Privacy Policy

1 Introduction

This Privacy Policy ("Policy") sets out how 3rrm ("3rrm", "the Platform", "we", "us" or "our"), operating at https://3rrm.cam, collects, uses, stores, shares and protects the personal data of individuals ("Users", "you" or "your") who register for or otherwise interact with the Platform.

3rrm is committed to handling your personal data with transparency, integrity and respect for your privacy. This Policy is designed to give you a clear and complete picture of our data practices so that you can make informed decisions about your use of the Platform.

By registering an account or continuing to use the 3rrm Platform, you acknowledge that you have read and understood this Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact us to arrange closure of your account.

2 Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, directly or indirectly.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, alteration or deletion.
• "Data Controller" means 3rrm, which determines the purposes and means of processing your Personal Data.
• "Data Processor" means any third party that processes Personal Data on behalf of 3rrm under a contractual arrangement.
• "Consent" means a freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "KYC Data" means identity and verification documents submitted during the Know Your Customer process, including CNIC, passport copies and proof of address.
• "Usage Data" means information collected automatically about your interactions with the Platform, including IP address, device type, browser, session duration and pages visited.
• "Special Category Data" means sensitive Personal Data including health information (which may be relevant in responsible-gambling contexts), as well as financial and biometric data where applicable.

3 Data We Collect

3rrm collects Personal Data through several channels. The categories of data we may collect include:

3.1 Registration Data

When you create an account on 3rrm, we collect the information you provide at registration, including:

• Full legal name
• Date of birth
• Residential address (including city — such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar — and postal code)
• Email address
• Mobile phone number
• Username and password (stored in hashed form)

3.2 KYC and Verification Data

As part of our identity verification obligations, we may collect copies of government-issued identification documents such as your Computerised National Identity Card (CNIC) or passport, as well as supporting documentation confirming your address and, where required, your source of funds.

3.3 Financial and Transaction Data

We collect records of deposits, withdrawals, bet placements and account balance history. This includes the payment method references used — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — solely to facilitate transaction processing. These references do not imply any endorsement by or affiliation with those payment providers in connection with gambling activities.

3.4 Usage Data

We automatically collect technical data when you access the Platform, including your IP address, browser type and version, operating system, device identifiers, referring URLs, pages visited, time on page and click-path data.

3.5 Communications Data

When you contact 3rrm support — whether by email, live chat or any other channel — we retain a record of that correspondence, including the content of messages, timestamps and any attachments provided.

3.6 Responsible Gambling Data

Where you voluntarily interact with our responsible gambling tools — such as setting deposit limits, activating a self-exclusion or completing a responsible gambling assessment — we record and store this information to honour your settings and monitor compliance with your stated preferences.

4 Data Processing

3rrm processes your Personal Data for the following purposes:

• Account Management: Creating, maintaining and administering your account, including authentication and security controls.
• Service Delivery: Enabling you to place bets, access casino games, participate in live dealer tables, manage your balance and use all features of the Platform.
• Identity and Age Verification: Conducting KYC checks to confirm your identity, age and eligibility in accordance with our Terms and applicable compliance obligations.
• Payment Processing: Facilitating deposits and withdrawals through the relevant payment channels and maintaining accurate financial records.
• Fraud and Security: Detecting, investigating and preventing fraudulent activity, money laundering, account takeover, bonus abuse and other prohibited conduct.
• Responsible Gambling: Monitoring usage patterns to identify potential problem gambling behaviour and giving effect to any limits or exclusions you have set.
• Customer Support: Managing support enquiries, resolving disputes and improving our service based on feedback.
• Marketing Communications: Where you have provided consent, sending you promotional information, offers and updates relevant to your use of 3rrm. You may withdraw consent at any time.
• Legal and Regulatory Compliance: Meeting obligations under applicable law, responding to lawful requests from regulators and competent authorities, and maintaining records as required.
• Platform Analytics and Improvement: Analysing aggregated usage data to understand how the Platform is used and to improve performance, design and features.

5 Legal Basis for Processing

Where data protection law requires a legal basis for processing Personal Data, 3rrm relies on one or more of the following grounds:

• Contractual Necessity: Processing required to perform our obligations under the agreement formed when you register an account and accept our Terms and Conditions — including account creation, transaction processing and service delivery.
• Legal Obligation: Processing necessary to comply with applicable law, including anti-money-laundering regulations, age verification requirements and responses to lawful authority requests.
• Legitimate Interests: Processing carried out to pursue our legitimate business interests — such as fraud prevention, Platform security, analytics and responsible gambling monitoring — where those interests are not overridden by your fundamental rights.
• Consent: Where we rely on your consent — primarily for direct marketing communications — you may withdraw that consent at any time by contacting support or using the opt-out mechanism in any marketing message.

