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Last Updated: 1 January 2025 Version 2.4

Privacy Policy — ok 37 — How Your Personal Data Is Protected

At ok 37 we take the privacy of every Pakistani player seriously. This policy explains clearly what data we collect, why we collect it, how we use it, who we share it with, and what rights you have over your own information.

ok 37

Our Privacy Commitments at a Glance

Before you read the full policy, here are the six principles that guide how ok 37 handles every piece of data you share with us.

Your Data Stays Secure

All data transmitted between your device and ok 37 is encrypted using TLS. Stored personal data is protected by access controls, encryption at rest, and regular security audits.

Never Sold to Third Parties

ok 37 does not sell, rent, or trade your personal data to advertisers or data brokers. Your information is used exclusively to operate and improve your ok 37 experience.

You Control Your Data

You have the right to access, correct, download, and request deletion of your personal data held by ok 37 at any time. Submit requests to support@ok37.wine and we respond within 30 days.

Collected Only What's Needed

ok 37 collects the minimum data required to operate your account, verify your identity, process payments, and comply with legal obligations. We do not collect data speculatively.

Marketing You Can Control

ok 37 marketing communications are opt-in. You can unsubscribe from any email or SMS campaign at any time, and marketing is stopped immediately for any self-excluded player.

Plain Language Promise

This privacy policy is written to be readable — not buried in legal jargon. If something is unclear, contact ok 37 support and we will explain it in plain English at no charge.

1Who We Are

This Privacy Policy applies to ok 37, the online gaming and sports betting platform operated at ok37.wine and all associated subdomains, mobile interfaces, and support channels. When this policy refers to "ok 37", "we", "us", or "our", it means the operating entity responsible for the ok 37 platform and the processing of your personal data in connection with it.

ok 37 is the data controller for personal information collected during account registration, identity verification, payment processing, gaming activity, and customer support interactions. As data controller, ok 37 is responsible for ensuring that your personal data is processed lawfully, fairly, and transparently in accordance with applicable data protection principles.

This policy applies to all players registered on the ok 37 platform, all visitors to the ok37.wine website, and all persons who interact with ok 37 through any support channel including email, live chat, WhatsApp, or Telegram. If you are located in Pakistan, the data protection principles applicable to your data processing relationship with ok 37 are those consistent with internationally recognised standards and the specific protections ok 37 has committed to in this policy.

Data Controller Contact: support@ok37.wine · ok37.wine · Available 24/7 for all privacy-related queries and data subject requests.

2Data We Collect

ok 37 collects personal data from you in several ways — directly when you register or interact with the platform, automatically through your device and browser when you use ok 37, and occasionally from third-party sources such as identity verification providers and payment processors. The categories of data we collect are set out below.

2.1 Registration Data

When you create your ok 37 account, we collect your full legal name, date of birth, residential address, mobile phone number, email address, and the username and password you choose. This data is mandatory — without it, ok 37 cannot open or operate your account.

2.2 Identity Verification Data (KYC)

As part of our compliance obligations, ok 37 may request copies of your CNIC (Computerised National Identity Card), a recent utility bill or bank statement as proof of address, and a live selfie or short video for biometric identity matching. This data is collected and processed solely for the purpose of verifying that you are who you say you are and that you meet ok 37's eligibility requirements.

2.3 Payment Data

When you make deposits or request withdrawals, ok 37 collects details of the payment method used — including the mobile number associated with your Easypaisa or JazzCash wallet, partial card numbers for Visa/Mastercard transactions, and bank account details for IBFT transfers. ok 37 does not store full card numbers. Payment data is processed by our payment processor partners and is retained by ok 37 only to the extent required to verify transaction ownership and process withdrawals to the correct method.

2.4 Gaming and Transaction Data

ok 37 records all bets, wagers, game outcomes, deposits, withdrawals, bonus activations, and account balance changes associated with your account. This data forms part of your account history and is used for account management, dispute resolution, responsible gaming monitoring, and compliance purposes.

2.5 Device and Technical Data

ok 37 automatically collects technical information when you access the platform, including your IP address, device type and operating system, browser type and version, session duration, pages visited, and referring URL. This data is used to maintain platform security, detect fraud, optimise the mobile experience for Pakistani users, and improve platform performance.

