1. Who We Are
This Privacy Policy applies to the 345com platform, accessible at 345com.app. When we refer to "345com", "we", "us", or "our" in this document, we mean the operator responsible for managing the 345com platform and all associated services. When we refer to "you" or "your", we mean any individual who accesses 345com, registers an account, or uses any of the platform's features.
345com operates under a valid gaming licence and is subject to the data protection obligations that come with that licence. This policy reflects those obligations as well as our own commitment to transparency with Pakistani players who use the platform.
For any data-related enquiries, questions, or requests, you can contact the 345com data team at support@345com.app with "Privacy" in the subject line.
2. What Data We Collect
345com collects personal data in the following categories, all of which are described in detail in the overview section above:
- Identity and contact data — name, date of birth, mobile number, email, and identification document details provided during registration or verification.
- Payment data — mobile wallet account numbers, bank account details, and card information (stored in tokenised form only) used to process PKR deposits and withdrawals.
- Transaction and gaming data — a complete record of financial transactions and gameplay activity on the 345com platform, including bet histories, settlement records, and balance movements.
- Device and technical data — IP address, device type, browser information, and session logs collected automatically when you access 345com.
- Communications data — records of support interactions, complaints, and any correspondence between you and the 345com team.
- Marketing preference data — your opt-in or opt-out status for various 345com communication channels.
We do not collect sensitive personal data categories such as biometric data, health information, or political/religious affiliations.
3. How We Collect Your Data
345com collects personal data through the following channels:
- Direct submission — when you register an account, complete identity verification, make a deposit or withdrawal, contact support, or respond to a survey.
- Automated collection — through the platform itself as you navigate, play games, and place bets. This includes session data, clickstream data, and error logs.
- Cookies and tracking technologies — as described in Section 7, 345com uses cookies to manage your session, remember preferences, and collect anonymised usage analytics.
- Third-party verification services — if you submit identity documents for KYC (Know Your Customer) verification, those documents may be processed by a regulated third-party verification provider on our behalf.
- Payment processors — transaction data flows between your chosen payment method (Easypaisa, JazzCash, etc.) and 345com via encrypted payment gateway connections.
4. Why We Use Your Data
The table below sets out the specific purposes for which 345com processes personal data, along with the type of data involved in each purpose:
| Purpose |
Data Types Used |
| Creating and managing your 345com account |
Identity, contact, device data |
| Processing PKR deposits and withdrawals |
Identity, payment, transaction data |
| Age and identity verification (KYC compliance) |
Identity data, document scans |
| Settling bets and game outcomes |
Transaction and gaming data |
| Fraud detection and prevention |
Device, transaction, identity data |
| Anti-money laundering (AML) compliance |
Identity, payment, transaction data |
| Customer support and dispute resolution |
Identity, communications, gaming data |
| Responsible gaming monitoring |
Gaming data, transaction data |
| Platform security and technical maintenance |
Device and technical data |
| Sending promotional communications (with consent) |
Contact data, marketing preferences |
| Analytics and platform improvement |
Anonymised device and usage data |
| Legal and regulatory reporting |
Identity, transaction data |
5. Legal Basis for Processing
345com processes personal data under the following legal bases:
- Contract performance — most data processing on 345com is necessary to fulfil our contract with you as a registered player. This includes account management, payment processing, and game settlement.
- Legal obligation — some processing is required to comply with our gaming licence conditions, anti-money laundering regulations, and data retention laws. This includes KYC verification and transaction record-keeping.
- Legitimate interests — 345com processes certain data — such as device information for fraud detection and anonymised analytics for platform improvement — under its legitimate interest in operating a secure, functional gaming platform.
- Consent — marketing communications are sent only to players who have specifically opted in. You can withdraw this consent at any time through your account settings or by contacting support@345com.app.
6. Sharing Your Data
345com does not sell personal data. We share data with third parties only in the following limited circumstances:
- Payment processors — when you make a deposit or request a withdrawal, relevant payment data is shared with your chosen payment provider (Easypaisa, JazzCash, NayaPay, SadaPay, your bank, or your card issuer) to facilitate the transaction.
- Identity verification providers — if you are required to submit identity documents, those documents are processed by a regulated KYC verification service that acts as a data processor under contract with 345com.
- Regulatory authorities — 345com will disclose personal data to relevant regulatory bodies, law enforcement agencies, or courts when required to do so by law, court order, or our gaming licence conditions.
- Technology and infrastructure providers — cloud hosting, analytics, and platform security tools used by 345com involve third-party providers who process data as processors under strict data processing agreements.
Any third party that processes data on behalf of 345com is bound by contractual obligations to handle that data only as instructed by 345com and to maintain appropriate security standards.
7. Cookies and Tracking Technologies
345com uses cookies and similar technologies to make the platform function correctly and to understand how it is used. The main types of cookies we deploy are:
- Essential cookies — required for the platform to function. These manage your login session, remember your language preference, and maintain your bet slip state. These cannot be turned off without disabling core platform functionality.
- Analytics cookies — anonymised data on how players navigate the 345com platform. This helps us identify which features are useful and which pages cause difficulty. Analytics data is aggregated and does not identify individual players.
- Security cookies — used to detect and prevent fraudulent login attempts and bot activity on the 345com platform.
You can manage cookie preferences through your browser settings. Blocking essential cookies will affect your ability to use core platform features including login.
8. Data Retention
345com retains personal data for as long as it is necessary for the purpose for which it was collected, subject to any legal minimum retention periods imposed by our operating licence or applicable regulations:
- Account and transaction data — retained for a minimum of 5 years following account closure, as required under anti-money laundering regulations.
- KYC verification data — retained for the duration of the account relationship plus 5 years post-closure.
- Support and communications data — retained for 3 years following the resolution of the relevant interaction.
- Marketing preference data — retained until you withdraw consent or close your account, whichever is earlier.
- Technical and device logs — retained for 12 months for security and fraud analysis purposes.
After the applicable retention period, data is securely deleted or anonymised so it can no longer be associated with an individual player.
9. Security Measures
345com implements technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or alteration. Key security measures include:
- 256-bit SSL encryption on all data transmitted between your device and the 345com platform.
- Payment card data stored in tokenised form only — full card numbers are never stored on 345com servers.
- Access to personal data restricted to authorised 345com personnel who need it to carry out their role.
- Regular security testing and vulnerability assessments of the 345com platform infrastructure.
- Two-factor authentication available for all player accounts.
- Incident response procedures in place for suspected data breaches, including player notification within required regulatory timeframes where a breach is likely to result in risk to your rights.
10. International Data Transfers
As an online gaming platform, 345com may store or process data on servers located outside Pakistan. Where personal data is transferred internationally, 345com ensures that appropriate safeguards are in place — including contractual obligations on the receiving party equivalent to those required under applicable data protection frameworks. If you would like details about the specific safeguards applicable to any particular transfer, you can request this by emailing support@345com.app.
11. Your Rights Over Your Data
As a 345com player, you have the following rights in relation to your personal data. Requests can be submitted by emailing support@345com.app with "Data Rights Request" in the subject line. 345com will respond within 30 days.