6 Data Sharing

3rrm does not sell your Personal Data to any third party. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual or legal safeguards:

6.1 Service Providers and Data Processors

We engage third-party service providers to support the Platform, including KYC and identity verification providers, payment processing partners, cloud hosting and infrastructure providers, fraud-detection services and customer support platforms. All processors operate under binding data processing agreements that restrict how they may use your data.

6.2 Regulatory and Legal Authorities

We may disclose Personal Data to licensing authorities, law enforcement agencies, financial intelligence units or courts where required to do so by applicable law, court order or lawful regulatory direction.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of 3rrm's business, Personal Data held by the Platform may be transferred to the relevant successor entity, subject to equivalent privacy protections.

7 Data Retention

We retain your Personal Data only for as long as necessary to fulfil the purposes set out in this Policy, including satisfying legal, regulatory, accounting and reporting obligations. The following general retention guidelines apply:

• Active Account Data: Retained for the duration of your account and for a minimum period after closure as required by applicable law and our licensing obligations.
• KYC and Identity Documents: Retained for a minimum of five (5) years following account closure or the last transaction, in line with standard AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years to comply with financial record-keeping obligations.
• Support and Communications Records: Retained for a period sufficient to resolve any outstanding disputes and for up to three (3) years following closure of a support case.
• Responsible Gambling Records: Retained for the duration of any active self-exclusion and for a sufficient period thereafter to prevent circumvention of exclusion settings on re-registration.

When data is no longer required, it is securely deleted or anonymised in a manner that prevents re-identification.

8 Cookies & Tracking Technologies

3rrm uses cookies and similar tracking technologies to support the operation and improvement of the Platform. The following categories of cookies may be active on the Platform:

• Essential Cookies: Strictly necessary for the Platform to function. These enable session management, login authentication and security features. They cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences and responsible gambling limit configurations to improve your experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how Users interact with the Platform — including pages visited, session duration and click paths — to help us understand usage patterns and improve performance.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic and suspicious account behaviour.

You can manage cookie preferences through your browser settings. Note that disabling non-essential cookies will not affect your core ability to use the Platform, but some personalisation features may not function as intended.

9 Data Security

3rrm implements appropriate technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include:

• TLS/SSL encryption for data transmitted between your device and the Platform.
• Hashing of passwords using industry-standard algorithms — your password is never stored in plain text.
• Role-based access controls limiting internal access to Personal Data to authorised personnel only.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Secure data centres with physical access controls and redundancy measures.

While we take these measures seriously, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

10 International Data Transfers

As an online platform serving users in Pakistan, 3rrm may process or store Personal Data in jurisdictions outside Pakistan, including countries where our hosting infrastructure or third-party service providers operate. Where Personal Data is transferred internationally, we take steps to ensure that appropriate safeguards are in place, such as contractual data protection clauses with the receiving party.

By using the Platform, you acknowledge that your Personal Data may be transferred to and stored in countries that may have different data protection standards than those applicable in your home jurisdiction. We will always handle your data in accordance with the commitments set out in this Policy, regardless of where it is processed.

11 User Rights

Subject to applicable law and certain limitations, you have the following rights in respect of your Personal Data held by 3rrm. To exercise any of these rights, contact our support team using the details in Section 14.

We will respond to all valid rights requests within thirty (30) days. In complex cases we may extend this period by a further sixty (60) days, in which case we will notify you of the extension and reasons within the initial thirty-day window.

12 Minors

The 3rrm Platform is strictly intended for adults aged 18 years and above — or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect Personal Data from individuals under the applicable minimum age.

If we become aware that Personal Data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that a minor has registered on the Platform, please contact us immediately using the details in Section 14.

13 Policy Amendments

3rrm reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law or Platform functionality. Where changes are material, we will notify registered users via their registered email address and update the "Last updated" date at the top of this page.

Your continued use of the Platform after the effective date of any amended Policy constitutes your acknowledgement of the updated terms. We encourage you to review this Policy periodically to stay informed about how we handle your Personal Data.

14 Contact Us

If you have any questions, concerns or requests regarding this Privacy Policy or the way 3rrm handles your Personal Data, please contact our support team. All contact details are provided as plain text only and must not be used for unsolicited commercial communications.

For requests related to self-exclusion, responsible gambling limits or gambling-related welfare concerns, please visit our dedicated Responsible Gambling page.