Privacy Policy — 365gam
Your privacy is important to us. This Privacy Policy explains exactly what personal data 365gam collects, why we collect it, how we use and protect it, and what rights you hold as a user of our platform.
01 Introduction
365gam ("we", "us", "our" or "365gam") operates the website located at https://365gam.cam (the "Platform"). We are committed to protecting and respecting your privacy. 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 by us.
This Policy applies to all users of the Platform worldwide, including users accessing the Platform from Pakistan. By accessing or using the Platform, you acknowledge that you have read, understood and agree to the practices described in this Policy. If you do not agree with this Policy, you must not use the Platform.
This Policy should be read alongside our Terms & Conditions and our Responsible Gambling policy. In the event of any conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail.
365gam is an informational and educational platform — it is not a licensed betting operator and does not process financial transactions on behalf of users. References to operators, payment methods and gambling activities on the Platform are editorial and educational in nature.
02 Definitions
For the purposes of this Privacy Policy, the following terms carry the meanings defined below:
- Personal Data
- Any information relating to an identified or identifiable natural person.
- Processing
- Any operation performed on personal data, including collection, storage, use, disclosure or erasure.
- Data Controller
- 365gam — the entity that determines the purposes and means of processing personal data.
- Data Subject / User
- Any identified or identifiable natural person whose personal data is processed by 365gam.
- Cookies
- Small text files stored on your device when you visit the Platform, used to remember preferences and analyse usage.
- Third Party
- Any person or entity other than you and 365gam involved in the delivery of the Platform or related services.
- KYC Data
- Identity and age verification documents (e.g., CNIC, passport) submitted during account verification.
- Platform
- The 365gam website at https://365gam.cam and all associated services.
03 Data We Collect
We collect and process only the personal data necessary to operate the Platform effectively and fulfil our legal obligations. The categories of data we may collect include:
3.1 Information You Provide Directly
- Account Registration Data: Full name, email address, username, password (stored in hashed form) and date of birth provided when creating an account.
- Profile Information: Optional details such as city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) that you choose to add to your profile.
- KYC Verification Documents: Where applicable, copies of government-issued identity documents such as a Pakistani CNIC or passport, and any supporting proof-of-address documentation, submitted through our secure HTTPS verification portal.
- Communications: The content of any messages, enquiries or correspondence you send to us via email or through any support channel.
- Feedback and Survey Responses: Voluntary feedback, survey answers or content moderation reports you submit through the Platform.
3.2 Information Collected Automatically
- Technical Data: IP address, browser type and version, operating system, device type, screen resolution and language settings.
- Usage Data: Pages visited, time spent on pages, links clicked, search queries entered and navigation patterns within the Platform.
- Cookie Data: Preferences, session identifiers and analytical data collected via cookies and similar tracking technologies. See Section 7 (Cookies & Tracking) for full details.
- Log Files: Server-side access logs recording timestamps, requested URLs and response codes for security and operational monitoring.
3.3 Information We Do Not Collect
365gam does not collect the following categories of data in the ordinary course of Platform operation:
- Payment card numbers, bank account details or digital wallet credentials;
- Special category data such as racial or ethnic origin, health data, biometric identifiers, religious beliefs or political opinions;
- Real-time location tracking data beyond city-level inference from IP address.
365gam does not process gambling wagers or financial transactions. Any payment method references on the Platform (including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are purely editorial and educational. We do not handle or store payment credentials.
04 How We Use Your Data
We use your personal data only for the specific purposes set out below. We will not use it in ways incompatible with these stated purposes without first obtaining your consent or as required by applicable law.
| Purpose | Data Used | Legal Basis |
|---|---|---|
| Account creation and management | Registration data, email, username | Contract performance |
| KYC identity and age verification | CNIC / passport, selfie / liveness | Legal obligation / legitimate interest |
| Responding to support enquiries | Communications, account data | Contract performance / consent |
| Platform security and fraud prevention | Technical data, usage data, log files | Legitimate interest |
| Analytics and platform improvement | Usage data, cookie data (anonymised) | Legitimate interest / consent |
| Legal compliance and audit | All categories as required | Legal obligation |
| Responsible gambling monitoring | Account activity, session data | Legal obligation / legitimate interest |
We will never use your personal data to send unsolicited marketing communications without your explicit prior consent. If you have consented to receiving promotional communications, you may withdraw that consent at any time by contacting us at support@365gam.cam.
05 Legal Basis for Processing
We process your personal data on one or more of the following legal grounds, depending on the specific activity:
- Contract Performance: Processing is necessary to perform our contractual obligations to you as a registered user of the Platform, including providing access to Services and managing your account.
- Legal Obligation: Processing is required to comply with applicable laws, including identity verification obligations, anti-money laundering (AML) requirements and age verification standards where applicable.
