Privacy Policy — How 365pak Safeguards Your Information

1. Who We Are

365pak ("we", "us", "our", "the Platform") operates the online casino and sports betting platform accessible at https://365pak.club. 365pak acts as the data controller in respect of personal data collected through the platform, meaning we determine the purposes and means of processing your personal information.

This Privacy Policy applies to all users of the 365pak platform, including registered account holders, visitors browsing the site without an account, and individuals who contact our customer support team. It covers all 365pak products and services, including cricket betting, PSL wagering, live casino, slots, Blackjack, payment services, and bonus programmes.

We operate under international gaming licensing standards and are committed to handling personal data in a manner consistent with globally recognised data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

2. Personal Data We Collect

365pak collects personal data that is necessary to provide our gaming services, comply with legal and regulatory obligations, and improve user experience. The following table summarises the categories of data we collect and the primary purpose for each:

Data Category	Examples	Primary Purpose
Identity Data	Full name, date of birth, CNIC number, nationality	Account registration, age verification, KYC compliance
Contact Data	Email address, phone number, residential address	Account management, support communications, notifications
Financial Data	JazzCash/EasyPaisa account numbers, HBL/UBL/Meezan Bank details, USDT wallet address, transaction history	Deposit and withdrawal processing, AML compliance, fraud prevention
Gaming Activity Data	Bet history, game sessions, wagering amounts, win/loss records, bonus usage	Service delivery, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type, operating system, session timestamps	Security monitoring, fraud detection, platform optimisation
Usage Data	Pages visited, features used, click paths, referral source	Platform improvement, personalisation, marketing analysis
Communications Data	Live chat transcripts, email correspondence, support ticket content	Customer support, quality assurance, dispute resolution
Verification Documents	Government-issued ID scans, proof of address, proof of payment method	KYC verification, AML compliance, age verification

We do not collect sensitive special-category data (such as health data, religious beliefs, or biometric data) except where strictly required for responsible gaming purposes, such as recording a self-exclusion request, in which case your explicit consent is obtained.

3. How We Collect Your Data

365pak collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated Collection: Technical and usage data collected automatically when you access the 365pak platform, including via cookies, session tokens, log files, and analytics tools embedded in the platform.
• Payment Processors: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast, and USDT TRC20 networks when processing your deposits and withdrawals.
• Identity Verification Services: Data received from third-party KYC and identity verification providers used to confirm the authenticity of documents you submit during account verification.
• Fraud Prevention Agencies: Risk signals and flagged data received from third-party fraud detection services as part of our platform security operations.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available databases as part of our AML compliance programme.

4. How We Use Your Personal Data

365pak processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your 365pak player account, including login authentication, account settings, and player profile management.
• Service Delivery: Providing access to cricket betting, PSL markets, live casino, slot games, Blackjack, and all other 365pak gaming products and features.
• Payment Processing: Facilitating PKR deposits and withdrawals via JazzCash, EasyPaisa, and other supported Pakistani payment methods; reconciling transaction records; processing refunds where applicable.
• Identity and Age Verification: Confirming that you meet the mandatory 21+ age requirement and verifying your identity in accordance with our KYC obligations under international gaming licensing standards.
• Regulatory and Legal Compliance: Meeting our obligations under applicable AML, counter-terrorism financing (CTF), and gaming regulatory requirements, including transaction monitoring, suspicious activity reporting, and record-keeping.
• Responsible Gaming: Monitoring gaming patterns to identify potentially problematic behaviour; administering deposit limits, self-exclusion, and cooling-off requests; fulfilling our duty of care to players.
• Fraud and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, bonus abuse, unauthorised account access, and other security threats to the platform.
• Customer Support: Responding to queries, resolving disputes, processing complaints, and providing technical assistance through live chat and email support channels.
• Marketing and Promotions: Sending promotional communications about 365pak bonuses, new games, and special offers — but only where you have provided consent or where we have a legitimate interest basis. You can opt out at any time.
• Platform Improvement: Analysing usage data and user behaviour to improve platform performance, game selection, user interface design, and overall player experience.
• Legal Proceedings: Exercising or defending legal claims, complying with court orders, and cooperating with regulatory or law enforcement authorities when lawfully required.

5. Legal Bases for Processing

365pak processes your personal data on the following legal bases, depending on the specific purpose:

• Contractual Necessity: Processing required to perform our contract with you — i.e., to provide the gaming services you have registered for, process your payments, and manage your account.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML laws, gaming licensing requirements, and age verification obligations.
• Legitimate Interests: Processing carried out for 365pak's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — particularly for direct marketing communications and for certain responsible gaming data processing. You may withdraw consent at any time by contacting [email protected].

6. Data Sharing & Disclosure

365pak does not sell your personal data to third parties. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: Your financial data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast, and USDT TRC20 network operators solely to process your deposit and withdrawal transactions.
• KYC and Identity Verification Providers: Identity documents and personal details are shared with our third-party verification partners to authenticate your identity and confirm your age in compliance with regulatory requirements.
• Fraud Prevention and AML Services: Technical and transactional data may be shared with fraud detection and AML compliance service providers to identify and prevent financial crime.
• Game Software Providers: Limited gameplay session data is shared with our licensed game content providers to facilitate fair game operation and resolve technical disputes.
• Regulatory and Law Enforcement Authorities: We are legally required to share data with gaming regulators, financial intelligence units, and law enforcement agencies upon receipt of a lawful request or court order.
• Professional Advisers: In limited circumstances, data may be shared with our legal counsel, auditors, or insurers under obligations of professional confidentiality.
• Business Successors: In the event of a merger, acquisition, or sale of the 365pak business, your data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

All third-party service providers engaged by 365pak are contractually required to process your data only for the specified purpose, to maintain appropriate security standards, and to comply with applicable data protection laws.

