Privacy Policy

This Privacy Policy ("Policy") is issued by jjjt ("Platform", "Operator", "we", "us", "our") and applies to all personal data collected, processed, stored or transmitted in connection with your registration for, and use of, the jjjt online betting and casino platform accessible at https://jjjt.cam, including all associated subdomains, mobile-optimised interfaces, and support services (collectively, the "Service").

We are committed to processing personal data in a lawful, fair and transparent manner, in accordance with applicable data protection law in the jurisdiction in which jjjt holds its operating license, and with recognised international data protection standards where those standards afford greater protection to the data subject.

By creating an account and using the Service, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein, to the extent that such processing is based on consent. Where processing is based on legitimate interest, legal obligation or contract performance, your use of the Service indicates your awareness of such processing.

This Policy should be read in conjunction with jjjt's Terms & Conditions and Responsible Gambling Policy, which together govern your use of the Service.

In this Policy, the following terms carry the meanings set out below:

• "Personal Data" — any information relating to an identified or identifiable natural person ("data subject"). An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data or one or more factors specific to their identity.
• "Processing" — any operation performed on Personal Data, including collection, recording, organisation, storage, adaptation, retrieval, use, disclosure, dissemination, erasure or destruction, whether by automated means or otherwise.
• "Data Controller" — the entity that determines the purposes and means of the Processing of Personal Data. jjjt is the Data Controller in respect of Personal Data collected through the Service.
• "Data Processor" — any third party that processes Personal Data on behalf of jjjt, under jjjt's instruction and pursuant to a data processing agreement.
• "KYC" — Know Your Customer; the identity verification process requiring Users to submit acceptable documentation to confirm their identity and eligibility.
• "Cookies" — small text files or similar tracking technologies placed on your device by the Platform or third-party services integrated into the Platform.
• "Sensitive Personal Data" — a special category of Personal Data that warrants heightened protection, including data relating to racial or ethnic origin, health, biometric data used for identification, or financial source-of-wealth information where collected for AML purposes.

jjjt is the Data Controller responsible for the Personal Data collected through the Service. The Operator's registered details, including jurisdiction of incorporation and licensing authority, are available in the Platform's Help Centre and licensing information footer.

For all data protection enquiries, subject access requests and complaints relating to the processing of your Personal Data, please contact us using the details provided in Clause 15 of this Policy.

jjjt collects Personal Data through multiple channels: directly from you when you register and use the Service; automatically through your interaction with the Platform; and, where necessary, from third-party sources such as identity verification providers, fraud prevention services and payment processors.

jjjt processes your Personal Data only where a lawful basis for doing so exists. The principal purposes for which we process Personal Data, and the corresponding legal basis, are set out below:

• Account registration and operation — Processing necessary for the performance of the contract between you and jjjt (the Terms & Conditions). Without this processing, we cannot open or maintain your Account.
• Identity verification (KYC) — Processing necessary to comply with our legal obligations under applicable anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
• Transaction processing — Processing necessary for contract performance. This includes recording deposits, processing withdrawals and maintaining accurate financial records of your Account balance.
• Fraud prevention and security — Processing based on our legitimate interests in detecting, investigating and preventing fraudulent activity, abuse of the Platform and financial crime.
• Responsible gambling monitoring — Processing based on our legal obligations and legitimate interests in identifying potentially problematic gambling behaviour and applying appropriate protective interventions.
• Regulatory compliance and reporting — Processing necessary to comply with legal obligations, including AML/CTF reporting requirements to relevant authorities.
• Customer support — Processing based on contract performance and our legitimate interests in providing effective support and resolving disputes.
• Platform improvement and analytics — Processing based on our legitimate interests in understanding how the Platform is used in order to improve its functionality and user experience. Analytics data is aggregated or pseudonymised where possible.
• Direct marketing — Processing based on your consent, where you have opted in to receive promotional communications from jjjt. You may withdraw consent at any time by updating your account preferences or contacting support.

jjjt does not sell or rent your Personal Data to any third party for their own commercial purposes. We may share your Personal Data with third parties in the following limited circumstances:

