3rrrr Privacy Policy – How We Handle Your Data

This Privacy Policy ("Policy") describes how 3rrrr ("the Company", "we", "us", "our") collects, uses, stores, protects and discloses personal information in connection with your use of the 3rrrr platform, accessible at https://3rrrr.app ("Platform").

By registering an account with 3rrrr or by otherwise using the Platform, you acknowledge that you have read, understood and consent to the data practices described in this Policy. If you do not agree with this Policy, you must discontinue use of the 3rrrr Platform immediately.

This Policy should be read alongside the 3rrrr Terms and Conditions. Capitalised terms used in this Policy but not defined herein shall have the meanings ascribed to them in the Terms and Conditions.

For the purposes of this Policy, 3rrrr is the data controller responsible for the personal data of Players on the Platform. As data controller, 3rrrr determines the purposes and means by which personal data is processed.

Enquiries relating to the processing of your personal data, including requests to exercise your data subject rights, should be directed to the 3rrrr Data Privacy team via the contact details set out in Section 15 of this Policy.

3rrrr collects the following categories of personal data in connection with the operation of the Platform:

3rrrr does not collect sensitive personal data — such as racial or ethnic origin, political opinions, religious beliefs or biometric data — unless specifically required by applicable anti-money laundering regulations or identity verification obligations, in which case such data will be processed solely for those compliance purposes.

3rrrr uses personal data collected from Players for the following purposes:

• Account registration and management — To create, verify and maintain your 3rrrr account, including processing your login credentials and managing your PKR balance.
• Identity verification (KYC) — To confirm your identity, age and eligibility to use the Platform in compliance with regulatory obligations. Pakistani players may be required to submit CNIC or passport documentation.
• Payment processing — To process deposits and withdrawals via JazzCash, Easypaisa, HBL, UBL, Meezan Bank and Bank Alfalah, including fraud detection and anti-money laundering screening.
• Platform operation and improvement — To deliver the games, sportsbook, live casino and other Platform features, and to analyse usage patterns in order to improve the 3rrrr experience.
• Responsible gaming — To monitor gaming behaviour and implement responsible gaming tools including deposit limits, reality checks and self-exclusion in accordance with our obligations and your requests.
• Customer support — To respond to enquiries, complaints and support requests submitted via live chat or email during PKT support hours.
• Legal and regulatory compliance — To meet obligations under applicable anti-money laundering, counter-terrorism financing and data protection laws.
• Marketing communications — To send promotional offers and updates to Players who have opted in to receive marketing communications from 3rrrr. Opt-out instructions are included in every marketing communication.

3rrrr processes personal data on the following legal bases:

• Contractual necessity — Processing required to perform the contract between 3rrrr and the Player, including account management, payment processing and platform service delivery.
• Legal obligation — Processing required to comply with applicable legal and regulatory requirements, including KYC, AML and responsible gaming obligations.
• Legitimate interests — Processing for fraud prevention, platform security, platform improvement, and customer service, where such interests are not overridden by the Player's rights.
• Consent — Processing for marketing communications and non-essential cookies, where the Player has provided explicit consent. Consent may be withdrawn at any time.

3rrrr does not sell, rent or trade your personal data to third parties for commercial purposes. Personal data may be disclosed in the following limited circumstances:

• Game providers — Technical data such as session identifiers may be shared with licensed game providers (including Evolution, Pragmatic Play, PG Soft and JILI) to the extent necessary to deliver game content on the Platform.
• Payment processors — Financial data is shared with payment service providers (JazzCash, Easypaisa, HBL, UBL, Meezan Bank and Bank Alfalah) solely for the purpose of processing deposits and withdrawals.
• Identity verification providers — Identity and document data may be shared with third-party KYC service providers for the purpose of verifying player identity and age.
• Regulatory and law enforcement authorities — 3rrrr may disclose personal data where required to do so by applicable law, court order, or the request of a competent regulatory or law enforcement authority.
• Corporate transactions — In the event of a merger, acquisition or sale of all or part of the business, personal data may be transferred to the relevant successor entity, subject to the same protections described in this Policy.

All third parties with whom 3rrrr shares personal data are required to maintain appropriate security measures and to use the data only for the purposes specified by 3rrrr.

