pa365 Privacy Policy — Your Data, Your Rights

pa365 (referred to in this document as "pa365", "we", "us", or "our") operates the online betting and gaming platform accessible at https://pa365.cam. We respect the privacy of every individual who accesses our Platform, registers an Account, or interacts with our services. This Privacy Policy (the "Policy") sets out the basis on which any personal data we collect from you — or that you provide to us — will be processed.

This Policy applies to all Users of the pa365 Platform, including prospective registrants, registered Account holders, and visitors who browse the Platform without registering. By accessing the Platform or creating an Account, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

pa365 targets users in Pakistan and the Platform is presented in English. This Policy is written in English and, in the event of any conflict between this Policy and a translated version, the English text shall prevail. Nothing in this Policy constitutes legal advice. Pakistani users should seek independent advice regarding their rights under applicable data protection legislation.

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

• "Account" — the registered user profile created upon successful completion of the pa365 registration process.
• "Controller" — the entity that determines the purposes and means of processing personal data. pa365 acts as the Controller in respect of personal data processed under this Policy.
• "Data Subject" — the identified or identifiable natural person to whom personal data relates; in this context, the User of the Platform.
• "KYC" — Know Your Customer, the identity and age verification process required for regulatory compliance, fraud prevention, and AML controls.
• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, device identifiers, and financial data.
• "Processing" — any operation performed on personal data, including collection, storage, use, disclosure, transfer, deletion, or destruction.
• "Platform" — the pa365 website at https://pa365.cam and any associated mobile interfaces or applications.
• "Processor" — a third party that processes personal data on behalf of pa365, under documented instructions and appropriate contractual safeguards.
• "Sensitive Data" — a category of personal data warranting heightened protection, including government-issued identity document numbers (e.g., CNIC), financial account details, and payment credentials.

pa365 collects only the personal data that is necessary for the purposes described in this Policy. The categories of data we collect include:

pa365 collects personal data through the following means:

4.1 Directly From You

• When you complete the Account registration form, including providing your name, date of birth, and contact details.
• When you upload KYC documents through the Platform's secure verification portal.
• When you initiate a deposit or withdrawal through the cashier, including selecting a payment method.
• When you contact our support team via live chat or email, including the content of those communications.
• When you set or amend responsible gambling preferences, such as deposit limits, session timers, or self-exclusion requests.

4.2 Automatically Through Platform Use

• Technical data including IP address, device identifiers, browser type, and session information collected automatically when you access the Platform.
• Behavioural data generated by your betting and gaming activity on the Platform, captured in our transaction and session logging systems.
• Cookie and tracking technology data as described in Section 10 of this Policy.

4.3 From Third Parties

• Identity verification service providers who assist pa365 in validating the authenticity of KYC documents and performing liveness checks.
• Fraud detection and AML screening services that may cross-reference your data against watchlists or databases as required by compliance obligations.
• Payment processors, to the extent necessary to confirm transaction status and reconcile accounts — pa365 does not receive or store full payment credentials such as full card numbers.

pa365 processes your personal data for the following specific purposes:

• Account Management: Creating, maintaining, and administering your Account, including login authentication and account security functions.
• Identity & Age Verification (KYC): Verifying that you meet the minimum age requirement and confirming your identity to satisfy compliance obligations and prevent fraud.
• Transaction Processing: Processing deposits and withdrawals, maintaining transaction records, and reconciling account balances.
• Anti-Money-Laundering (AML) & Fraud Prevention: Monitoring transaction patterns and account behaviour for indicators of financial crime, including money laundering, identity fraud, and account takeover.
• Responsible Gambling Compliance: Operating deposit limits, loss limits, session controls, and self-exclusion systems; monitoring for indicators of problem gambling behaviour and intervening where appropriate.
• Customer Support: Responding to Account queries, processing complaints, and providing technical assistance.
• Platform Improvement: Analysing usage patterns in aggregate to improve Platform functionality, performance, and user experience.
• Legal Compliance: Meeting obligations imposed by the Platform's licensing framework, applicable financial regulations, and other mandatory legal requirements.
• Communications: Sending transactional communications (e.g., deposit confirmations, KYC status updates, withdrawal notifications) and, where you have consented, promotional communications about offers relevant to your account.

pa365 processes personal data on the following legal bases, which vary depending on the specific purpose:

• Contractual Necessity: Processing required to perform the contract you entered into when registering an Account and accepting the Terms & Conditions — including Account management, transaction processing, and KYC verification.
• Legal Obligation: Processing required to comply with mandatory legal obligations under the Platform's licensing framework, AML legislation, and other applicable regulations — including identity verification, transaction monitoring, and record-keeping.
• Legitimate Interests: Processing carried out for pa365's legitimate interests where these are not overridden by your privacy rights — including fraud prevention, platform security monitoring, and aggregate analytics for product improvement.
• Consent: Processing for which you have given specific, informed, and freely given consent — including the sending of optional promotional communications. You may withdraw consent for consent-based processing at any time by contacting support or updating your account notification preferences.

pa365 does not sell your personal data to third-party marketers or advertising networks. We share personal data only in the following limited circumstances:

7.1 Service Providers (Processors)

pa365 engages carefully selected third-party service providers who process personal data on our behalf, under written agreements that require them to maintain appropriate security standards and process data only on our documented instructions. These include: identity verification providers, fraud and AML screening services, cloud hosting and data storage providers, payment processing infrastructure providers, and customer support platform operators.