• Identity verification providers: Specialist KYC and AML screening services that verify the identity and eligibility of our users. These providers act as Data Processors under binding data processing agreements.
• Payment processors: Payment technology providers that facilitate deposits and withdrawals. Where payment methods familiar to Pakistani users — such as Easypaisa, JazzCash, Raast or traditional bank transfers via HBL, UBL, Meezan Bank or Bank Alfalah — are available in the cashier, the relevant payment processor will receive the minimum transaction data required to execute and record the transaction. These providers are independent data controllers in respect of their own data processing activities and are subject to their own privacy policies.
• Gaming software providers: Third-party game studios and live casino providers whose games are integrated into the Platform. These providers may receive pseudonymised session data necessary for game operation and fair-play verification.
• Fraud and security services: Third-party fraud detection platforms that analyse transaction and behavioural data to identify and prevent abuse.
• Regulatory and law enforcement authorities: Where we are legally required to disclose Personal Data to a regulatory body, court, law enforcement agency or other governmental authority, we will do so in accordance with applicable law. Where permitted by law, we will notify you of such disclosure.
• Professional advisers: Legal, financial and audit professionals engaged by jjjt, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, restructuring or sale of all or part of jjjt's business, Personal Data held by jjjt may be transferred to the successor entity, subject to equivalent data protection safeguards.

All Data Processors engaged by jjjt are required to process Personal Data only on jjjt's instructions and in accordance with a data processing agreement that imposes obligations at least equivalent to those under applicable data protection law.

jjjt operates internationally and your Personal Data may be transferred to, and processed in, countries other than your country of residence. In particular, our servers, Data Processors and technology partners may be located in jurisdictions outside Pakistan and outside the Operator's primary licensing jurisdiction.

Where Personal Data is transferred to a country that does not offer an equivalent level of data protection to that provided in the Operator's licensing jurisdiction, jjjt will implement appropriate safeguards to protect your data, which may include:

• Standard contractual clauses approved by the applicable data protection authority;
• Binding corporate rules where the transfer is between entities within the same corporate group;
• Transfers to jurisdictions that have been assessed as providing an adequate level of protection; or
• Other recognised safeguards as permitted under applicable data protection law.

We retain your Personal Data for no longer than is necessary to fulfil the purposes described in this Policy, or as required by applicable law. The principal retention periods applied by jjjt are as follows:

• Account and transaction records: Retained for a minimum of five (5) years following account closure, or longer where required by AML/CTF regulations applicable in the Operator's licensing jurisdiction.
• KYC documentation: Retained for a minimum of five (5) years following the completion of the relevant transaction or the closure of the Account, whichever is later, in accordance with AML obligations.
• Communication records: Support chat transcripts and email correspondence retained for a minimum of three (3) years from the date of the communication.
• Technical and analytics data: Aggregated or pseudonymised analytics data may be retained indefinitely. Raw technical data (e.g., server logs) is retained for a maximum of twelve (12) months unless required for fraud investigation or legal proceedings.
• Marketing data: Retained until you withdraw consent or for a maximum of two (2) years from your last active engagement, whichever is earlier.

Following the applicable retention period, Personal Data will be securely deleted or irreversibly anonymised, subject to any ongoing legal obligation that requires continued retention.

jjjt implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data fields (including password hashes and financial data) at rest;
• Role-based access controls ensuring that staff access to Personal Data is limited to that which is necessary for their specific function;
• Two-factor authentication options available to all Users and mandatory for privileged staff access;
• Regular internal and third-party security assessments and penetration testing;
• Incident response and data breach notification procedures designed to ensure timely reporting to the applicable supervisory authority and affected data subjects where required by law.