3rrrr takes the security of payment data particularly seriously, given that Pakistani players transact in PKR through local mobile wallets and bank accounts. The following protections apply to payment data specifically:

• 3rrrr does not store full payment card numbers, JazzCash account credentials or Easypaisa PINs on its own servers. Payment authentication is handled exclusively by the respective payment processor.
• Transaction reference data retained by 3rrrr is used solely for financial reconciliation, dispute resolution, AML compliance and player account management.
• Deposit and withdrawal history held in your 3rrrr account is accessible only to you and authorised 3rrrr staff with a legitimate operational need.
• Where 3rrrr is required by law to report financial transactions to regulatory authorities, this will be done without prior notice to the affected Player where such notice is prohibited or would undermine the reporting obligation.

The 3rrrr Platform uses cookies and similar tracking technologies to operate correctly and to improve the player experience. The following categories of cookies are used:

• Strictly necessary cookies — Required for the Platform to function. These include session authentication cookies and security tokens. These cookies cannot be disabled without breaking the Platform.
• Analytical cookies — Used to understand how Players interact with the Platform, which pages are visited most frequently, and where technical issues occur. Analytics data is aggregated and anonymised where possible.
• Preference cookies — Store your language preference, display settings and other personalisation choices to improve your experience on return visits.

3rrrr does not use behavioural advertising cookies that profile your browsing activity across third-party sites. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your 3rrrr account.

3rrrr implements technical and organisational security measures appropriate to the risk level of the personal data processed. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between the Player's device and 3rrrr servers.
• Encryption of sensitive data fields at rest within 3rrrr databases.
• Access controls that restrict personal data access to authorised personnel with a documented operational need.
• Regular security assessments of the Platform and infrastructure.
• Two-factor authentication available for all Player accounts.

Notwithstanding these measures, no transmission of data over the internet can be guaranteed to be completely secure. 3rrrr will notify affected Players in accordance with applicable legal obligations in the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals.

3rrrr retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Active account data is retained for the duration of the Player's registration on the Platform.
• Following account closure, identity and transaction data is retained for a minimum of five (5) years to satisfy AML record-keeping requirements.
• Support communications are retained for a period of two (2) years following the resolution of the relevant matter.
• Technical log data (IP addresses, session logs) is retained for a period of twelve (12) months unless required to be retained longer for an active investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 3rrrr's data destruction procedures.

Subject to applicable law, Players have the following rights with respect to their personal data held by 3rrrr:

• Right of access — You may request confirmation of whether 3rrrr holds personal data about you and a copy of that data.
• Right to rectification — You may request correction of inaccurate or incomplete personal data. Some corrections may require identity re-verification.
• Right to erasure — You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and where no legal obligation requires its retention.
• Right to restrict processing — You may request restriction of processing of your personal data in certain circumstances, including where you contest the accuracy of the data or object to its processing.
• Right to data portability — Where processing is based on consent or contractual necessity, you may request a copy of your personal data in a structured, commonly used and machine-readable format.
• Right to withdraw consent — Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact 3rrrr at [email protected]. 3rrrr will respond to data subject requests within thirty (30) days. Where the request is complex or where a high volume of requests is received, this period may be extended by a further two months with notification to the requester.

The 3rrrr Platform integrates with third-party game providers, payment processors and technical service providers necessary to deliver the Platform. These third parties operate under their own privacy practices which 3rrrr does not control.

3rrrr has contractual data processing agreements in place with all third-party processors to ensure that personal data shared with them is handled in accordance with appropriate security and confidentiality standards consistent with this Policy.

3rrrr is not responsible for the privacy practices of third-party services that are not operated by or on behalf of 3rrrr.

The 3rrrr Platform is strictly for individuals aged 18 years and above. 3rrrr does not knowingly collect or process personal data from individuals under the age of 18. If 3rrrr becomes aware that personal data has been collected from a minor, the relevant account will be immediately suspended and the data will be deleted as soon as practicable.

If you believe that a minor has registered an account on 3rrrr or that their personal data has been collected by the Platform, please contact 3rrrr support immediately at [email protected].

3rrrr reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes will be communicated to registered Players via email or prominent Platform notice with reasonable advance notice.

The current version of this Privacy Policy is available at https://3rrrr.app/privacy-policy. The effective date of the most recent revision is displayed at the top of the document. Continued use of the Platform following the effective date of any revision constitutes acceptance of the updated Policy.

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by 3rrrr, please contact:

• Email: [email protected]
• Subject line: Privacy Policy Enquiry – [Your Registered Email]
• Support Hours: Monday – Sunday, 10:00 – 02:00 Pakistan Standard Time (PKT)

3rrrr aims to acknowledge all privacy-related enquiries within five (5) business days and to provide a substantive response within thirty (30) days of receipt.