7. Cookies & Tracking Technologies

365pak uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the 365pak website. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game display options, and notification preferences to personalise your experience.
• Analytics Cookies: Collect anonymised data about how players use the platform — which games are most visited, where users drop off, and how pages perform — to help us improve the service.
• Marketing Cookies: Used to deliver relevant promotional content about 365pak bonuses and offers, based on your platform activity. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect your ability to use some 365pak features. Strictly necessary cookies cannot be disabled via browser settings as they are required for core security and session management functions.

8. Data Retention

365pak retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with 365pak, plus a minimum of 5 years following account closure, to comply with AML and gaming regulatory record-keeping requirements.
• Transaction Records: Financial transaction data is retained for a minimum of 7 years from the date of the transaction, in line with international AML record-keeping standards.
• KYC Documents: Identity verification documents are retained for a minimum of 5 years following account closure or the date of verification, whichever is later.
• Communications Data: Support correspondence and live chat transcripts are retained for up to 3 years from the date of the interaction.
• Gaming Activity Logs: Bet and game session records are retained for a minimum of 5 years for dispute resolution and regulatory audit purposes.
• Marketing Consent Records: Records of your consent to receive marketing communications are retained for the duration of the marketing relationship plus 3 years.

Where data is no longer required, 365pak will securely delete or anonymise it in a manner that prevents reconstruction of your personal information.

9. Data Security

365pak implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 365pak platform.
• Encryption at rest for sensitive data stored on 365pak servers, including financial records and identity documents.
• Role-based access controls ensuring that only authorised 365pak personnel with a legitimate need can access player personal data.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security professionals.
• Multi-factor authentication requirements for internal staff accessing player data systems.
• Intrusion detection systems and 24/7 security monitoring for anomalous platform activity.
• Formal data breach response procedures with defined notification timelines.

10. Your Privacy Rights

As a 365pak user, you hold the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected]. We will respond within 30 days of receiving your request:

• Right of Access: You have the right to request a copy of the personal data 365pak holds about you, together with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances, such as where the data is no longer necessary for its original purpose. Note that this right is subject to our legal obligation to retain certain records for regulatory and AML compliance purposes.
• Right to Restriction: You have the right to request that we restrict the processing of your data in certain circumstances, for example while the accuracy of data is being contested.
• Right to Data Portability: You have the right to receive a structured, machine-readable copy of personal data you have provided to 365pak, where processing is based on consent or contractual necessity.
• Right to Object: You have the right to object to processing based on legitimate interests, including direct marketing. Upon receiving a marketing objection, we will cease all promotional communications to you immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

We will not charge a fee for exercising your privacy rights in standard circumstances. If a request is manifestly unfounded or excessive, we reserve the right to charge a reasonable administrative fee or decline the request, with written reasons provided.

11. Children's Privacy

The 365pak platform is strictly intended for users who are 21 years of age or older. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. If we become aware that an account has been registered by or on behalf of a person under 21, we will immediately suspend the account, delete all associated personal data to the extent permitted by law, and return any deposited funds in accordance with our responsible gaming obligations.

If you believe that a minor has accessed or registered on the 365pak platform, please contact our support team immediately at [email protected] so that we can take prompt action.

12. International Data Transfers

365pak's platform infrastructure and some of our third-party service providers may be located outside of Pakistan. When your personal data is transferred internationally, 365pak ensures that adequate safeguards are in place to protect your data, including:

• Contractual data protection clauses incorporated into agreements with all international service providers.
• Transfer only to service providers operating in jurisdictions with recognised data protection frameworks.
• Technical security controls equivalent to those applied to data processed within Pakistan.

By using the 365pak platform, you acknowledge and consent to the transfer of your personal data to our service providers in other jurisdictions as described in this policy, subject always to the safeguards described above.

13. Third-Party Services & Links

The 365pak platform may reference or interact with third-party services — particularly in relation to payment processing (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank) and game content provision. These third-party services operate under their own privacy policies, and 365pak is not responsible for the data practices of third-party providers once data leaves the 365pak platform environment.

We recommend reviewing the privacy policies of any third-party payment services you use in connection with your 365pak account. 365pak selects third-party partners based on their demonstrated commitment to data security and privacy compliance.

14. Updates to This Privacy Policy

365pak reserves the right to update, amend, or replace this Privacy Policy at any time. When we make material changes to this policy, we will notify registered users via the email address on file or through a prominent in-platform notification, with at least 7 days' advance notice before the updated policy takes effect.

The "Last Updated" date at the top of this policy reflects the most recent revision. Your continued use of the 365pak platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, please close your account before the effective date.

15. Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 365pak handles your personal data, please contact our Data Protection team through the following channels:

• Live Chat: Available 24/7 inside the 365pak platform. This is the fastest route for urgent data-related queries.
• Email: [email protected] — please include "Privacy Request" in the subject line so your query is routed to the correct team.

We aim to acknowledge all privacy-related requests within 48 hours and provide a substantive response within 30 days. For complex requests, we may extend this period by a further 60 days and will notify you of the extension with reasons.

If you are not satisfied with our handling of your privacy concern after following our internal complaint process, you have the right to escalate the matter to the relevant data protection supervisory authority or gaming regulatory body in your jurisdiction.