2.6 Communications Data

When you contact ok 37 support — whether by email, live chat, WhatsApp, or Telegram — we retain a record of the communication including its content, the date and time, and any resolution or action taken. This data is used to resolve your query, maintain service quality, and as a reference in the event of future related queries.

Data Category Examples Mandatory?
RegistrationName, DOB, address, mobile, emailYes
KYC / IdentityCNIC copy, selfie, proof of addressFor withdrawals
PaymentEasypaisa/JazzCash number, partial cardFor transactions
Gaming HistoryBets placed, outcomes, deposits, withdrawalsAutomatic
Device / TechnicalIP address, browser, OS, session dataAutomatic
CommunicationsSupport chat logs, email threadsWhen you contact us
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3How We Use Your Data

ok 37 uses your personal data only for specific, legitimate purposes. We do not use data for any purpose that would be incompatible with why it was originally collected. The main purposes for which ok 37 processes personal data are:

  • Account creation and management: To open your ok 37 account, maintain it, process login requests, and manage password resets and account settings.
  • Identity verification: To verify your age, identity, and eligibility to use ok 37 in compliance with responsible gaming and anti-money laundering obligations.
  • Payment processing: To process deposits and withdrawals in PKR via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, and card methods. To verify that withdrawal destinations match the account holder's verified identity.
  • Providing gaming services: To operate the betting, live casino, slot, Aviator, and card game products available on ok 37. To record game outcomes and maintain your betting history.
  • Customer support: To respond to your queries, resolve disputes, and maintain a record of communications to ensure consistency of service.
  • Fraud and security: To detect, investigate, and prevent fraudulent activity, unauthorised access, and misuse of the ok 37 platform.
  • Responsible gaming: To monitor gaming behaviour for indicators of problem gambling, enforce deposit limits and self-exclusion requests, and deliver responsible gaming notifications to players who have requested them.
  • Legal compliance: To comply with anti-money laundering (AML) requirements, respond to lawful requests from authorities, and maintain records as required by applicable law.
  • Platform improvement: To analyse aggregated, anonymised usage patterns in order to improve the ok 37 platform, identify popular features, and fix technical issues.
  • Marketing: To send promotional communications to players who have opted in. See Section 12 for full details of your marketing rights and opt-out options.

4Legal Basis for Processing

ok 37 processes your personal data on the following legal bases, depending on the purpose of the processing:

  • Contract performance: Processing necessary to open your account, process transactions, and deliver the gaming services you have signed up for. Without this processing, ok 37 cannot fulfil its obligations to you as a player.
  • Legal obligation: Processing required by law, including identity verification for KYC compliance, transaction monitoring for AML purposes, and data retention required by applicable regulations.
  • Legitimate interests: Processing carried out for ok 37's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, responsible gaming monitoring, and service improvement based on anonymised usage analytics.
  • Consent: Processing based on your specific, freely given consent — primarily for marketing communications. Consent-based processing can be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.
Note: Where ok 37 relies on legitimate interests as a legal basis, we have carried out a balancing assessment to ensure that our interests do not override your fundamental rights and freedoms. Details of these assessments are available on request.

5Sharing Your Data

ok 37 does not sell your personal data to third parties. We share personal data only in the following circumstances and only to the minimum extent necessary for the stated purpose:

5.1 Payment Processors

When you make a deposit or withdrawal, ok 37 shares the necessary payment data with the relevant payment processor — Easypaisa, JazzCash, NayaPay, SadaPay, or the relevant card network. These processors are bound by their own data protection obligations and contractual commitments to ok 37. They use your data only to process the specific transaction.

5.2 Identity Verification Providers

ok 37 uses third-party KYC and identity verification services to process CNIC documents and biometric data during account verification. These providers process your data under contract with ok 37 and are prohibited from using your data for any purpose other than the verification requested by ok 37.

5.3 Game Software Providers

The game studios whose titles are hosted on ok 37 — including Pragmatic Play, NetEnt, PG Soft, and others — may receive anonymised session data for the purpose of game optimisation and fault diagnosis. These providers do not receive your name, CNIC, payment details, or any other directly identifying information as part of this data sharing.

5.4 Legal and Regulatory Disclosure

ok 37 may disclose personal data to regulatory bodies, law enforcement agencies, or courts when legally required to do so. Such disclosures are made only to the extent required by law and, where permitted, ok 37 will notify you of any such disclosure request.

