Privacy Policy

This Privacy Policy ("Policy") is published by 365com, the operator of the website located at https://365com.cam/ ("Platform", "we", "us", "our"). It describes how 365com collects, processes, stores, shares and protects personal data relating to users of the Platform ("you", "your", "User").

365com is an English-language online gaming information and entertainment platform serving users primarily based in Pakistan. We are committed to processing personal data in a lawful, fair and transparent manner, in accordance with applicable data protection legislation and international best practices.

By accessing or using the Platform, you acknowledge that you have read and understood this Policy and consent to the data processing practices described herein. If you do not agree with any part of this Policy, you must discontinue your use of the Platform.

The following terms carry the meanings defined below throughout this Privacy Policy:

• "Personal Data" — Any information relating to an identified or identifiable natural person, including name, email address, IP address, device identifiers and behavioural data.
• "Processing" — Any operation or set of operations performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" — The entity that determines the purposes and means of processing Personal Data. For this Platform, the Data Controller is 365com.
• "Data Processor" — Any third party that processes Personal Data on behalf of 365com under a contractual arrangement.
• "Consent" — A freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data.
• "Cookies" — Small text files placed on your device by the Platform to store session information, preferences and analytical data.
• "Third Party" — Any natural or legal person other than you and 365com who may receive Personal Data under the terms of this Policy.

365com acts as the Data Controller for all Personal Data processed in connection with the Platform. As Data Controller, we are responsible for ensuring that your Personal Data is handled in accordance with this Policy and applicable data protection law.

If you have any questions about how your Personal Data is processed, or if you wish to exercise any of your data rights, you may contact our Data Protection contact using the details provided in Section 16 of this Policy.

365com collects Personal Data through several channels. The categories of data we collect, and the means by which we collect them, are set out below.

4.1 Data You Provide Directly

When you register for an Account, contact our support team or interact with Platform features, you may provide us with:

• Full name and username.
• Email address.
• Date of birth (for age-verification purposes).
• City or region within Pakistan (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar) — used solely to contextualise content.
• Communications submitted via our support channels, including the content and timestamp of each message.
• Any additional information you voluntarily provide in account profile fields.

4.2 Data Collected Automatically

When you visit the Platform, certain data is collected automatically by our systems and third-party analytics tools:

4.3 Data from Third Parties

We may receive limited Personal Data from third-party service providers who assist with Platform operations, such as identity verification partners and fraud detection services. Such data is handled in accordance with this Policy and applicable processor agreements.

We process your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to provide the services you have requested, including account management and technical support.
• Consent: Where you have given explicit consent to a specific processing activity, such as receiving marketing communications or accepting non-essential cookies.
• Legitimate Interests: Processing necessary for our legitimate business interests — such as fraud prevention, platform security and analytics — where those interests are not overridden by your rights.
• Legal Obligation: Processing required to comply with applicable legal or regulatory obligations, including age verification and anti-money laundering checks conducted by or on behalf of licensed Operators.

365com processes your Personal Data for the following specific purposes only. We do not use your data for any purpose incompatible with those listed below:

1. Account Management: Creating, maintaining and securing your user account, including authentication and password reset processes.
2. Platform Personalisation: Tailoring content, recommendations and layout preferences based on your account settings and usage patterns — for example, prioritising cricket or PSL betting content for users who frequently access those sections.
3. Customer Support: Responding to your enquiries, resolving technical issues and managing responsible gambling requests, including self-exclusion notifications.
4. Security and Fraud Prevention: Detecting, investigating and preventing fraudulent, abusive or illegal activity on the Platform, including multi-account detection and bot prevention.
5. Analytics and Improvement: Analysing aggregated, anonymised usage data to understand how the Platform is used and to identify areas for improvement in content, performance and user experience.
6. Legal Compliance: Fulfilling obligations under applicable law, including cooperation with regulatory bodies, law enforcement agencies and court orders where legally required.
7. Communications: Sending transactional communications such as account confirmations and security alerts. Marketing communications are sent only with your explicit prior consent and can be withdrawn at any time.

365com does not sell, rent or trade your Personal Data to any third party. We share Personal Data only in the limited circumstances described below, and only to the extent strictly necessary:

7.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process data on our behalf under contractual data processing agreements. These providers are permitted to use your data only for the purposes we specify and must implement appropriate security measures. Categories of providers include:

• Cloud hosting and infrastructure providers.
• Analytics and performance monitoring tools.
• Customer support software providers.
• Identity verification and age-check services.
• Fraud detection and cybersecurity providers.

7.2 Legal Authorities

We may disclose Personal Data to law enforcement agencies, regulatory bodies or courts where required to do so by applicable law, a valid court order or a legally binding governmental request. We will notify you of such disclosure where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of 365com's assets, Personal Data held by us may be transferred to the acquiring entity. You will be notified of any such transfer and your rights under this Policy will continue to apply.

