Privacy Policy — 37ok Pakistan

1. Introduction

37ok ("we", "us", "our") operates the online casino and sports betting platform accessible at 37ok.app. We understand that privacy matters deeply to our players, and we are committed to handling personal data with transparency, integrity, and in full compliance with applicable data protection obligations under our international gaming licence framework.

This Privacy Policy applies to all personal data collected from individuals who visit, register on, or interact with the 37ok platform, including through our website, mobile interface, customer support channels, and any promotional communications. It covers Pakistani players as well as any other users who access the platform from eligible jurisdictions.

This policy should be read alongside our Terms & Conditions, which also form part of your agreement with 37ok.

2. Data Controller

For the purposes of applicable data protection law, 37ok is the data controller responsible for your personal information. 37ok operates under a valid international gaming licence, and all personal data processing activities are conducted in compliance with the data protection obligations imposed under that licensing framework.

If you have questions about how 37ok processes your personal data, or wish to exercise any of your data subject rights, please contact our Data Protection team using the details set out in Section 14 of this policy.

3. Personal Data We Collect

37ok collects personal data in the following categories, depending on the nature of your interaction with the platform:

37ok does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, beyond what may be incidentally included in identity documents submitted for KYC purposes.

4. How We Use Your Personal Data

37ok uses the personal data collected for the following specific purposes:

• Account Management: To create, maintain, and manage your 37ok player account, including authentication and account security.
• Identity Verification (KYC): To verify your identity and age in compliance with anti-money laundering (AML) and responsible gaming obligations applicable under our gaming licence.
• Transaction Processing: To process PKR deposits and withdrawals through your chosen payment method, reconcile accounts, and maintain financial records.
• Regulatory Compliance: To fulfil legal and regulatory obligations, including AML reporting, fraud prevention, and cooperation with competent authorities where legally required.
• Customer Support: To respond to your queries, complaints, and requests submitted through our support channels.
• Responsible Gaming: To monitor gaming activity for indicators of problem gambling, apply player-requested limits, and enforce self-exclusion requests in compliance with our responsible gaming obligations.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve platform performance, game offerings, and user experience.
• Marketing Communications: To send promotional emails, bonus notifications, and PSL or cricket season offers — but only where you have given explicit consent. You may withdraw marketing consent at any time through your account settings.
• Fraud & Security: To detect, investigate, and prevent fraudulent activity, account takeovers, collusion, and any other security threats to the platform or its players.

5. Legal Basis for Processing

37ok processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to perform the contract between you and 37ok (i.e., operating your account, processing bets, and handling transactions).
• Legal Obligation: Processing required to comply with AML regulations, KYC requirements, gaming licence conditions, and any lawful requests from regulatory or law enforcement authorities.
• Legitimate Interests: Processing necessary for 37ok's legitimate interests in fraud prevention, platform security, and responsible gaming oversight, provided such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given clear and freely withdrawable consent.

6. Data Sharing & Third Parties

37ok does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Data is shared only in the following circumstances and only to the extent necessary:

• Payment Processors: Personal and transaction data is shared with licensed payment service providers (including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT gateway operators) solely for the purpose of processing your PKR transactions.
• KYC & AML Providers: Identity documents and verification data may be shared with third-party KYC and AML compliance service providers engaged by 37ok to fulfil its regulatory obligations.
• Game Providers: Technical identifiers (not full identity data) may be shared with third-party game studios and RNG certification bodies in connection with game audits and dispute resolution.
• Regulatory & Legal Authorities: 37ok will disclose personal data to regulators, law enforcement agencies, or courts where required by law, a valid legal order, or the conditions of our gaming licence.
• IT & Infrastructure Providers: Hosting, cloud storage, and cybersecurity service providers may have access to personal data in the course of providing services to 37ok, subject to strict data processing agreements.

7. Data Retention

37ok retains personal data only for as long as is 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:

• Account & Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, or longer where required by applicable financial regulations.
• Gaming Activity Logs: Retained for a minimum of three (3) years from the date of activity for responsible gaming monitoring and dispute resolution purposes.
• Customer Support Records: Retained for two (2) years from the date of the last interaction, or longer where a complaint or legal matter remains unresolved.
• Marketing Preference Data: Retained until you withdraw consent, at which point marketing processing ceases promptly and preference data is updated accordingly.
• Technical & Log Data: Retained for up to twelve (12) months for security monitoring and platform diagnostic purposes.