5.5 Business Transfers

In the event that ok 37's business is acquired, merged, or transferred in whole or in part, personal data held by ok 37 may form part of the transferred assets. You will be notified of any such transfer and your rights with respect to your data will be preserved.

What we will never do: ok 37 will never sell your data to advertisers, share your data with other gambling operators for marketing purposes, or disclose your information to any third party without a lawful basis to do so.
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6Data Retention

ok 37 retains your personal data for as long as your account is active and for a period after closure as required by applicable law and legitimate business purposes. The main retention periods applied by ok 37 are as follows:

  • Account and registration data: Retained for the duration of your account and for five years after account closure, to comply with record-keeping requirements applicable to ok 37's operations.
  • KYC and identity verification data: Retained for five years from the date of verification or from account closure, whichever is later, in line with AML record-keeping requirements.
  • Payment and transaction records: Retained for five years from the date of each transaction.
  • Gaming history: Retained for the duration of your account and for five years after closure for compliance and dispute resolution purposes.
  • Customer support communications: Retained for three years from the date of the communication.
  • Technical and device data: Retained for 12 months from collection for security and fraud prevention purposes, then anonymised or deleted.

After the applicable retention period, ok 37 will securely delete or irreversibly anonymise your personal data. You may request early deletion of certain data types by contacting support@ok37.wine — requests will be assessed against ok 37's legal retention obligations and a decision communicated within 30 days.

7Security of Your Personal Data

ok 37 takes the security of your personal data seriously and implements a layered set of technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, or alteration. These measures include:

  • TLS encryption: All data in transit between your device and ok 37 servers is encrypted using TLS 1.2 or higher. The padlock icon in your browser confirms this when you access ok37.wine.
  • Encryption at rest: Sensitive data stored on ok 37 infrastructure — including KYC documents and payment details — is encrypted at rest using AES-256 or equivalent standard.
  • Access controls: Access to personal data within ok 37's systems is restricted to staff with a legitimate need for that access. Access is logged and reviewed regularly.
  • Multi-factor authentication: Administrative access to ok 37's data systems requires multi-factor authentication. Players can also enable optional MFA on their own ok 37 accounts.
  • Regular security testing: ok 37's platform undergoes periodic security assessments to identify and remediate vulnerabilities.

Despite these measures, no internet-connected system is completely immune to security risk. In the unlikely event of a data breach that poses a risk to your rights and freedoms, ok 37 will notify you without undue delay and will take immediate steps to contain and remediate the breach.

If you suspect your account has been compromised: Contact ok 37 support immediately at support@ok37.wine or via Live Chat. We will investigate and take action within hours.

8Cookies and Tracking Technologies

ok 37 uses cookies and similar tracking technologies on the ok37.wine website. A cookie is a small text file placed on your device by a website to remember information about your visit. The cookies ok 37 uses fall into four categories:

You can manage cookie preferences through your browser settings. Most browsers allow you to view, block, and delete cookies. Note that blocking essential cookies will prevent you from logging into your ok 37 account.

9Your Rights Over Your Personal Data

As a player whose data is processed by ok 37, you have the following rights. ok 37 is committed to responding to all rights requests within 30 days of receipt. Requests can be submitted to support@ok37.wine with the subject line "Data Rights Request".

Right of Access

Request a copy of all personal data ok 37 holds about you, including what data is held, why, for how long, and with whom it has been shared.

Right to Rectification

Request correction of any inaccurate or incomplete personal data ok 37 holds about you. Some corrections may require supporting documentation.

Right to Erasure

Request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ok 37's legal retention obligations.

Right to Restrict Processing

Request that ok 37 limits the processing of your data while a complaint or correction request is being investigated, or where you object to processing based on legitimate interests.

Right to Portability

Request a machine-readable export of personal data you have directly provided to ok 37, such as registration details and transaction history, for transfer to another service.

Right to Object

Object to processing carried out on the basis of ok 37's legitimate interests. ok 37 will stop that processing unless we can demonstrate compelling grounds that override your objection.

How to exercise your rights: Email support@ok37.wine with "Data Rights Request" in the subject line. Include your registered name and mobile number for verification. ok 37 will acknowledge your request within 5 business days and respond fully within 30 days.

