Data Protection & Privacy — ok 37

Privacy Policy

Your privacy matters to us at ok 37. This policy explains clearly what personal information we collect, why we collect it, how we use it, and what rights you have over your own data. We've written it in plain English so Pakistani players can actually understand it — not just lawyers.

Last Updated: January 2025 Language: English (en-PK) Applies To: All ok 37 Members GDPR-Aligned Principles
ok 37

ok 37's Six Privacy Commitments to You

Before you read the full policy, here's a summary of how ok 37 approaches your privacy. These are promises, not just policy statements.

We Encrypt Your Data

All personal data transmitted to and from ok 37 is encrypted using industry-standard TLS. Sensitive account data at rest is stored with encryption at the database level. Your information is never transmitted in plain text.

We Never Sell Your Data

ok 37 does not sell, rent, or trade your personal information to any third party for marketing or any other commercial purpose. Your data is yours. The only sharing that happens is what's strictly necessary to operate the platform.

We Collect Only What We Need

ok 37 operates on data minimisation principles. We collect only the personal information required to run your account, verify your identity, process your payments, and comply with our legal obligations — nothing more.

You Control Your Data

You have the right to access, correct, or request deletion of your personal data at any time by contacting our support team. We make this process straightforward — no lengthy bureaucratic procedures, no unexplained delays.

We Are Transparent About Use

Every purpose for which ok 37 uses your personal data is listed in this policy. We don't use your data for any purpose not described here, and when our purposes change, we update this policy and notify you.

We Don't Keep Data Longer Than Necessary

ok 37 applies clear data retention schedules. Account data is kept while your account is active and for a defined period after closure. Data we no longer need for any legitimate purpose is securely deleted.

1

Who We Are

ok 37 operates the online gaming platform available at ok37.im ("the Platform"). In this Privacy Policy, "ok 37," "we," "us," and "our" refer to the platform operator. "You" and "your" refer to any person who visits, registers with, or uses the ok 37 platform in any capacity.

ok 37 acts as the data controller in relation to the personal information you provide when registering and using the platform. This means we determine the purposes and means by which your personal data is processed. Where we engage third parties to process data on our behalf — such as payment processors or identity verification providers — those parties act as data processors under our instruction and are bound by data processing agreements that reflect the same standards described in this policy.

This policy applies to all personal data collected through the ok 37 website, mobile interface, customer support channels, and any associated services. It does not apply to third-party websites that may be linked from ok 37's platform — those sites have their own privacy policies and ok 37 is not responsible for their data practices.

Plain Language: ok 37 is responsible for looking after your personal data. This policy tells you exactly what we do with it. If anything is unclear, our support team is available 24/7 to explain — please ask before you register if you have concerns.


2

Data We Collect

ok 37 collects the following categories of personal data:

CategorySpecific Data PointsCollected At
Identity Data Full legal name, date of birth, CNIC number (where provided for KYC), gender Registration & KYC
Contact Data Mobile number, email address, residential address Registration
Financial Data Payment method type (Easypaisa / JazzCash / NayaPay / SadaPay / IBFT / card), transaction amounts, deposit and withdrawal history First deposit & ongoing
Gaming Activity Data Bets placed, games played, win/loss records, session duration, bonus usage Ongoing platform use
Technical Data IP address, device type, operating system, browser type, approximate location (city/region level from IP) Each platform visit
Communications Data Support chat transcripts, emails sent to us, complaint records When you contact us
KYC Documentation Copy of CNIC, proof of address, payment method verification documents On KYC request

ok 37 does not collect biometric data, health data, political opinions, religious beliefs, or any other special category of sensitive personal data as defined under applicable data protection principles.


3

How We Collect Your Data

ok 37 collects personal data through the following means:

  • Directly from you — when you complete the registration form, submit KYC documents, make a deposit, contact support, or update your account settings.
  • Automatically during platform use — through cookies, server logs, and similar tracking technologies that record technical data about your device and how you interact with the platform. See Section 7 for full details on cookies.
  • From payment processors — when you make a deposit or withdrawal via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, or card, the payment provider confirms transaction status and the reference details to our system.
  • From identity verification providers — where ok 37 uses a third-party KYC service to verify the authenticity of your submitted documents, that service may return a verification result and certain data points to our system.
  • From fraud prevention systems — ok 37 uses automated fraud detection tools that analyse platform activity patterns. These tools process gaming activity, IP addresses, and device fingerprints to identify potentially fraudulent behaviour.

