1. Introduction and Scope
This Privacy Policy ("Policy") describes how 3pate ("3pate", "we", "us", "our") collects, processes, stores and protects personal data relating to individuals ("you", "User", "Player") who visit, register on, or otherwise interact with the website located at 3pate.com and all associated services and products available thereon.
By registering a 3pate account or continuing to use the platform, you acknowledge that you have read this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with the terms of this Policy, you should not use the 3pate platform.
This Policy should be read alongside the 3pate Terms & Conditions and Responsible Gaming policy, which together form the full agreement between you and 3pate.
2. Data Controller
For the purposes of this Policy, 3pate acts as the data controller in respect of all personal data collected from users of the platform. Any questions regarding the collection or use of your personal data should be directed to the 3pate data protection team at [email protected]. We aim to acknowledge all data-related enquiries within five (5) business days.
3. Personal Data We Collect
3pate collects the following categories of personal data from users of the platform:
- Identity Data: Full legal name, date of birth, nationality and government-issued identification document details collected during KYC verification.
- Contact Data: Pakistani mobile number, email address (where provided) and city or region of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad).
- Account Data: Username, hashed password, account creation date, login history and account preference settings.
- Financial Data: Deposit and withdrawal records, payment method identifiers (e.g., JazzCash account reference, Easypaisa wallet reference, bank account last four digits), transaction amounts and timestamps. 3pate does not store full bank account numbers or payment card numbers on its own servers.
- Gaming and Betting Data: Bet history, game session records, wager amounts, win and loss records, bonus usage and responsible gaming limit settings.
- Technical Data: IP address, device type, browser type and version, operating system, screen resolution, session duration and referring URL collected automatically when you access the platform.
- Communications Data: Records of correspondence with 3pate support, including live chat transcripts and email exchanges.
4. How We Collect Your Data
3pate collects personal data through the following means:
- Direct Provision: Data you voluntarily provide during account registration, KYC verification, deposit or withdrawal requests, support interactions, or when completing any other platform form or process.
- Automated Collection: Technical and usage data collected automatically by our servers and analytics systems when you access or interact with the platform. This includes cookie data as described in Section 8.
- Third-Party Sources: Identity verification data may be cross-referenced against third-party KYC and anti-fraud databases as part of our regulatory compliance obligations. Payment providers such as JazzCash and Easypaisa may confirm transaction status information to 3pate for deposit and withdrawal processing purposes.
5. How We Use Your Personal Data
3pate uses the personal data it collects for the following purposes:
- To register and maintain your 3pate account and verify your identity in compliance with KYC obligations.
- To process deposits and withdrawals in PKR via your chosen payment method.
- To provide access to all 3pate products and services, including live casino, sports betting, slots and other entertainment features.
- To detect, investigate and prevent fraud, money laundering, collusion and other prohibited conduct on the platform.
- To enforce the 3pate Terms & Conditions, including age verification and responsible gaming limit management.
- To send service notifications, security alerts and account activity updates to your registered mobile number.
- To send promotional communications about 3pate offers and new features, where you have opted in to receive such communications. You may opt out of marketing messages at any time by contacting support.
- To analyse platform usage patterns, improve the user experience and resolve technical issues.
- To comply with applicable legal and regulatory obligations.
6. Legal Bases for Processing
3pate processes your personal data on the following legal bases:
- Contractual Necessity: Processing required to perform the contract between you and 3pate, including account management, payment processing and service delivery.
- Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements and tax reporting obligations.
- Legitimate Interests: Processing necessary for 3pate's legitimate business interests, including fraud prevention, platform security and service improvement, where such interests are not overridden by your privacy rights.
- Consent: Processing based on your explicit consent, including marketing communications. You may withdraw consent at any time.
7. Disclosure of Personal Data to Third Parties
3pate does not sell, rent or trade your personal data to third parties for marketing purposes. Your data may be shared with the following categories of third party only where necessary and subject to appropriate data protection agreements:
- Payment Processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah and other payment service providers, for the sole purpose of processing your financial transactions.
- Identity Verification Providers: Third-party KYC and anti-fraud service providers who assist with identity verification and fraud prevention as part of 3pate's compliance programme.
