This Privacy Policy ("Policy") describes how 33rs ("we", "us", "our"), the operator of the platform accessible at https://33rs.cam, collects, uses, stores, discloses and safeguards personal data provided by or collected about you ("User", "you", "your") in connection with your use of the 33rs platform ("Platform").
By creating an Account on 33rs or by continuing to access the Platform, you acknowledge that you have read and understood this Policy and that you consent to the data practices described herein. If you do not agree to this Policy, you must not use the Platform.
This Policy forms part of, and should be read alongside, our Terms & Conditions. Where this Policy conflicts with the Terms, the more specific provision shall prevail in relation to data matters.
For the purposes of this Privacy Policy, the following terms carry the meanings set out below:
33rs collects Personal Data through several channels. The categories of data we collect are as follows:
3.1 Registration Data. When you create an Account on 33rs, we collect:
- Full name and date of birth
- Email address and chosen username
- Residential address (including city and country)
- Phone number (where provided)
- Password (stored in hashed and salted form — never in plain text)
3.2 Identity Verification (KYC) Data. To comply with anti-money-laundering regulations and to verify your age and identity, we may collect:
- Government-issued photo identification (such as a national identity card, passport or driving licence)
- Proof of residential address (such as a utility bill or bank statement)
- Proof of payment method ownership
- Selfie or facial verification data where required by the operator
3.3 Financial Transaction Data. When you make deposits or withdrawal requests, we collect:
- Payment method identifiers (account number endings, wallet IDs)
- Transaction amounts in PKR or other applicable currencies
- Transaction timestamps and reference numbers
Full payment instrument credentials (card numbers, full bank account details) are processed by payment service providers and are not stored by 33rs directly. References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah reflect commonly used payment methods in Pakistan. Their mention here does not imply endorsement or affiliation with gambling activities.
3.4 Gameplay and Activity Data. During your use of the Platform, we automatically collect:
- Betting and gaming history including stake amounts, markets accessed and outcomes
- Session durations and login timestamps
- Responsible gambling tool settings (deposit limits, self-exclusion status, session reminders)
3.5 Technical and Device Data. We collect technical data to operate and secure the Platform:
- IP address and approximate geolocation
- Device type, operating system and browser version
- Unique device identifiers
- Referring URLs and pages viewed on the Platform
3.6 Communications Data. If you contact support by email or live chat, we retain records of those communications to resolve your query and for quality and compliance purposes.
We process your Personal Data for the following purposes:
Where applicable data protection law requires us to identify a legal basis for each processing activity, 33rs relies on the following grounds:
- Contractual necessity: Processing required to deliver the Platform services you have registered for, including account creation, transaction processing and responsible gambling tool operation.
- Legal obligation: Processing required to comply with applicable laws, including KYC/AML requirements, age verification and record-keeping mandates under the operator's licensing obligations.
- Legitimate interests: Processing carried out for fraud prevention, platform security, abuse detection and aggregate analytics — where those interests do not override your fundamental rights.
- Consent: Where we rely on your consent for specific processing activities (such as non-essential cookies or marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
33rs does not sell your Personal Data. We may share data with third parties only in the following circumstances and to the minimum extent necessary:
- Payment service providers: To process deposits and withdrawals through applicable payment methods. Each provider operates under its own privacy and security obligations.
- Identity verification (KYC) providers: To carry out age and identity verification checks required by applicable regulation.
- IT and infrastructure providers: Hosting, cloud storage, content delivery and platform support services that process data on our behalf under contractual data-processing agreements.
- Analytics and security providers: For fraud detection, abuse monitoring and aggregate platform performance analysis. These providers do not receive data for their own commercial purposes.
- Legal and regulatory authorities: Where required by applicable law, court order, regulatory request or to protect the rights and safety of 33rs, its users or third parties.
- Business transfers: In the event of a merger, acquisition or sale of platform assets, your data may be transferred to a successor entity, subject to equivalent privacy protections.
We retain Personal Data for as long as is necessary to fulfil the purposes described in this Policy or to comply with applicable legal retention obligations. Our general retention approach is as follows:
- Active account data: Retained for the duration of your Account and for a period following closure as required by applicable law and compliance obligations.
- Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction to satisfy AML and accounting requirements, or longer where mandated by the applicable licensing jurisdiction.
- KYC documentation: Retained for the period required by applicable anti-money-laundering regulations, typically five (5) years from the end of the business relationship.
- Support communications: Retained for up to three (3) years from the date of the last interaction, unless retention is required for ongoing dispute resolution or legal proceedings.
- Technical and analytics data: Aggregated or anonymised and may be retained indefinitely; individually identifiable technical logs are retained for a shorter period sufficient for security and fraud investigation purposes.
When Personal Data is no longer required, it is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.
33rs implements technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration, loss or destruction. These measures include, but are not limited to:
- SSL/TLS encryption for all data transmitted between your device and the Platform.
- Password hashing using industry-standard algorithms — your password is never stored in plain text.
- Access controls limiting internal access to Personal Data to personnel with a legitimate operational need.
- Intrusion detection systems monitoring for unusual access patterns and potential security incidents.
- Regular security assessments of the Platform infrastructure and data handling processes.
- Incident response procedures for identifying, containing and reporting data breaches in accordance with applicable obligations.
While 33rs applies robust security controls, no online platform can guarantee absolute security. You are responsible for keeping your Account credentials confidential and for notifying us promptly if you suspect any unauthorised access to your Account.
33rs uses cookies and similar tracking technologies to operate the Platform and improve user experience. The categories of cookies we use are as follows:
You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent the Platform from functioning correctly. For analytics and non-essential cookies, you may withdraw consent at any time through your browser settings, which will not affect the lawfulness of prior processing.
Subject to applicable law and the operator's licensing obligations, you have the following rights in respect of your Personal Data held by 33rs. To exercise any of these rights, contact us using the details in Section 14.
You may request a copy of the Personal Data we hold about you and information about how it is processed. We will respond within a reasonable timeframe as required by applicable law.
If any Personal Data we hold about you is inaccurate or incomplete, you may request that we correct it. You can also update certain information directly through your Account settings.
You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected. This right is subject to overriding legal obligations such as AML record-keeping requirements, which may require us to retain certain data.
In certain circumstances, you may request that we restrict active processing of your Personal Data, for example while you dispute its accuracy or object to its use.
Where processing is based on consent or contractual necessity, you may request your Personal Data in a structured, machine-readable format to transfer to another service provider.
You may object to processing based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms.
Where we rely on your consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
The 33rs Platform is strictly for adults. Access is limited to users aged 18 years or older, or the higher minimum age required by the applicable license jurisdiction. We do not knowingly collect or process Personal Data relating to individuals under the age of 18.
If we become aware that Personal Data has been submitted by or collected about a minor, we will take immediate steps to delete that data and close the associated Account. Any funds held in such an Account will be handled in accordance with our Terms & Conditions and applicable law.
If you believe a minor may have registered on the Platform using falsified information, please contact us immediately at [email protected] so that we can investigate and take appropriate action.
As an online platform operating internationally, 33rs may transfer Personal Data to third-party service providers located in jurisdictions outside of Pakistan. Where such transfers occur, we take steps to ensure that appropriate safeguards are in place to protect your data, including contractual data-protection agreements with receiving parties.
33rs does not claim that its data processing arrangements are overseen by or approved by the Government of Pakistan, PTA or the State Bank of Pakistan. Users accessing the Platform from Pakistan do so voluntarily and acknowledge that data may be processed outside of Pakistan in connection with the operator's license jurisdiction and infrastructure arrangements.
33rs reserves the right to amend this Privacy Policy at any time. Where material changes are made, we will notify registered Users by email or via a prominent notice on the Platform before the changes take effect, where practicable.
The date of the most recent review is displayed at the top of this page. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the Platform and may request Account closure.
We recommend reviewing this Policy periodically to stay informed about how we handle your Personal Data.
If you have any questions, concerns or requests regarding this Privacy Policy or the handling of your Personal Data, please contact the 33rs data support team:
For general platform terms, please refer to our Terms & Conditions. For responsible gambling tools and support, visit our Responsible Gambling page.