- Legitimate Interests: Processing is necessary for our legitimate business interests — such as maintaining platform security, preventing fraud, improving our Services, and conducting analytics — provided those interests are not overridden by your fundamental rights and freedoms.
- Consent: Where we rely on your consent, you retain the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
06 Data Sharing & Disclosure
365gam does not sell, rent, trade or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. We may share your data only in the following limited and controlled circumstances:
6.1 Service Providers
We may share data with carefully selected third-party service providers who assist us in operating the Platform — including hosting providers, cloud storage vendors, analytics platforms and email delivery services. All such providers are bound by data processing agreements that restrict their use of your data to the services they provide to us and prohibit any independent processing or onward sharing.
6.2 Legal Requirements
We may disclose personal data where required to do so by law, court order, regulatory authority or where we believe in good faith that such disclosure is necessary to protect our legal rights, enforce our Terms & Conditions, or protect the safety of users or third parties.
6.3 Business Transfers
In the event of a merger, acquisition, reorganisation or sale of all or substantially all of our assets, your personal data may be transferred as part of the transaction. We will take reasonable steps to ensure that your privacy rights continue to be protected in any such transfer and will notify you in advance where feasible.
6.4 No Disclosure to Pakistani Authorities Without Legal Basis
We will not proactively disclose user data to any Pakistani government authority, the PTA, the State Bank of Pakistan or any law enforcement body unless compelled to do so by a valid and lawful legal instrument. If we receive such a request, we will assess its legality before complying and will notify affected users to the extent permitted by law.
07 Cookies & Tracking Technologies
The Platform uses cookies and similar tracking technologies to enhance your experience, remember your preferences, and gather anonymous analytics data that helps us understand how users interact with the Platform.
7.1 Types of Cookies Used
| Cookie Type | Purpose | Retention |
|---|---|---|
| Essential Cookies | Required for core Platform functions (session management, security tokens) | Session |
| Preference Cookies | Remember your language and display settings | Up to 12 months |
| Analytics Cookies | Collect anonymised data on page views, traffic sources and user journeys | Up to 24 months |
7.2 Managing Cookies
You may control or disable cookies through your browser settings. Disabling essential cookies may impair the functionality of the Platform. Disabling analytics cookies will not affect your ability to access content but will limit our ability to improve the Platform based on usage data.
Most modern browsers — including those commonly used in Pakistan, such as Chrome on Android — provide cookie management controls under Settings > Privacy. We recommend reviewing your browser's documentation for specific instructions.
By continuing to use the Platform after being presented with a cookie notice, you consent to the use of non-essential cookies as described in this section. You may withdraw consent by adjusting your browser settings at any time.
08 Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. Our standard retention periods are as follows:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years | Legal obligation / contractual |
| KYC verification documents | Duration of account + 7 years | AML / legal obligation |
| Support correspondence | 3 years from last contact | Legitimate interest |
| Analytics data (anonymised) | Up to 26 months (rolling) | Legitimate interest |
| Server log files | Up to 12 months | Security / legitimate interest |
Where we have no legitimate ongoing purpose to retain your data, we will securely delete or anonymise it. Anonymised data is no longer considered personal data and may be retained indefinitely for statistical purposes.
09 Data Security
We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:
- HTTPS Encryption: All data transmitted between your browser and the Platform is encrypted using TLS (Transport Layer Security).
- Password Hashing: User passwords are stored using strong one-way hashing algorithms. We do not store passwords in plain text.
- Access Controls: Personal data is accessible only to authorised personnel who require it for specific operational purposes.
- Secure Document Handling: KYC documents submitted through the Platform are stored in access-controlled, encrypted environments. Never send sensitive documents through unencrypted channels or third-party chat applications.
- Intrusion Monitoring: Our infrastructure is subject to continuous security monitoring to detect and respond to potential threats.
No method of electronic transmission or storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law.
If you suspect any unauthorised access to your 365gam account or believe your credentials have been compromised, please contact us immediately at support@365gam.cam and change your password without delay.
10 Your Rights
Subject to applicable law, you have the following rights in relation to your personal data held by 365gam. To exercise any of these rights, please contact us using the details in Section 15. We will respond to all valid requests within a reasonable timeframe — typically within 30 days, though complex requests may take longer.
Right of Access
You may request a copy of the personal data we hold about you and information about how it is being used.
Right to Rectification
You may request correction of any inaccurate or incomplete personal data we hold about you.
Right to Erasure
You may request deletion of your personal data where we no longer have a lawful basis to retain it, subject to legal retention obligations.
Right to Restriction
You may request that we limit processing of your data in certain circumstances, such as while you contest its accuracy.
Right to Portability
Where technically feasible, you may request a copy of your data in a structured, machine-readable format for transfer to another service.
