3rcom Privacy Policy

1 Who We Are

3rcom ("we", "us", "our", or "the Company") operates the online casino and sports betting platform available at 3rcom.pro, providing Pakistani players with cricket betting, live casino games, high-RTP slot titles, and instant PKR payment services via JazzCash, EasyPaisa, Raast, and major Pakistani banks.

For the purposes of this Privacy Policy, 3rcom is the data controller responsible for your personal data. This means we determine how and why your personal data is processed. Where 3rcom uses third-party service providers to process your data on its behalf, those parties act as data processors and are contractually bound to process your data only on 3rcom's instructions and in accordance with this Policy.

If you have any questions about how 3rcom handles your personal data, or wish to exercise any of your data rights described in Section 10 of this Policy, please contact us at [email protected].

2 Personal Data We Collect

3rcom collects personal data from you directly when you register an account, use the platform, make transactions, or contact our support team. We also collect certain data automatically through your use of the 3rcom website and mobile platform. The categories of personal data we collect are as follows:

2.1 Identity & Contact Data

• Full legal name as it appears on your CNIC or passport;
• Date of birth (used to verify the 21+ age requirement);
• Pakistani CNIC number or passport number;
• Residential address (city, province, postal code);
• Pakistani mobile phone number;
• Email address.

2.2 Account & Transaction Data

• 3rcom username and encrypted password hash;
• Deposit and withdrawal history, including amounts in PKR, payment method used, timestamps, and transaction reference numbers;
• Betting and gaming history, including bets placed, game results, and wagering activity;
• Bonus claims, promotional participation records, and wagering requirement progress;
• Account balance history and cashier activity logs.

2.3 KYC Verification Documents

• Scanned or photographed copies of government-issued identity documents (CNIC, passport, driving licence);
• Proof of address documentation (utility bills, bank statements);
• Proof of payment method ownership (JazzCash account screenshots, EasyPaisa registration details, bank account statements).

2.4 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, browser type and version;
• Session duration, pages visited, features accessed, and click-path data;
• Device fingerprint data used for fraud detection and duplicate account identification;
• Log files generated by your use of the 3rcom platform.

2. 5 Communications Data

• Records of live chat conversations with 3rcom support agents;
• Email correspondence sent to or received from 3rcom;
• Complaint records, dispute submissions, and their resolutions;
• Survey responses and feedback you voluntarily submit.

3 How We Use Your Personal Data

3rcom uses your personal data only for the purposes described in this Policy. We do not use your data for any purpose that is incompatible with the reason it was originally collected. The primary purposes for which we process your personal data are:

4 Legal Basis for Processing

3rcom processes your personal data only where a valid legal basis exists under applicable data protection law. The legal bases we rely on are:

• Contract Performance: Processing necessary to fulfil the contractual relationship between you and 3rcom, including operating your account, processing transactions, and delivering gaming services;
• Legal Obligation: Processing required to comply with 3rcom's obligations under its international gaming licence, including KYC verification, AML obligations, age verification, and regulatory reporting;
• Legitimate Interests: Processing necessary for 3rcom's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving the user experience, where such interests are not overridden by your fundamental rights;
• Consent: Where you have given explicit consent, such as for receiving marketing communications or promotional notifications. You may withdraw this consent at any time by contacting support or updating your account communication preferences.

Where we rely on consent as a legal basis, withdrawal of consent does not affect the lawfulness of processing carried out prior to that withdrawal. Withdrawing marketing consent will not affect your ability to use the 3rcom platform.

5 Data Sharing & Disclosure

3rcom does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes under any circumstances. We share your personal data only in the following limited circumstances:

5.1 Service Providers & Data Processors

3rcom engages trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These include:

• Payment processors and mobile wallet operators (JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank) for the purpose of processing your PKR deposits and withdrawals;
• Identity verification and KYC service providers for the purpose of verifying CNIC documents and confirming the 21+ age requirement;
• Cloud hosting and infrastructure providers for the purpose of storing platform data securely;
• Customer support platform providers for the purpose of managing live chat and email communications;
• Fraud detection and cybersecurity service providers for the purpose of protecting the platform and its users.

5.2 Regulatory & Legal Disclosure

3rcom may disclose your personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by law, by the terms of 3rcom's international gaming licence, or in connection with the prevention, detection, or investigation of fraud, money laundering, or other criminal activity.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 3rcom's business, your personal data may be transferred to the relevant successor entity, subject to equivalent privacy protections being maintained. You will be notified of any such transfer by email prior to its completion where practicable.

6 Payment Data & PKR Transactions

3rcom processes all transactions in Pakistani Rupees (PKR). When you make a deposit via JazzCash, EasyPaisa, Raast, or a Pakistani bank transfer, the payment is processed through that payment provider's own secure infrastructure. 3rcom receives a transaction confirmation and reference number but does not store your mobile wallet PIN, bank account password, or full account credentials.

Transaction records — including deposit amounts, withdrawal amounts, timestamps, and payment method type — are retained by 3rcom for a minimum of five years in accordance with AML regulatory requirements. These records may be disclosed to 3rcom's licensing authority upon request.

All withdrawals at 3rcom are processed exclusively to the payment method registered in your name, matching your KYC-verified identity. This is a mandatory anti-money laundering control and cannot be waived. Third-party withdrawals are never permitted under any circumstances.