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4

Why We Use Your Data

ok 37 uses your personal data for the following clearly defined purposes:

  • Account creation and management: Setting up your ok 37 account, verifying your identity, and maintaining your account in good standing.
  • Processing transactions: Handling deposits, withdrawals, and bonus credit/debit to and from your account balance in PKR via your chosen payment method.
  • Identity and age verification: Confirming that you meet the 18+ age requirement and that your account details correspond to a real individual. This is both a legal obligation and a responsible gaming measure.
  • Providing customer support: Responding to your queries, investigating complaints, and resolving disputes. Support transcripts are retained to maintain a record of what was agreed and to train our support team.
  • Platform security and fraud prevention: Detecting and investigating suspicious activity, preventing multiple-account fraud, identifying unusual betting patterns, and protecting the integrity of the platform for all members.
  • Responsible gaming compliance: Monitoring account activity to identify signs of problem gambling, applying player-requested limits, processing self-exclusion requests, and fulfilling our responsible gaming obligations.
  • Legal and regulatory compliance: Maintaining the records required to comply with applicable laws, including anti-money laundering (AML) obligations, and responding to lawful requests from relevant authorities.
  • Platform improvement: Analysing aggregated, anonymised usage data to improve the ok 37 platform, identify technical issues, and prioritise feature development based on how Pakistani players actually use the platform.
  • Marketing communications: Sending you promotional offers, bonus notifications, and platform news — but only if you have opted in to receive these. See Section 11 for full details and opt-out instructions.

5

Legal Basis for Processing

ok 37 processes your personal data under one or more of the following legal bases, depending on the specific processing activity:

  • Contract performance: Processing necessary to provide the services described in the ok 37 Terms and Conditions — account management, payment processing, game provision, and customer support.
  • Legal obligation: Processing required by applicable law — including identity verification, age verification, AML record-keeping, and responding to lawful authority requests.
  • Legitimate interests: Processing for purposes where ok 37 has a legitimate business interest that is not overridden by your rights — including fraud prevention, platform security, and aggregate analytics for platform improvement.
  • Consent: Processing based on your explicit agreement — specifically, sending you marketing communications. Where consent is the basis, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

If you want to know the specific legal basis that applies to any particular processing activity, contact our support team and we will explain it clearly.


6

Who We Share Your Data With

ok 37 does not sell your personal data. We share it only in the following specific circumstances:

  • Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, IBFT banking partners, and card payment networks receive the transaction data required to process your deposits and withdrawals. These providers have their own privacy obligations and do not receive your gaming activity data.
  • Identity verification providers: Where ok 37 uses a third-party KYC service, your submitted documents and identity data are shared with that service solely for the purpose of verification. Results are returned to ok 37 and the data is not retained by the KYC provider beyond the time required for verification.
  • Fraud prevention services: ok 37 uses technical fraud detection systems. Device fingerprint and behavioural data may be processed by these systems. No personally identifiable data is shared with external fraud databases without your specific knowledge in cases of confirmed fraud investigation.
  • Legal authorities: ok 37 will disclose personal data to law enforcement, courts, or regulatory bodies where we are legally required to do so. We will notify you of any such disclosure where legally permitted to do so.
  • Platform infrastructure providers: Cloud hosting and technology infrastructure providers that store and process data on our behalf under strict data processing agreements.

To be clear: ok 37 does not share your data with other gaming platforms, marketing agencies, data brokers, or any entity for purposes unrelated to the operation of your ok 37 account.


7

Cookies & Tracking Technologies

ok 37 uses cookies and similar tracking technologies to provide and improve the platform experience. Here is what each category of cookie does:

  • Essential cookies: These are required for the platform to function. They maintain your login session, remember your game preferences, and enable core features like deposit and withdrawal flows. You cannot opt out of essential cookies without ceasing to use the platform.
  • Analytics cookies: ok 37 uses anonymised analytics to understand how players use the platform — which pages are visited most, where players drop off during registration, and which games are most popular. This data is aggregated and no individual player is identified.
  • Functional cookies: These remember your preferences — such as your preferred game lobby view, your last-used stake amount, or your notification settings — so you don't have to reset them on every visit.
  • Security cookies: Short-lived cookies that help ok 37 detect unusual login patterns, multiple-device access, and potential account takeover attempts.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies may affect certain convenience features but will not prevent you from placing bets or accessing your account balance.


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8

Data Security

ok 37 takes the security of your personal data seriously and implements multiple layers of protection:

  • Encryption in transit: All data transmitted between your device and ok 37's servers is encrypted using TLS 1.2 or higher. This applies to login, account management, deposits, withdrawals, and all other platform interactions.
  • Encryption at rest: Sensitive data fields — including payment method references, identity document data, and KYC records — are encrypted at the database level.
  • Access controls: ok 37 staff access to personal data is role-based and limited to what each team member needs to perform their job. Access logs are maintained and reviewed.
  • Two-factor authentication: ok 37 provides optional two-factor authentication (2FA) for account login. We strongly encourage all members to enable 2FA to protect their account from unauthorised access.
  • Penetration testing: The ok 37 platform undergoes periodic security assessments to identify and address vulnerabilities before they can be exploited.