7.2 Regulatory & Legal Disclosures

pa365 may disclose personal data to regulatory authorities, licensing bodies, law enforcement agencies, or courts where required to do so by law, court order, or lawful regulatory direction. We will notify you of such disclosures where we are legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, asset sale, or restructuring involving pa365, personal data held in our systems may be transferred to the successor entity. Users will be notified of any such transfer in advance where possible, and the successor entity will be bound to honour the commitments in this Policy.

pa365's Platform infrastructure and service providers may be located in jurisdictions outside Pakistan. As a result, your personal data may be transferred to and processed in countries other than your country of residence, including countries whose data protection laws differ from those that may apply in Pakistan.

Where personal data is transferred to a jurisdiction that does not provide an equivalent level of data protection, pa365 will implement appropriate safeguards including data processing agreements containing standard contractual clauses, data security requirements, and transfer impact assessments where relevant.

By using the Platform and accepting this Policy, you acknowledge that your personal data may be transferred internationally as described above, subject to the safeguards pa365 has put in place.

pa365 retains personal data for only as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or licensing obligations. The following general retention principles apply:

• Active Account Data: Personal data associated with an active Account is retained for the duration of the Account's existence and for a minimum period after closure as required by the Platform's licensing framework.
• KYC & AML Records: Identity documents and AML-related records are retained for a period of at least five (5) years following Account closure, or longer where required by applicable law or regulatory direction.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years to satisfy financial record-keeping obligations.
• Support Communications: Customer support chat and email records are retained for up to three (3) years following the close of a support interaction.
• Technical & Log Data: Server logs, session data, and technical records are retained for up to twelve (12) months for security analysis and fraud prevention purposes.

On expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised. Data that has been anonymised is no longer personal data and is not subject to this Policy.

pa365 uses cookies and similar tracking technologies to support Platform functionality, maintain session continuity, and gather aggregate analytics data. The following categories of cookies may be used:

• Strictly Necessary Cookies: Essential for the Platform to function, including login session management and security tokens. These cannot be disabled.
• Functional Cookies: Store your preferences, such as language settings and responsible gambling limit configurations, to improve your experience across sessions.
• Analytics Cookies: Collect aggregate, anonymised data about how users interact with the Platform to support performance improvements. No individual user is identified through analytics data.

pa365 does not deploy third-party advertising or retargeting cookies. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair your ability to use certain Platform features, including logging into your Account.

The personal data collected during the KYC verification process — including CNIC or passport details, proof-of-address documents, and liveness check data — is treated as a category of sensitive data requiring heightened protection. The following specific controls apply to KYC and AML data:

• KYC documents are transmitted and stored exclusively over encrypted channels using HTTPS with 256-bit SSL.
• Access to KYC documentation is restricted to authorised compliance personnel and, where applicable, contracted third-party identity verification providers under strict data processing agreements.
• pa365 does not retain raw identity document images for longer than is required to complete the verification process and to satisfy the mandatory retention period under the Platform's licensing framework.
• You must never share KYC documents through unsecured channels such as WhatsApp, Telegram, or general email. pa365 will only request KYC documents through the official secure verification portal within your Account.

Depending on applicable law in your jurisdiction, you may have the following rights in relation to your personal data held by pa365. To exercise any of these rights, please contact our support team as described in Section 16.

The pa365 Platform is strictly intended for users aged 18 or over (or the higher minimum age required by the operator's licensing jurisdiction). pa365 does not knowingly collect or process personal data from individuals under the age of 18.

If pa365 becomes aware that personal data has been collected from a minor, the relevant Account will be closed immediately, any funds held in that Account will be suspended pending investigation, and the personal data will be securely deleted in accordance with our data retention procedures. Age verification during the KYC process is the primary mechanism pa365 uses to enforce this restriction.

If you believe that a minor has created an Account on pa365, please contact our support team immediately at [email protected].

pa365 implements a range of technical and organisational security measures to protect personal data from unauthorised access, disclosure, alteration, destruction, or loss. These include:

• All data transmitted between your device and the Platform is encrypted using HTTPS with 256-bit SSL/TLS.
• Personal data at rest is stored using encryption controls appropriate to the data category, with KYC and financial data subject to the highest encryption standards.
• Access to personal data is restricted on a strict need-to-know basis, with role-based access controls, audit logging, and regular access reviews.
• pa365's infrastructure undergoes regular security assessments, vulnerability scanning, and, where applicable, penetration testing by qualified third parties.
• pa365 maintains an internal data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights and freedoms, pa365 will notify affected Users and relevant authorities in accordance with applicable obligations and without undue delay.

Whilst pa365 takes every reasonable precaution to protect your personal data, no method of electronic transmission or storage is entirely secure. You are also responsible for maintaining the security of your Account credentials. If you suspect your Account has been compromised, contact pa365 support immediately.

pa365 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When a material change is made, we will provide notice to registered Users via the Platform notification system and/or the registered email address, with at least seven (7) calendar days' advance notice before the revised Policy takes effect.

The current version of this Policy, along with its effective date and version number, will always be accessible at https://pa365.cam/privacy-policy. Your continued use of the Platform after the effective date of any updated Policy constitutes acceptance of the revised terms. If you do not agree with the changes, you must close your Account before the updated Policy takes effect.

For any questions, requests, or complaints relating to this Privacy Policy or the handling of your personal data, please contact pa365 through the following channels:

• Email: [email protected] — plain text address, not a clickable link. Please use the subject line "Privacy Enquiry" for data-related requests.
• Live Chat: Available on the Platform. Typical response time: within minutes during operating hours.
• Response Commitment: Email enquiries related to data rights are acknowledged within five (5) business days.

Support is available in English. Urdu-language assistance may be available on request for Pakistani users who require it.