Privacy Policy

01 Introduction

77f77 (referred to in this Privacy Policy as "the Platform", "we", "us" or "our") is an English-language online gaming information and services platform accessible at https://77f77.cam. This Privacy Policy governs the collection, use, storage, disclosure and protection of personal data relating to users of the Platform ("you", "your" or "User").

We understand that privacy is a serious matter. Pakistani users interacting with digital platforms share personal information in a context where data protection awareness is growing, and where the consequences of data mishandling can be significant. This policy is designed to be clear, honest and complete — not to obscure our practices behind complex language.

This policy applies to all personal data collected through the Platform website, account registration process, KYC verification flow, payment processing, support communications, and any other interaction you have with 77f77. It should be read alongside our Terms & Conditions, which incorporate this policy by reference.

02 Definitions

For the purposes of this Privacy Policy, the following terms carry the meanings set out below:

Term	Meaning
"Personal Data"	Any information that relates to an identified or identifiable natural person — including name, email address, date of birth, financial information, IP address and device identifiers.
"Processing"	Any operation performed on personal data — including collection, storage, use, transmission, anonymisation or deletion.
"Data Controller"	The entity that determines the purposes and means of processing personal data. For this Platform, 77f77 is the Data Controller.
"Data Processor"	A third party that processes personal data on behalf of the Data Controller under a contractual arrangement (e.g., KYC verification providers, payment processors).
"Consent"	A freely given, specific, informed and unambiguous indication by the User that they agree to the processing of their personal data for a stated purpose.
"Sensitive Data"	Special categories of personal data warranting heightened protection — including national identity document numbers (CNIC), biometric data and financial account details.
"KYC"	Know Your Customer — identity and age verification procedures required under applicable law and platform policy.
"Cookie"	A small text file placed on a user's device by a website to store session, preference or tracking information.

03 Data Controller Identity

3.1 The Data Controller responsible for personal data collected through the 77f77 Platform is the operating entity behind 77f77, holding the applicable gaming or information services licence under which this Platform operates.

3.2 For data protection enquiries, access requests, deletion requests or complaints relating to how your personal data is handled, Users may contact the Platform using the contact details set out in Section 17 of this policy.

3.3 Where 77f77 engages third-party Data Processors — such as KYC verification service providers, payment processing partners or analytics platforms — those processors handle personal data solely on behalf of 77f77 and under binding contractual data processing agreements that prohibit them from using your data for their own independent purposes.

04 Personal Data We Collect

4.1 The categories of personal data we collect depend on how you interact with the Platform. The following table sets out the principal categories:

Category	Specific Data Points
Identity Data	Full legal name, date of birth, gender (where required for verification), nationality and country of residence.
Contact Data	Email address, mobile phone number and, where provided, residential address in Pakistan or elsewhere.
Identity Documents	CNIC (Computerised National Identity Card) number and scan, Pakistani passport details, utility bills or other proof-of-address documents submitted through the KYC portal.
Financial Data	Payment method details (wallet IDs, bank account identifiers, transaction reference numbers) required to process deposits and withdrawals. Full card or bank account numbers are not stored by 77f77 — they are handled by PCI-compliant payment processors.
Account Data	Username, encrypted password, account settings, communication preferences, responsible gambling limit settings and account history.
Transactional Data	Deposit and withdrawal records, game play history, betting history, bonus claims and wagering progress records.
Technical Data	IP address, device type, operating system, browser type, session timestamps and geolocation data (city-level, for compliance and fraud prevention purposes).
Communication Data	Records of support chat conversations, email correspondence and any feedback submitted through the Platform.
Marketing Preferences	Records of consent or opt-out status for promotional email, SMS and push notification communications.

4.2 Data We Do Not Collect

Unless specifically required by law or a regulatory obligation that is communicated to you at the time of collection, 77f77 does not collect: detailed political opinions, religious or philosophical beliefs, trade union membership, genetic data, or health information beyond what is required for responsible gambling self-exclusion processes.

05 How Personal Data Is Collected

5.1 Personal data is collected through the following channels:

• Direct Submission: Data you provide when creating an account, completing KYC verification, making deposits or withdrawals, contacting support, or submitting feedback.
• Automated Technical Collection: IP addresses, device identifiers, browser fingerprints and session data collected automatically when you access the Platform.
• Cookies and Similar Technologies: Session cookies, preference cookies and analytics cookies placed on your device as described in Section 11.
• Third-Party Verification Services: Identity and document verification data returned by our KYC providers during the verification process.
• Payment Processors: Transaction confirmation data and payment method identifiers returned by payment processing partners following deposit or withdrawal processing.
• Fraud and AML Screening: Results of automated and manual screening processes against sanctions lists and fraud databases, as required by applicable law.