- Game Providers: Licensed third-party game studios whose content is hosted on the 3pate platform may receive limited session data necessary for game functionality and integrity purposes.
- Regulatory Authorities: Data may be disclosed to relevant regulatory bodies, law enforcement agencies or courts where required by applicable law or pursuant to a valid legal order.
- IT and Infrastructure Providers: Cloud hosting, server management and cybersecurity service providers operating under strict confidentiality obligations.
8. Cookies and Tracking Technologies
3pate uses cookies and similar technologies to operate and improve the platform. Cookies are small data files stored on your device when you access the website. The following categories of cookies are used by 3pate:
- Strictly Necessary Cookies: Required for the platform to function, including maintaining your login session and remembering your responsible gaming preferences. These cannot be disabled.
- Functional Cookies: Remember your settings and preferences, such as language and display options, to enhance your experience on return visits.
- Analytics Cookies: Collect aggregated, anonymised data about how users interact with the platform, used to identify technical issues and improve the user experience.
- Security Cookies: Help detect and prevent fraudulent access attempts and protect the integrity of 3pate accounts.
You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect platform functionality. 3pate does not use third-party advertising or behavioural tracking cookies.
9. Data Retention
3pate retains personal data for as long as your account remains active and for a period thereafter as required by applicable legal, regulatory and audit obligations. Specific retention periods are as follows:
- Account and identity data: Retained for the duration of the account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
- Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
- Gaming history: Retained for the duration of the account and for three (3) years following account closure.
- Support communications: Retained for two (2) years from the date of the last communication in a given case.
Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 3pate's data destruction procedures.
10. Data Security
3pate employs appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:
- TLS/SSL encryption for all data transmitted between your device and the 3pate platform.
- Bcrypt hashing of all account passwords — 3pate does not store plaintext passwords.
- Role-based access controls limiting internal staff access to personal data on a need-to-know basis.
- Regular security audits and penetration testing of platform infrastructure.
- Two-factor authentication (2FA) available to all users and mandatory for internal administrative access.
- Incident response procedures to detect, report and address data security breaches promptly.
While 3pate takes all reasonable precautions, no digital transmission or storage system can be guaranteed to be 100% secure. You play an important role in keeping your account safe — please refer to Section 3 of the 3pate Terms & Conditions for your account security responsibilities.
11. Your Rights as a Data Subject
Subject to applicable data protection law, you hold the following rights in respect of your personal data held by 3pate:
- Right of Access: You may request a copy of the personal data 3pate holds about you.
- Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold.
- Right to Erasure: You may request deletion of your personal data in certain circumstances, subject to our legal retention obligations.
- Right to Restrict Processing: You may request that we limit the processing of your data in defined circumstances.
- Right to Data Portability: You may request that we provide your personal data in a structured, machine-readable format.
- Right to Object: You may object to processing based on legitimate interests, including direct marketing.
- Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact 3pate at [email protected] with your registered username and a clear description of your request. We will respond within thirty (30) days. Identity verification may be required before we fulfil any data request.
12. Children's Privacy
The 3pate platform is strictly intended for persons aged 18 years and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete such data and close the associated account. If you believe a minor has registered on 3pate, please notify us immediately at [email protected].
13. Changes to This Privacy Policy
3pate reserves the right to update this Privacy Policy at any time. Where material changes are made to the way in which we process your personal data, we will notify you by displaying a prominent notice on the platform or by sending a notification to your registered mobile number prior to the change taking effect. The "Effective Date" at the top of this Policy will be updated to reflect the date of the most recent revision. Your continued use of the 3pate platform following notification of a revised Policy constitutes your acceptance of the updated terms.
14. Contact and Data Requests
All privacy-related enquiries, data subject access requests and concerns regarding this Policy should be directed to the 3pate data protection team through the following channels:
- Email: [email protected] — please include "Privacy Request" in the subject line.
- Live Chat: Available 24 hours a day, 7 days a week via the chat widget in your 3pate account.
We aim to acknowledge all privacy enquiries within five (5) business days and to resolve substantive requests within thirty (30) days. Complex requests may require additional time; we will inform you if this is the case.