fly33 Privacy Policy

1. Introduction

fly33 ("we", "us", "our") operates the online gaming reference platform accessible at https://fly33.cam (the "Platform"). We are committed to protecting the personal data of every individual who visits or registers on the Platform, including the many players we serve across Pakistan — from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar.

This Privacy Policy ("Policy") sets out how fly33 collects, uses, stores, shares and protects your personal data when you use the Platform. It also explains your rights in relation to that data and how to exercise them.

By accessing the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with the practices described herein, please discontinue use of the Platform immediately. This Policy is incorporated by reference into our Terms & Conditions and should be read alongside them.

2. Definitions

The following definitions apply throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject").
• "Processing" means any operation performed on personal data, including collection, storage, use, transmission and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data — fly33 in this context.
• "Data Processor" means any third party that processes personal data on behalf of the Data Controller under instruction.
• "User" means any individual who accesses, browses, registers on or uses the Platform.
• "KYC" means Know Your Customer — identity verification required prior to enabling financial transactions.
• "AML" means Anti-Money Laundering compliance procedures required to detect and prevent financial crime.
• "Cookie" means a small text file placed on your device by a website to enable certain functionality or track usage.
• "Sensitive Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, genetic data, biometric data or health information.

3. Data Controller

fly33 is the Data Controller responsible for the personal data collected through this Platform. For all matters relating to data privacy, including subject access requests, correction requests, deletion requests and general enquiries, please contact us at the email address provided in Section 15 of this Policy.

Where fly33 engages third-party Data Processors (such as payment gateway providers, identity verification services or analytics platforms), appropriate data processing agreements are in place to ensure that your data is handled in accordance with applicable data protection standards.

4. Data We Collect

fly33 collects personal data through several channels, including account registration, KYC verification, payment processing, Platform usage and support interactions. The categories of personal data we may collect include:

fly33 does not intentionally collect Sensitive Data as defined in Section 2, unless required for specific AML or responsible-gambling purposes (for example, health information provided voluntarily in the context of a self-exclusion request).

5. How We Use Your Data

Your personal data is used for the following specific purposes:

• Account Management: Creating, maintaining and securing your registered account.
• Identity Verification (KYC): Confirming your identity and age in compliance with operator requirements and anti-fraud obligations.
• AML Compliance: Monitoring transactions and account behaviour to detect, prevent and report suspected money laundering or financial crime.
• Payment Processing: Facilitating deposits and withdrawals through your chosen payment method, which may include familiar Pakistani payment references such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah. These providers process your transaction data under their own privacy policies.
• Responsible Gambling Monitoring: Identifying patterns that may indicate problem gambling behaviour, and applying limits or interventions where appropriate.
• Platform Security: Detecting and preventing unauthorised access, fraud and abuse.
• Customer Support: Responding to your enquiries, resolving disputes and processing feedback.
• Service Improvement: Analysing aggregated usage data to improve Platform features, navigation and content quality.
• Legal Obligations: Complying with applicable laws, regulations and licensing conditions, including responding to lawful requests from competent authorities.
• Communications: Sending essential account notifications, policy updates and security alerts. Marketing communications are only sent with your explicit opt-in consent.

6. Legal Basis for Processing

fly33 processes personal data only where a valid legal basis exists. Depending on the nature of the processing activity, we rely on one or more of the following legal bases:

1. Performance of a Contract: Processing necessary to create and manage your account, process payments and deliver the services you have requested.
2. Legal Obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements and licensing obligations.
3. Legitimate Interests: Processing necessary for Platform security, fraud prevention, service improvement and responsible gambling monitoring — where these interests are not overridden by your rights.
4. Consent: Processing for which you have provided explicit, informed and freely given consent — such as optional marketing communications. Consent may be withdrawn at any time.