10Children's Privacy

ok 37 is strictly an adults-only platform. No person under the age of 18 is permitted to register, deposit, wager, or access any gaming or betting product on ok 37. ok 37 does not knowingly collect personal data from anyone under 18. Where ok 37 identifies or has reasonable grounds to believe that a minor has registered an account, that account will be immediately closed, any deposits will be returned, and the personal data of the minor will be deleted from ok 37's systems as soon as reasonably practicable.

If you believe a minor has registered on ok 37 using false information, please contact support@ok37.wine immediately. ok 37 treats reports of underage account access as a priority and will investigate and act within 24 hours.

ok 37 actively encourages parents and guardians to use parental control tools to prevent minors from accessing online gambling and betting platforms. If you need guidance on available tools, the ok 37 Responsible Gaming page at ok37.wine/responsible-gaming provides further information.

11International Data Transfers

ok 37's primary player base is in Pakistan, and the platform is designed specifically for Pakistani users. However, some of the third-party service providers that ok 37 uses — including game software providers, identity verification services, and payment processors — may process data in jurisdictions outside Pakistan.

Where personal data is transferred internationally, ok 37 ensures that appropriate safeguards are in place to protect your data to a standard consistent with the protections described in this policy. These safeguards may include contractual clauses, supplier security assessments, and data processing agreements that bind third-party processors to equivalent data protection standards.

ok 37 does not transfer personal data to countries that lack adequate data protection frameworks without implementing supplementary safeguards. If you have questions about the specific countries to which your data may be transferred, contact support@ok37.wine.

12Marketing Communications

ok 37 sends promotional communications — including bonus offers, new game announcements, and seasonal promotions — to players who have opted in to receive them. Marketing consent is collected at registration and can be updated at any time through your account settings or by contacting support@ok37.wine.

ok 37 will never send marketing communications to players who have not opted in. ok 37 will immediately stop all marketing communications to any player who applies for self-exclusion or requests to be removed from ok 37's marketing list. The removal will take effect within 5 business days of your request.

To opt out of ok 37 marketing communications, you can: use the unsubscribe link in any email, reply STOP to any SMS, or contact support@ok37.wine stating that you wish to be removed from all ok 37 marketing lists. Opting out of marketing does not affect operational communications — ok 37 will continue to send you account-related notifications such as deposit confirmations and verification requests as these are not marketing communications.

Self-exclusion and marketing: If you self-exclude from ok 37 under the Responsible Gaming programme, marketing communications will be stopped immediately as part of the self-exclusion process. No separate opt-out request is needed.

13Changes to This Privacy Policy

ok 37 may update this Privacy Policy from time to time to reflect changes in our data processing practices, new services added to the platform, changes in applicable law, or feedback received from players. The "Last Updated" date at the top of this page will be changed whenever an update is made.

For material changes — those that substantially affect how your data is processed or your rights in relation to it — ok 37 will provide at least 14 days' advance notice by email to your registered address and by a prominent notice on the ok 37 platform. Your continued use of ok 37 after the effective date of any change constitutes acceptance of the updated Privacy Policy.

If you do not accept a material change to this Privacy Policy, you may close your ok 37 account as described in the Terms and Conditions. Any data collected before the change will continue to be processed in accordance with the policy version that was in effect at the time of collection, unless you agree to the new policy.

14Contact ok 37 About Privacy

If you have any questions, concerns, or requests related to this Privacy Policy or the way ok 37 processes your personal data, please get in touch with us. ok 37 takes all privacy enquiries seriously and commits to responding promptly and helpfully.

  • Email (preferred for data rights requests): support@ok37.wine — subject line "Privacy Enquiry" or "Data Rights Request"
  • Live Chat: Available 24/7 on ok37.wine — for urgent privacy or security concerns
  • WhatsApp / Telegram: Available 24/7 — contact details visible after login

ok 37 acknowledges all privacy-related enquiries within 5 business days and aims to provide a full response within 30 days. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days — we will inform you if this is the case.

If you are not satisfied with ok 37's response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority or regulatory body applicable in your jurisdiction.

Effective Date: This Privacy Policy is effective from 1 January 2025 and supersedes all previous versions published by ok 37. By registering or continuing to use ok 37 after this date, you confirm your acknowledgement of this Policy.
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Your Data Is Safe at ok 37 — Play With Confidence

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