Privacy Policy

1. Definitions

In this Privacy Policy, the following terms carry the meanings set out below unless the context requires otherwise:

• "fly33," "we," "us," "our" refers to the fly33 online gaming platform and its operators, accessible at https://fly33.ws.
• "Player," "you," "your" refers to any individual who accesses, registers on, or otherwise interacts with the fly33 platform.
• "Personal Data" refers to any information that identifies or can reasonably be used to identify a living individual, including name, email address, date of birth, payment details, and device identifiers.
• "Processing" refers to any operation performed on personal data, including collection, storage, use, disclosure, and deletion.
• "Third Party" refers to any natural or legal person, public authority, agency, or body other than the Player and fly33.
• "KYC" refers to Know Your Customer identity verification procedures required by fly33 for regulatory compliance.
• "Cookies" refers to small text files placed on your device by the fly33 platform to store information about your session and preferences.

2. About This Privacy Policy

2.1 This Privacy Policy sets out how fly33 collects, uses, stores, shares, and protects the personal data of individuals who use the fly33 platform. It also describes the rights available to Players in relation to their personal data.

2.2 This Privacy Policy forms part of the fly33 Terms & Conditions and should be read alongside them. In the event of any conflict between this Privacy Policy and the Terms & Conditions in relation to data privacy matters, this Privacy Policy shall prevail.

2.3 fly33 is the data controller in respect of all personal data collected through the fly33 platform. As data controller, fly33 is responsible for determining the purposes and means by which your personal data is processed.

2.4 This Privacy Policy is written in English. If any translation is made available for convenience, the English version shall be the authoritative version in the event of any discrepancy.

3. Personal Data We Collect

3.1 fly33 collects the following categories of personal data from Players:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, CNIC number, government-issued ID	Registration & KYC verification
Contact Data	Email address, mobile number, city of residence (e.g., Karachi, Lahore, Islamabad)	Registration & account updates
Financial Data	JazzCash / EasyPaisa wallet references, HBL / UBL / Meezan Bank account details, transaction history	Deposits, withdrawals & KYC
Technical Data	IP address, device type, browser type, operating system, session tokens	Automatic collection on platform access
Usage Data	Games played, bet history, session duration, bonus redemptions, login timestamps	Ongoing during platform use
Communications Data	Customer support correspondence, live chat transcripts, email content	When you contact fly33 support
Responsible Gaming Data	Self-exclusion status, deposit limit settings, cooling-off period records	When responsible gaming tools are activated

3.2 fly33 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, or biometric data, except where required by applicable law or regulatory obligation.

3.3 Where you choose not to provide personal data that fly33 requires for regulatory or operational purposes (such as KYC documentation), fly33 may be unable to process your withdrawal request, activate your account, or continue providing services to you.

4. How We Collect Your Data

4.1 fly33 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or updating your account profile;
• Automated technologies: Technical and usage data collected automatically when you access the fly33 platform, including through cookies, web beacons, server logs, and similar tracking technologies;
• Third-party sources: Identity and fraud-check data received from KYC verification providers, payment processors (such as JazzCash, EasyPaisa, and partner banks), and fraud prevention agencies where fly33 is legally permitted to receive and use such data;
• Publicly available sources: Information available from public records where relevant to fraud prevention or regulatory compliance.

5. Purpose & Legal Basis for Processing

5.1 fly33 processes your personal data only where there is a lawful basis for doing so. The table below sets out the primary purposes for which fly33 processes personal data and the corresponding legal basis:

Purpose	Legal Basis
Account registration and management	Performance of contract
Processing deposits and withdrawals	Performance of contract
Identity verification (KYC) and age verification	Legal obligation & performance of contract
Fraud detection, prevention, and security monitoring	Legitimate interests & legal obligation
Anti-money laundering compliance	Legal obligation
Customer support and dispute resolution	Performance of contract & legitimate interests
Responsible gaming monitoring and intervention	Legal obligation & legitimate interests
Platform improvement and analytics	Legitimate interests
Promotional communications (where consented)	Consent

5.2 Where fly33 relies on your consent as the legal basis for processing (for example, for direct marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to the withdrawal.

6. Data Sharing & Disclosure

6.1 fly33 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Your data is shared only in the circumstances described in this section.

6.2 fly33 may share your personal data with the following categories of recipients:

• Payment processors and banking partners: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers, strictly to process your financial transactions;
• KYC and identity verification providers: Third-party identity verification services used to confirm your identity and age in accordance with fly33's regulatory obligations;
• Fraud prevention and security services: Specialist agencies used to detect, prevent, and investigate fraudulent activity on the fly33 platform;
• Technology and infrastructure providers: Hosting, cloud storage, and platform software providers who process data on fly33's behalf under strict data processing agreements;
• Regulatory and legal authorities: Government bodies, law enforcement agencies, or courts where fly33 is legally required or permitted to disclose personal data;
• Game content providers: Third-party game studios whose titles are hosted on the fly33 platform, to the limited extent required for game functionality and fairness auditing.

6.3 All third-party service providers who receive personal data from fly33 are contractually required to process that data only for the specified purpose, to maintain appropriate security standards, and to comply with applicable data protection laws.

6.4 In the event that fly33 undergoes a merger, acquisition, or business transfer, your personal data may be transferred to the acquiring entity, subject to that entity agreeing to honour this Privacy Policy or providing you with advance notice and the opportunity to object.

7. Data Retention

7.1 fly33 retains your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, or as required by applicable law and regulatory obligations.