06 Legal Basis for Processing

6.1 Where applicable data protection law requires a legal basis for each processing activity, 77f77 relies on the following bases:

Legal Basis	Processing Activities Covered
Contract Performance	Processing necessary to open and manage your account, process deposits and withdrawals, and deliver the gaming services you have requested.
Legal Obligation	KYC/AML verification, age verification, fraud prevention screening and regulatory reporting obligations imposed by applicable law.
Legitimate Interests	Platform security, fraud detection, network integrity, responsible gambling monitoring, service improvement analytics and personalisation of the gaming experience — where these interests are not overridden by your privacy rights.
Consent	Marketing communications (promotional emails, SMS, push notifications) and placement of non-essential cookies. Consent may be withdrawn at any time without affecting processing already carried out on that basis.

07 Purposes of Processing

7.1 Your personal data is used for the following purposes:

• Account Creation and Management: Setting up your account, verifying your identity and age, and maintaining your profile and preferences.
• Payment Processing: Processing deposits and withdrawals, verifying payment method ownership and managing transaction records.
• KYC and Compliance: Fulfilling identity verification, anti-money laundering (AML) and counter-terrorist financing (CTF) obligations under applicable law.
• Fraud Prevention and Security: Detecting and investigating suspicious account activity, multiple account abuse, bonus fraud and payment fraud.
• Responsible Gambling: Monitoring gambling patterns where voluntary limits have been set, applying self-exclusion decisions and preventing access by self-excluded users.
• Customer Support: Responding to your queries, resolving complaints and maintaining records of communications for quality and compliance purposes.
• Platform Analytics: Understanding how users interact with the Platform to improve usability, performance and content relevance — using aggregated or anonymised data where possible.
• Marketing (with Consent): Sending promotional communications about offers, new games, sports betting markets and platform features — but only where you have opted in, and subject to your right to opt out at any time.
• Legal Compliance: Meeting obligations imposed by the operator's licensing authority, applicable domestic law, court orders or regulatory requests.

08 Sharing Personal Data with Third Parties

8.1 We share personal data with third parties only where necessary and under appropriate safeguards. The categories of recipients are as follows:

8.1 KYC and Identity Verification Providers

Specialist identity verification providers process CNIC scans, passport data, selfies and liveness checks on our behalf for the purpose of age and identity verification. These processors are bound by data processing agreements prohibiting secondary use of your data.

8.2 Payment Processing Partners

Payment processors handle the technical mechanics of deposit and withdrawal transactions. 77f77 does not store full financial account numbers — these are handled directly by PCI-DSS compliant processors. Contextual references to familiar Pakistan payment methods such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah are used for illustrative purposes only; 77f77 makes no claim that any of these providers endorse gambling activity.

8.3 Fraud and AML Screening Services

Certain personal data — such as name, date of birth and document identifiers — may be checked against sanctions databases, politically exposed persons (PEP) lists and fraud registries as required by AML obligations.

8.4 Regulatory and Law Enforcement Authorities

We may disclose personal data to licensing authorities, financial intelligence units or law enforcement agencies where required by applicable law, a court order or a legitimate regulatory request. We do not voluntarily disclose personal data beyond what is legally required.

8.5 Analytics and Technology Providers

Platform performance analytics and infrastructure providers may have access to technical data (such as aggregated session data) to support platform operation. We use contractual measures to minimise the personal data shared with these providers and prefer anonymised or pseudonymised data where feasible.

09 International Data Transfers

9.1 The 77f77 Platform operates internationally, and your personal data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, we implement appropriate safeguards to protect your data, which may include:

• Standard contractual clauses approved by the relevant data protection authority;
• Binding corporate rules where applicable;
• Transfers to countries recognised as providing an adequate level of data protection under applicable law.

9.2 By using the Platform, you acknowledge that your personal data may be transferred and processed in jurisdictions that may have different data protection standards from those in your country of residence. We take all reasonable steps to ensure that such transfers are handled securely and lawfully.