7. Data Sharing & Disclosure

fly33 does not sell, rent or trade your personal data to third parties. We may, however, share your personal data with third parties in the following limited circumstances:

• Service Providers: Identity verification services, payment processors, hosting providers and analytics platforms that process data on our behalf as Data Processors, subject to binding contractual obligations.
• Gaming Operators: Where the Platform connects you to an associated gaming operator, that operator will process your data independently under their own privacy policy and licensing obligations.
• Regulatory Authorities: Where required by law, court order or regulatory direction, fly33 will disclose personal data to competent authorities. We are not required to notify you in advance where legally prohibited from doing so.
• AML / Fraud Prevention Agencies: Where we are obliged or permitted to disclose data to anti-fraud or AML organisations for the prevention of financial crime.
• Business Transfers: In the event of a merger, acquisition or sale of assets, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.

8. International Data Transfers

fly33 may process or store personal data on servers located outside Pakistan. Where data is transferred internationally, we take appropriate safeguards to ensure that your personal data continues to receive adequate protection, including:

• Contractual clauses requiring third-party recipients to protect data to a standard equivalent to this Policy.
• Selection of processors in jurisdictions that maintain adequate data protection frameworks.
• Encryption of data in transit and at rest during cross-border transfers.

9. Data Retention

fly33 retains personal data for the period necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. General retention guidelines are as follows:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, to satisfy AML record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years from the date of verification, or longer where required by applicable regulation.
• Transaction Records: Retained for a minimum of five (5) years from the date of transaction.
• Support Communications: Retained for three (3) years from the date of resolution.
• Marketing Consent Records: Retained for three (3) years from the date of consent, or until consent is withdrawn.
• Technical / Log Data: Typically retained for twelve (12) months and then securely deleted or anonymised.

When personal data is no longer required, it is securely deleted or rendered permanently anonymous in a manner that prevents reconstruction.

10. Cookies & Tracking Technologies

fly33 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file stored on your device that allows the Platform to recognise returning visitors and maintain session state.

Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function correctly — including session management, security tokens and login persistence. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Functionality Cookies: Remember your preferences (such as language selection or display settings) to improve your experience across sessions.
• Security Cookies: Help detect and prevent fraudulent activity, bot access and account takeover attempts.

Third-party advertising cookies are not placed on the Platform without your explicit consent. You may control cookie preferences through your browser settings. Disabling strictly necessary cookies may impair Platform functionality.

11. Your Rights

Depending on applicable data protection law, you may hold some or all of the following rights in relation to your personal data. To exercise any right, submit a written request to [email protected]. Requests are typically processed within 30 days, subject to identity verification.

12. Minors & Age Verification

The fly33 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 or process personal data from individuals under the age of 18.

All accounts are subject to age verification as part of the KYC process. Where we discover, or have reasonable grounds to believe, that an account holder is under the minimum required age, we will immediately suspend the account, flag the matter for review and delete any associated personal data that is not required for regulatory record-keeping purposes.

If you believe a minor has registered on the Platform, please contact us immediately at [email protected] (displayed as plain text — not a clickable link).

13. Security Measures

fly33 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration or disclosure. These include:

• TLS/SSL encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Role-based access controls limiting data access to authorised personnel only.
• Regular security assessments and vulnerability testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative system access.
• Incident response procedures for detecting and responding to data security events.

While we take these measures seriously, no security system is completely impenetrable. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant supervisory authorities as required by applicable law.

14. Changes to This Policy

fly33 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. The "Last updated" date at the top of this page will be revised with each update.

Where changes are material, we will notify registered users by email and/or through a prominent notice on the Platform. Your continued use of the Platform following notification of changes constitutes acceptance of the updated Policy. If you do not accept the revised Policy, you must discontinue use of the Platform and request account closure.

15. Contact Us

For any questions, concerns or requests relating to this Privacy Policy — including data subject rights requests — please contact the fly33 Data Privacy team. All enquiries are handled in English and Urdu by our 24/7 support team.

Email: [email protected] (displayed as plain text — not a clickable link)

We aim to acknowledge all privacy-related requests within 5 business days and resolve them within 30 days. Where a request is particularly complex or voluminous, we may extend this period by a further 30 days, with notice to you.