data Protection team using the following details:

If you are unsatisfied with 33dd's response to a privacy concern, you have the right to escalate the matter to 33dd's licensing authority's consumer complaints division, details of which are provided in the 33dd Terms & Conditions.