10 Data Retention

10.1 We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active Account Data: Retained for the duration of the account relationship plus any mandatory post-closure retention period required by the operator's licensing authority.
• KYC Documents: Retained for a minimum of five years following the end of the account relationship, or longer where required by applicable AML law.
• Transaction Records: Retained for a minimum of five years following the transaction date, or as required by applicable financial regulations.
• Support Communications: Retained for a minimum of two years following the resolution of the query, subject to any ongoing dispute or legal proceedings.
• Marketing Consent Records: Retained for as long as a consent remains in force, plus a reasonable period following withdrawal to demonstrate the history of consent.

10.2 When personal data is no longer required for any lawful purpose, it is securely deleted or anonymised in accordance with our data disposal procedures.

11 Cookies and Tracking Technologies

11.1 The Platform uses cookies and similar tracking technologies to support platform functionality, remember your preferences and, where consented to, measure usage and deliver relevant content. The principal categories of cookies used are:

Cookie Type	Purpose	Consent Required?
Strictly Necessary	Session management, authentication, security tokens and CSRF protection. These are essential for the Platform to function and cannot be disabled.	No
Functional	Remembering language preferences, display settings and previously entered information to improve your experience.	Yes
Analytics	Measuring page visits, session duration and navigation patterns to understand how users interact with the Platform and to identify areas for improvement. Data is aggregated where possible.	Yes
Marketing	Tracking conversions and measuring the effectiveness of promotional communications — used only where you have opted into marketing communications.	Yes

11.2 You may manage your cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from using the Platform's core features, though some functional preferences may not be retained between sessions.

12 Your Data Rights

12.1 Subject to applicable law and our legal obligations, you have the following rights with respect to your personal data held by 77f77:

12.2 To exercise any of these rights, contact us using the details in Section 17. We may require identity verification before processing a rights request to protect against fraudulent claims. We do not charge a fee for handling rights requests unless they are manifestly unfounded or excessive.

12.3 If you are dissatisfied with our response to a data rights request, you have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction where the Platform holds its operating licence.

13 Children's Privacy

13.1 If we become aware that personal data has been collected from a person under the applicable minimum age without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account.

13.2 If a parent or guardian becomes aware that their child has provided personal data to 77f77, they should contact us immediately at the address in Section 17. We will investigate and respond promptly.

14 Data Security

14.1 We implement technical and organisational security measures appropriate to the nature and sensitivity of the personal data we process. These measures include:

• HTTPS encryption across all Platform pages and data transmission channels;
• Encrypted storage of sensitive data, including account credentials and identity document references;
• Role-based access controls limiting staff access to personal data to those with a genuine operational need;
• Regular security assessments of Platform infrastructure and third-party processors;
• PCI-DSS compliant handling of payment card and financial account data through specialist processors;
• Audit logging of access to sensitive data categories for fraud detection and compliance purposes.

14.2 No data transmission over the internet can be guaranteed to be completely secure. While we apply all reasonable technical safeguards, we cannot provide an absolute guarantee of security in relation to data transmitted to or from the Platform.

14.3 Users are responsible for maintaining the security of their own account credentials. You should use a strong, unique password for your 77f77 account and not share your login details with any other person. If you suspect your account has been compromised, contact support immediately.

15 Marketing Communications

15.1 We will only send you promotional marketing communications — including emails about bonuses, new game categories, sports betting markets and platform features — where you have explicitly opted in to receive them during registration or at a later point in your account settings.

15.2 You may withdraw your consent to receive marketing communications at any time by:

• Using the unsubscribe link included in every marketing email;
• Updating your communication preferences in your account settings dashboard; or
• Contacting our support team as described in Section 17.

15.3 Withdrawal of marketing consent does not affect your ability to use the Platform or receive essential service communications — such as account notifications, security alerts, transaction confirmations and support responses — which are sent on a contractual basis regardless of marketing preference.

15.4 Where you have set responsible gambling deposit or loss limits, we will not send you promotional communications designed to encourage you to exceed those limits.

16 Amendments to This Privacy Policy

16.1 77f77 reserves the right to update or revise this Privacy Policy at any time. Where changes are material — for example, changes to the categories of data collected, new purposes for processing, or new third-party recipients — we will notify registered Users via the email address associated with their account, by in-platform notification, or by posting a prominent update notice on the website.

16.2 The effective date of the current version of this policy is shown at the top of the document. We recommend that you review this policy periodically to stay informed of any changes.

16.3 Continued use of the Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised policy, you should cease using the Platform and may request account closure.

17 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the handling of your personal data, please contact the 77f77 Data Protection team through the following channels:

We aim to acknowledge all data rights requests within 5 business days and to respond substantively within the timeframe required by applicable law — typically 30 calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days with prior notice to you.