Right to Object
You may object to processing based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
Right to Complain
You have the right to lodge a complaint with the relevant data protection authority in your jurisdiction if you believe your rights have been violated.
Please note that certain rights may be subject to limitations. For example, we may be unable to erase data we are legally required to retain, or restrict processing where it is necessary for security or legal compliance purposes. We will always explain any limitations that apply when responding to your request.
11 Minors & Age Policy
The Platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect personal data from individuals under this age threshold.
If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data from our systems. If you are a parent or guardian and believe your child has provided personal data to 365gam, please contact us immediately at support@365gam.cam so we can investigate and take appropriate action.
Age verification measures may be applied during account registration or KYC processing. Providing false information regarding your age constitutes a material breach of our Terms & Conditions and may result in immediate account closure and forfeiture of any associated benefits.
12 Pakistan-Specific Notes
365gam recognises that a significant portion of its user base accesses the Platform from Pakistan. The following notes are specifically relevant to Pakistani users:
- No PTA or Government Authorisation: 365gam is not registered with, licensed by, or approved by the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan (SBP), or any other Pakistani government body. This Policy does not constitute legal compliance advice under Pakistani law.
- Pakistan Electronic Crimes Act (PECA) 2016: We are aware of the regulatory environment under PECA 2016 and related legislation. Users in Pakistan must independently assess their obligations under this and other applicable laws.
- Cross-Border Data Transfers: As an international platform, your personal data may be processed on servers located outside Pakistan. By using the Platform, you consent to this transfer, provided it is conducted with appropriate security safeguards in place.
- Payment Provider References: References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Platform are made in an educational context only. These providers do not process data on behalf of 365gam and are not data processors under this Policy.
Pakistani users are encouraged to review local data protection legislation, including any applicable provisions of the Prevention of Electronic Crimes Act (PECA) 2016, and to seek independent legal advice if they have concerns about data processing compliance in Pakistan.
13 Third-Party Links & Services
The Platform may contain references to third-party operators, payment service providers, sports leagues and other external entities for educational and informational purposes. These references do not constitute endorsements, partnerships or affiliations. 365gam has no control over the data practices of any third-party website or service, and this Privacy Policy does not apply to third-party platforms.
If you navigate from the Platform to any third-party website — whether through a link, advertisement or other reference — you do so at your own risk and should review that party's own privacy policy before providing any personal data. We recommend exercising particular caution when accessing any site that requests payment information or identity documents.
14 Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time in response to changes in applicable law, regulatory guidance, our business operations or data processing practices. When we make material changes, we will update the "Last Updated" date at the top of this page.
For significant changes that materially affect how we process your personal data, we may provide additional notice through the Platform or by email (where we hold a valid email address for your account). Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the revised terms.
We encourage you to review this Policy periodically to stay informed about how we protect your information. Previous versions of this Policy may be made available upon written request to support@365gam.cam.
15 Contact & Complaints
If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your personal data by 365gam, please contact us using the details below. We will handle all privacy-related enquiries with appropriate care and respond within a reasonable timeframe.
Privacy Enquiries & Data Subject Requests
support@365gam.cam
Please use the subject line "Privacy Request – [Your Request Type]" (e.g., "Privacy Request – Data Deletion" or "Privacy Request – Access"). Include your registered email address and a clear description of your request. We may need to verify your identity before processing data subject requests.
Complaint Process
If you are dissatisfied with our response to a privacy request or believe we have processed your data unlawfully, you have the right to escalate your complaint to the relevant data protection supervisory authority in your jurisdiction. We encourage users to contact us directly in the first instance to give us the opportunity to resolve any concerns before escalating to a regulatory body.
For related legal information, please review our Terms & Conditions. For responsible gambling support resources, visit our Responsible Gambling page.
Privacy at a Glance
Our Data Commitments to You
Six core data practices that define how 365gam handles your personal information.
No Data Selling
We will never sell, rent or trade your personal data to third parties for commercial or marketing purposes. Your information exists to make the Platform work for you — nothing more.
Minimal Data Collection
We collect only what is necessary for Platform operation and legal compliance. We do not collect payment credentials, biometric data or special-category personal information in the ordinary course of our operations.
Anonymised Analytics
Where we use analytics tools, usage data is anonymised or pseudonymised before processing. We cannot identify individual users from our analytics data and do not attempt to do so.
HTTPS Encryption
All data transfers between your device and the Platform are secured with TLS encryption. Documents uploaded for KYC verification must only be submitted through our secure HTTPS portal — never via chat or email.
Your Rights, Respected
You have the right to access, correct, delete and port your personal data. Submit a request to support@365gam.cam and we will respond within a reasonable timeframe after verifying your identity.
Clear Retention Limits
We keep your data only as long as necessary for the purpose it was collected, or as required by law. When the retention period expires, data is securely deleted or irreversibly anonymised.