365com uses cookies and similar tracking technologies to operate the Platform effectively and to understand how users interact with our content. The following categories of cookies are in use:

You can manage your cookie preferences through your browser settings or via our cookie preference centre when it is presented to you. Please note that disabling strictly necessary cookies may prevent certain Platform features from functioning correctly.

We retain Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention framework is as follows:

• Account Data: Retained for the duration of your Account's active status and for a period of up to five (5) years following Account closure, to comply with legal and audit obligations.
• Support Communications: Retained for up to three (3) years from the date of the last communication, to support dispute resolution and service improvement.
• Usage and Analytics Data: Anonymised or aggregated data may be retained indefinitely for statistical and research purposes. Personally identifiable usage data is retained for up to two (2) years.
• Cookie Data: Session cookies are deleted when you close your browser. Persistent cookies are retained for the durations specified in Section 8.
• Legal Compliance Data: Data retained for legal compliance purposes (e.g., age verification records) is held for the period required by the applicable regulation.

At the end of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised. You may request early deletion of your data subject to the conditions described in Section 12.

365com implements a layered approach to data security, incorporating both technical and organisational measures designed to protect Personal Data against unauthorised access, accidental loss, destruction or disclosure. Our security measures include:

• Encryption: All data transmitted between your browser and our servers is protected using TLS (Transport Layer Security) encryption. Sensitive data at rest is encrypted using industry-standard algorithms.
• Access Controls: Access to Personal Data is restricted on a need-to-know basis. All internal access is subject to authentication, role-based permissions and audit logging.
• Infrastructure Security: Our hosting infrastructure is maintained by reputable cloud providers with established security certifications. Environments are regularly patched and vulnerability-scanned.
• Incident Response: We maintain a documented data breach response plan. In the event of a breach affecting your data, we will notify you and any applicable regulatory authority within the timeframes required by law.
• Staff Training: All personnel with access to Personal Data receive regular data protection training and are bound by confidentiality obligations.

Your Personal Data may be transferred to, and processed in, countries other than Pakistan in connection with our use of third-party service providers. Such countries may have data protection laws that differ from those applicable in Pakistan.

Where we transfer Personal Data internationally, we take steps to ensure that appropriate safeguards are in place, including:

• Executing data processing agreements with all international processors that incorporate appropriate data protection clauses.
• Transferring data only to processors operating in jurisdictions with recognised adequate data protection frameworks where possible.
• Implementing additional technical safeguards — such as encryption — where transfers involve jurisdictions with lower regulatory standards.

If you would like further information about international transfers of your Personal Data or the safeguards we have put in place, please contact us at [email protected].

Subject to applicable law and certain conditions, you have the following rights in relation to your Personal Data held by 365com. To exercise any of these rights, please contact us in writing at [email protected]:

We aim to respond to all valid data rights requests within thirty (30) calendar days. In complex cases, this period may be extended by a further two months with prior notice to you. We may request identity verification before processing a request to protect against unauthorised disclosure.

The Platform is strictly intended for individuals aged 18 years and over — or the higher minimum age required by the applicable operator or license jurisdiction. 365com does not knowingly collect Personal Data from minors.

If we become aware that we have inadvertently collected Personal Data from a person under the applicable minimum age, we will take immediate steps to delete that data from our systems and to close the associated Account. Any bonuses or balances associated with such an Account will be forfeited in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor under your care has created an Account on 365com or provided us with Personal Data without your consent, please contact us immediately at [email protected]. Please mark your message "URGENT: Minor Account Concern".

The Platform may contain references to or descriptions of third-party services, including licensed Operators whose products are discussed in our content. 365com does not control the data practices of any third-party website or service, and this Policy applies solely to data collected by 365com on this Platform.

If you navigate to a third-party website from a link or reference on 365com, we encourage you to review the privacy policy of that website independently. 365com accepts no responsibility for the privacy practices of third-party operators, service providers or any other entity not under our direct control.

365com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements or platform features. All changes will be published on this page with an updated effective date.

Where changes are material — that is, where they significantly affect your rights or how we process your Personal Data — we will notify registered users by email or through a prominent notice on the Platform prior to the changes taking effect.

Your continued use of the Platform after any revised Policy is published constitutes your acceptance of the updated terms. We recommend reviewing this page periodically to stay informed of any updates.

If you have any questions, concerns or requests regarding this Privacy Policy or the way in which 365com processes your Personal Data, please contact us using the details below. All communications must be in English and should include sufficient detail to allow us to identify your Account and understand your request.

Privacy & Data Protection Contact:
[email protected] — please use the subject line "Privacy Request" (plain text address — not a clickable link).

Support Hours: 24 hours a day, 7 days a week.

Acknowledgement: We will acknowledge all privacy requests within two (2) business days and aim to provide a substantive response within thirty (30) calendar days, subject to the complexity of your request.

We also encourage you to review our related policies for a full understanding of how 365com operates:

• Terms & Conditions — governs your use of the Platform.
• Responsible Gambling Policy — outlines our commitments and tools for safe gambling.