7 Cookies & Tracking Technologies

3rcom uses cookies and similar tracking technologies on the 3rcom.pro website to enable core platform functionality, improve user experience, and support fraud detection. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the operation of the 3rcom platform, including session management, login authentication, and security functions. These cannot be disabled without breaking core platform features;
• Functional Cookies: Remember your preferences such as language settings, last-used payment method, and display preferences to personalise your 3rcom experience;
• Analytics Cookies: Collect anonymised data about how users navigate the 3rcom platform to help us identify and resolve usability issues and improve game and content placement;
• Security & Fraud Detection Cookies: Used alongside device fingerprinting technology to identify suspicious login patterns, detect duplicate account registrations, and flag potentially fraudulent activity.

You can manage non-essential cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 3rcom platform, including the ability to stay logged in or access personalised features. 3rcom does not use third-party advertising cookies or behavioural tracking cookies that share your data with external ad networks.

8 Data Retention

3rcom retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, and licensing obligations. The following retention periods apply:

At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual. Anonymised, aggregated data may be retained indefinitely for statistical and business analytics purposes.

9 Data Security

3rcom implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 3rcom platform is encrypted in transit using industry-standard TLS 1.3 protocols;
• Encrypted Data Storage: Sensitive personal data, including KYC documents and identity information, is encrypted at rest using AES-256 encryption;
• Password Security: Account passwords are never stored in plain text. 3rcom uses bcrypt hashing with a unique salt per account, ensuring passwords cannot be recovered even in the event of a data breach;
• Two-Factor Authentication (2FA): 3rcom offers optional 2FA via one-time codes sent to your registered Pakistani mobile number, adding a second layer of protection to your account login;
• Access Controls: Access to personal data is restricted to 3rcom staff and contractors on a strict need-to-know basis, enforced through role-based access control (RBAC) systems;
• Regular Security Audits: 3rcom's platform and infrastructure undergo regular third-party penetration testing and security audits as required under its international gaming licence;
• Fraud Detection Systems: Automated systems monitor account activity continuously for signs of unauthorised access, suspicious transactions, and account compromise.

Notwithstanding these measures, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights, 3rcom will notify affected users and the relevant regulatory authority as required by applicable data protection obligations.

10 Your Data Rights

As a 3rcom user, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request", including your registered username and a description of your request. 3rcom will respond within 30 calendar days.

11 Children & Minors

The 3rcom platform is strictly intended for adults aged 21 years and above. 3rcom does not knowingly collect personal data from any individual under the age of 21. The 21+ age requirement is enforced through mandatory CNIC-based identity verification during the account registration process.

If 3rcom becomes aware that personal data has been collected from an individual under the age of 21, that account will be immediately and permanently closed, all associated data will be securely deleted (subject to any mandatory legal retention obligations), and the matter will be reviewed in accordance with 3rcom's responsible gaming and child protection procedures.

If you believe that a person under the age of 21 has registered a 3rcom account, please contact us immediately at [email protected]. 3rcom treats all such reports as priority matters and will investigate and respond within 24 hours.

12 International Data Transfers

3rcom operates under an international gaming licence and uses cloud infrastructure and service providers that may be located outside Pakistan. When your personal data is transferred outside Pakistan, 3rcom ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy.

Safeguards for international data transfers include:

• Contractual data processing agreements incorporating standard data protection clauses binding third-party processors to equivalent data protection standards;
• Transfers to service providers operating in jurisdictions with recognised data protection frameworks;
• Where required, explicit consent obtained from you prior to any transfer that cannot be adequately protected by contractual safeguards alone.

3rcom's primary data hosting infrastructure is located in jurisdictions subject to comprehensive data protection regulation. Pakistani player data is not transferred to jurisdictions without adequate data protection standards without appropriate safeguards being in place.

13 Updates to This Privacy Policy

3rcom reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our platform features. The current version of this Policy, together with its effective date and version number, is always available at 3rcom.pro/privacy-policy.

Where changes are material — meaning they substantively affect your rights or how your data is used — 3rcom will notify you by email to your registered address and via a prominent notice on the platform at least 14 days before the changes take effect. Non-material changes, such as typographical corrections or clarifications that do not alter your rights, may take effect immediately.

Your continued use of the 3rcom platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you must cease using the platform and may request account closure in accordance with the 3rcom Terms & Conditions.

14 Contact & Data Requests

For all privacy-related enquiries, data rights requests, or concerns about how 3rcom handles your personal data, please contact our Data Protection team using the following channels:

• Email: [email protected] — use the subject line "Privacy Enquiry" or "Data Rights Request";
• Live Chat: Available 24/7 at 3rcom.pro — select "Account & Privacy" from the support menu.

3rcom commits to acknowledging all privacy-related requests within 48 hours and providing a substantive response within 30 calendar days. In complex cases where additional time is required, we will notify you within the 30-day window and provide an extended response date.

If you are not satisfied with how 3rcom has handled your data rights request or privacy complaint, you have the right to escalate the matter to the relevant supervisory authority or independent data protection regulator in the applicable jurisdiction. Details of the applicable supervisory authority can be provided upon request.