Despite these measures, no online platform can guarantee absolute security. If you become aware of any security concern related to your ok 37 account — suspected unauthorised access, a phishing attempt, or unusual activity — please contact our support team immediately. We will act without delay to investigate and protect your account.

ok 37 will never ask you for your account password through any communication channel. If someone claiming to be from ok 37 asks for your password, treat this as fraudulent and report it immediately.


9

Data Retention

ok 37 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention principles apply:

  • Active account data: Retained for the full duration of your membership at ok 37.
  • Financial transaction records: Retained for a minimum of five years after the transaction date, in line with standard AML compliance requirements.
  • KYC documentation: Retained for the duration of your account and for a minimum of five years after account closure.
  • Support communications: Retained for up to two years from the date of the interaction, to allow us to reference prior context in the event of follow-up queries or disputes.
  • Gaming activity logs: Retained for up to three years from the date of activity, used for responsible gaming monitoring, dispute resolution, and fraud investigation purposes.
  • Closed account data: Following voluntary or enforced account closure, ok 37 will retain the minimum data required to meet our legal obligations. Data not required for any legal purpose will be securely deleted within 90 days of account closure.

When data reaches the end of its retention period, it is securely deleted or anonymised so that it can no longer be associated with you as an individual.


10

Your Rights

As a member of ok 37, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team at support@ok37.im — we will respond within a reasonable timeframe and without undue delay.

Right of Access

You can request a copy of all personal data ok 37 holds about you. We will provide this in a clear, readable format within a reasonable timeframe.

Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You can update most contact details directly in your account settings.

Right to Erasure

You can request that ok 37 delete your personal data. This right is subject to our legal retention obligations — we cannot delete financial transaction records or KYC data that we are legally required to retain, but we can delete data beyond those requirements.

Right to Restrict Processing

In certain circumstances you can request that we limit our processing of your data while a dispute or verification matter is resolved.

Right to Data Portability

You can request a copy of your personal data in a structured, machine-readable format, allowing you to transfer it to another service if you wish.

Right to Object to Processing

You can object to processing based on legitimate interests where you have grounds relating to your particular situation. You can always object to processing for direct marketing purposes without needing to provide any reason.


11

Marketing Communications

ok 37 sends marketing communications — including promotional offers, bonus notifications, new game announcements, and seasonal offers — only to members who have opted in to receive them. You can manage your marketing preferences at any time through your account settings or by contacting support.

Withdrawing consent for marketing communications will not affect your ability to use the platform, receive your winnings, or access customer support. It will simply stop promotional messages from being sent to you.

Note that certain operational communications — such as deposit confirmations, withdrawal notifications, security alerts, and important account notices — are not marketing communications and will continue regardless of your marketing preference settings. These are necessary for the provision of the service and cannot be opted out of while your account remains active.


12

Children's Privacy

ok 37 is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. Our registration process includes age verification steps, and we conduct further KYC checks where there is any doubt about a member's age.

If ok 37 becomes aware that personal data has been collected from a person under the age of 18, we will immediately close the associated account, delete the personal data, and return any deposits where possible in line with our Terms and Conditions.

If you believe that a minor may have registered at ok 37, please contact our support team immediately. We treat such reports as high priority and will investigate within 24 hours.


13

Changes to This Policy

ok 37 will update this Privacy Policy when our data practices change, when legal requirements change, or when we introduce new services that involve new categories of data processing. When material changes are made, we will update the "Last Updated" date at the top of this page and notify active members via on-platform notification or email before the changes take effect.

We encourage you to review this policy periodically. If you continue to use ok 37 after a revised policy has been communicated, you are deemed to have accepted the updated terms. If you disagree with any changes, you may close your account and we will process your remaining eligible balance in the normal course.


14

Contact & Complaints

If you have any questions about this Privacy Policy, want to exercise any of your rights described in Section 10, or wish to make a complaint about how ok 37 has handled your personal data, please contact us:

  • Live Chat: Available 24/7 through the ok 37 platform — the fastest channel for all privacy-related queries.
  • Email: support@ok37.im — mark your email "Privacy Request — [your query type]" to ensure it reaches the right team. We aim to respond within 48 hours.
  • FAQ: Our FAQ section covers common data and account questions that may answer your query immediately.

ok 37 is committed to handling privacy concerns fairly and promptly. If you feel your concern has not been adequately addressed, please escalate by marking your follow-up email "Privacy Escalation" and it will be reviewed by a senior team member within 24 hours.

Your data is safe at ok 37. Ready to play?

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Questions About Your Privacy at ok 37?

Our support team is available around the clock to answer any data or privacy questions before you register. We believe transparency builds trust — ask us anything.

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Data never sold TLS encrypted You control your data Transparent purposes 18+ platform