7.2 In general, fly33 applies the following retention guidelines:

• Account and identity data: Retained for the duration of your account and for a minimum period of five (5) years following account closure, in accordance with anti-money laundering and record-keeping obligations;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, as required by financial regulations;
• Customer support communications: Retained for up to three (3) years from the date of the last communication;
• Technical and usage data: Typically retained for up to twelve (12) months, unless longer retention is required for security or fraud investigation purposes;
• Responsible gaming records: Retained for the duration of any self-exclusion or restriction period plus a minimum of five (5) years.

7.3 When personal data is no longer required and no legal retention obligation applies, fly33 will securely delete or anonymise that data in a manner that prevents reconstruction or re-identification.

8. Security Measures

8.1 fly33 takes the security of your personal data seriously and has implemented a range of technical and organisational measures to protect it against unauthorised access, loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the fly33 platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorised fly33 personnel can access personal data, and only to the extent required for their specific role;
• Regular security audits, penetration testing, and vulnerability assessments of the fly33 platform;
• Staff training on data protection obligations and secure data handling practices;
• Incident response procedures to detect, contain, and report data security breaches in a timely manner.

8.2 Whilst fly33 employs all reasonable security measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials and for notifying fly33 immediately if you suspect any unauthorised access to your account.

9. Cookies & Tracking Technologies

9.1 fly33 uses cookies and similar tracking technologies (including web beacons and local storage) to operate and improve the platform, to personalise your experience, and to compile analytics data. The main categories of cookies used by fly33 are:

• Strictly necessary cookies: Essential for the operation of the fly33 platform, including session management, login authentication, and security functions. These cannot be disabled without affecting core platform functionality;
• Performance and analytics cookies: Used to collect anonymised data about how Players use the fly33 platform, including pages visited, session duration, and error rates, to help fly33 improve performance;
• Functional cookies: Used to remember your preferences such as language settings, game history, and interface customisations;
• Targeting and personalisation cookies: Used to deliver relevant promotional content and to measure the effectiveness of fly33's marketing activities, where you have consented to receive marketing communications.

9.2 You may manage and control cookie settings through your browser's privacy settings. Please be aware that disabling certain categories of cookies may affect the functionality of the fly33 platform.

9.3 fly33 does not use cookies to track your activity on third-party websites unrelated to the fly33 platform.

10. Your Data Rights

10.1 As a fly33 Player, you have the following rights in relation to your personal data, subject to applicable law and fly33's legitimate regulatory obligations:

• Right of access: You have the right to request a copy of the personal data fly33 holds about you;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by fly33;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to fly33's legal and regulatory retention obligations;
• Right to restriction: You have the right to request that fly33 restrict the processing of your personal data in certain circumstances;
• Right to data portability: You have the right to receive a copy of certain personal data you have provided to fly33 in a structured, commonly used, and machine-readable format;
• Right to object: You have the right to object to fly33's processing of your personal data where that processing is based on legitimate interests, including profiling for direct marketing purposes;
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time.

10.2 To exercise any of the rights listed above, please submit a written request to fly33 at [email protected]. fly33 will acknowledge your request promptly and respond substantively within a reasonable timeframe. fly33 may need to verify your identity before processing your request.

10.3 fly33 will not charge a fee for processing legitimate data rights requests unless a request is manifestly unfounded or excessive, in which case fly33 reserves the right to charge a reasonable administrative fee or decline the request.

11. Children's Privacy

11.1 fly33 is not directed at, and does not knowingly collect personal data from, individuals under the age of 21. All registration forms include a mandatory declaration of age, and fly33 employs age verification checks during the KYC process.

11.2 If fly33 becomes aware that personal data has been collected from a person under the age of 21, fly33 will immediately suspend the relevant account, delete the personal data concerned, and refund any real-money balance to the payment source used, in accordance with fly33's underage gambling procedure.

12. Marketing Communications

12.1 fly33 may send you promotional communications about bonuses, new games, platform updates, and special offers, where you have provided your consent to receive such communications during registration or at any subsequent point.

12.2 You may opt out of receiving marketing communications from fly33 at any time by:

• Clicking the "unsubscribe" link included in any marketing email from fly33;
• Updating your communication preferences within the fly33 account settings;
• Contacting fly33 customer support at [email protected] and requesting removal from marketing lists.

12.3 Opting out of marketing communications will not affect fly33's ability to send you essential transactional communications related to your account, deposits, withdrawals, security alerts, or changes to fly33's policies.

13. Third-Party Services

13.1 The fly33 platform may contain links to third-party websites or services, including payment providers and game studios. fly33 is not responsible for the privacy practices of these third parties and encourages Players to review the privacy policies of any third-party service they access.

13.2 Where third-party services are integrated into the fly33 platform (such as payment gateways), those third parties process personal data under their own privacy policies and data processing agreements with fly33. fly33 conducts due diligence on all third-party data processors to ensure they maintain adequate security and privacy standards.

13.3 fly33 is not liable for any breach of privacy or data security occurring on third-party platforms or services that are not directly operated by fly33, even where those services are accessed via a link or integration on the fly33 platform.

14. Updates to This Privacy Policy

14.1 fly33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or fly33's data processing practices. All updates will be published on this page with a revised "Last Updated" date at the top of the policy.

14.2 Where changes to this Privacy Policy are material, fly33 will endeavour to notify registered Players by email to the address held on their account, or by displaying a prominent notice on the fly33 platform, at least fourteen (14) days before the changes take effect.

14.3 Your continued use of the fly33 platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised policy. If you do not accept the updated terms, you should discontinue use of the platform and request account closure.

15. Contact Us

15.1 If you have any questions, concerns, or complaints regarding this Privacy Policy or fly33's data processing practices, please contact the fly33 data protection team:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week
• Response Language: English

15.2 For information on fly33's Terms & Conditions, please visit fly33.ws/terms-conditions. For information on fly33's responsible gaming tools, including self-exclusion and deposit limits, please visit fly33.ws/responsible-gaming.