Notwithstanding the above, no method of data transmission or storage is completely secure. jjjt cannot guarantee absolute security of your Personal Data. You are responsible for keeping your Account credentials confidential and for immediately notifying us if you suspect unauthorised access to your Account.

jjjt uses cookies and similar tracking technologies to operate and improve the Platform, to maintain session integrity, and to collect analytical data about how the Platform is used. The principal categories of cookies used are:

• Essential cookies: Strictly necessary for the operation of the Platform, including session management, security and fraud prevention. These cookies cannot be disabled without materially impairing the functionality of the Service.
• Functional cookies: Used to remember your preferences and settings (such as language preference and responsible gambling tool configurations) to enhance your experience.
• Analytical cookies: Used to collect anonymised or pseudonymised data about how users interact with the Platform, including page views, session durations and feature usage patterns, to inform Platform improvements.
• Marketing cookies: Where you have consented, used to deliver relevant promotional content and to measure the effectiveness of our marketing activities. You may withdraw consent to marketing cookies at any time.

You can control the use of non-essential cookies through the Cookie Preference Centre accessible via the Platform's cookie consent banner on your first visit, and subsequently through your browser settings. Disabling essential cookies may prevent the Platform from functioning correctly.

The Service is strictly intended for adults aged 18 years or older — or the higher minimum age required by the applicable operator license jurisdiction. jjjt does not knowingly collect or process Personal Data relating to persons below the applicable minimum age.

Age verification is conducted as part of the KYC process. Where jjjt becomes aware that Personal Data has been collected from a person below the minimum age, such data will be deleted promptly and the associated Account will be closed. Any winnings generated by an underage Account will be forfeited.

If you are a parent or guardian and believe that your child has registered with jjjt, please contact our support team immediately using the details in Clause 15 so that we may take appropriate action.

Subject to applicable data protection law and certain exceptions, you have the following rights in relation to your Personal Data held by jjjt. To exercise any of these rights, please submit a request to us using the contact details in Clause 15.

We will respond to all rights requests within the timeframe required by applicable law, typically within 30 days of receipt. Where a request is complex or numerous, we may extend this period by a further 30 days with prior notification. We may request verification of your identity before processing a rights request to protect against unauthorised disclosure.

jjjt recognises that the majority of its users are based in Pakistan, with significant player communities in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We have written this Policy in clear English to ensure it is accessible and understandable to Pakistani users.

Pakistan does not currently have a comprehensive enacted data protection law equivalent to the GDPR or similar frameworks. jjjt nonetheless commits to applying the data protection principles described in this Policy to Pakistani users' Personal Data on a voluntary basis, as a matter of good practice and respect for our users' privacy expectations.

Payment provider data notice: Where Pakistani users make use of payment methods such as Easypaisa, JazzCash or Raast, or conduct bank transfers via HBL, UBL, Meezan Bank or Bank Alfalah, the relevant payment provider will process transaction data in accordance with their own privacy policies and applicable Pakistani financial regulations, including State Bank of Pakistan directives. jjjt is not responsible for the data processing activities of independent payment providers. Users should review the relevant payment provider's privacy policy before transacting. These payment references are contextual only — none of these providers endorses gambling on the jjjt platform.

Government and regulatory disclosure: jjjt may be required to disclose Personal Data to authorities in its licensing jurisdiction or in other jurisdictions pursuant to applicable law. jjjt is not required to report to Pakistani authorities unless required by a lawful order from a competent authority in a jurisdiction where jjjt has a legal obligation to comply with such an order.

jjjt reserves the right to update and amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the structure of our business. Where amendments are material — meaning they significantly affect the way in which we process your Personal Data or the rights available to you — we will notify you by email to your registered address and/or by a prominent notice on the Platform prior to the amendment taking effect.

The "Effective Date" at the top of this Policy will be updated with each revision. We recommend that you review this Policy periodically to stay informed about how we handle your Personal Data. Your continued use of the Service following the effective date of any amendment constitutes your acknowledgment of the updated Policy.

For all data protection enquiries, subject access requests, rights exercises and privacy-related complaints, please contact jjjt using the details below. All formal correspondence should be submitted in English.

If you are not satisfied with our response to a privacy complaint, you have the right to lodge a complaint with the competent data protection supervisory authority in the Operator's licensing jurisdiction. Contact details for the relevant authority are available on the Platform's Help Centre.

For responsible gambling support, including self-exclusion, deposit limits and cooling-off periods, please visit our Responsible Gambling page.