Following expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

8. Security Measures

37ok implements a range of technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure:

• All data in transit between your device and 37ok servers is encrypted using SSL/TLS protocols.
• Sensitive personal data at rest is stored using industry-standard encryption in secured data centres with access controls and audit logging.
• Access to personal data is restricted to authorised 37ok personnel who require it to perform their role, subject to role-based access controls and confidentiality obligations.
• 37ok conducts periodic security assessments and vulnerability testing of its platform infrastructure.
• In the event of a personal data breach that poses a risk to your rights, 37ok will notify affected players and relevant authorities in accordance with applicable obligations under our gaming licence framework.

While 37ok takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for keeping your account credentials confidential and for notifying 37ok immediately if you suspect unauthorised access to your account.

9. Cookies & Tracking Technologies

37ok uses cookies and similar technologies (such as local storage and session tokens) on its platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication tokens, CSRF protection cookies, and load-balancing identifiers. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and responsible gaming limit configurations. These improve your experience but are not essential.
• Analytical Cookies: Used to collect anonymised data about how players interact with the platform, which pages are visited, and where errors occur. This data helps 37ok improve the platform experience.
• Marketing Cookies: Used only where you have provided explicit consent to receive personalised promotional communications related to 37ok offers, PSL cricket betting promotions, and other relevant campaigns.

You may manage your cookie preferences at any time through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the 37ok platform. Withdrawing consent for non-essential cookies does not affect the lawfulness of any prior processing.

10. Your Data Subject Rights

Subject to applicable data protection law and the terms of our gaming licence obligations, you have the following rights in relation to your personal data held by 37ok:

• Right of Access: You may request a copy of the personal data 37ok holds about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data held in your account.
• Right to Erasure: In certain circumstances, you may request deletion of your personal data. Note that this right is limited where 37ok is required to retain data for legal, regulatory, or AML compliance purposes.
• Right to Restrict Processing: You may request that 37ok restricts the processing of your personal data in certain defined circumstances while a dispute or correction request is being resolved.
• Right to Data Portability: Where technically feasible and legally applicable, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time through your account settings or by contacting support. Withdrawal does not affect prior lawful processing.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including direct marketing. 37ok will cease such processing unless it can demonstrate compelling grounds that override your interests.

To exercise any of these rights, please contact us at [email protected]. We will respond within a reasonable timeframe, typically within 30 days of receiving your request. We may need to verify your identity before processing your request.

11. Minors & Age Policy

37ok is strictly an adults-only platform. All players must be at least 21 years of age to register and use 37ok services. 37ok does not knowingly collect personal data from individuals under the age of 21.

If 37ok becomes aware that personal data has been collected from a person under the minimum age, that account will be immediately closed, all data deleted, and any deposits returned to the originating payment method following applicable verification checks.

12. International Data Transfers

As an internationally licensed platform serving Pakistani players, 37ok may process or store certain personal data on servers located outside of Pakistan. Where personal data is transferred internationally, 37ok ensures that appropriate safeguards are in place, including:

• Transfers to jurisdictions with an adequate level of data protection as determined under our licensing framework.
• Data processing agreements with all third-party service providers that impose equivalent data protection standards.
• Technical and organisational security measures that apply regardless of the geographic location of data processing.

By using the 37ok platform, you acknowledge and accept that your personal data may be transferred to and processed in jurisdictions outside Pakistan in accordance with the safeguards described in this policy.

13. Changes to This Privacy Policy

37ok reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our gaming licence obligations. Where changes are material, 37ok will notify registered players by email or through a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this policy reflects the most recent revision. Continued use of the 37ok platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not agree with any changes, you should cease using the platform and may request account closure in accordance with the Terms & Conditions.

14. Contact Us — Privacy Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 37ok, please contact our support team through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• Support Hours: 10:00 AM – 02:00 AM PKT, daily

Please include your registered account username and a clear description of your privacy request or concern. We aim to acknowledge all privacy-related enquiries within 5 business days and resolve them within 30 days.