77y888 Privacy Policy

01 Introduction

77y888 is committed to protecting the privacy and personal data of all users. This Policy sets out in clear, structured terms what personal data we collect, why we collect it, how we use it, with whom we share it, how long we retain it and what rights you have in relation to it.

This Policy should be read alongside our Terms & Conditions, which govern the contractual relationship between you and 77y888. In any conflict between this Policy and the Terms & Conditions on a privacy matter, this Policy prevails.

77y888 does not claim to be registered, licensed or regulated as a data controller under Pakistani law, including the Personal Data Protection Bill or any enacted successor legislation. However, we are committed to handling personal data responsibly regardless of jurisdiction, and this Policy reflects those commitments.

02 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, postal address, national identity number, financial account details and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, erasure or destruction.
• "Data Controller" refers to 77y888 as the entity that determines the purposes and means of processing Personal Data.
• "Data Processor" refers to any third party that processes Personal Data on behalf of 77y888, such as payment processors, KYC verification providers and analytics services.
• "KYC" (Know Your Customer) refers to the identity and age verification process conducted for regulatory compliance and player protection purposes.
• "Cookies" refers to small data files placed on your device by the Platform for session management, analytics and preference storage.
• "Sensitive Data" refers to categories of Personal Data that warrant heightened protection, including identity document numbers and financial information.

03 Data We Collect

3.1 Data Provided Directly by You

When you register, verify your account, make deposits or contact support, you provide us with data including:

Data Category	Examples	Purpose
Identity Data	Full name, date of birth, gender, CNIC / passport number	Account registration, KYC age and identity verification
Contact Data	Email address, phone number, residential address (city, province)	Account communication, support, transaction notifications
Financial Data	Payment method details (wallet reference, bank name, crypto wallet address)	Deposit and withdrawal processing, fraud prevention
KYC Documents	CNIC image, passport scan, proof of address document	Identity verification, AML compliance
Account Preferences	Responsible gambling limits, communication preferences, language settings	Platform personalisation, responsible play management
Support Communications	Live Chat transcripts, email correspondence	Issue resolution, service improvement, compliance record-keeping

3.2 Data Collected Automatically

When you access and use the Platform, we automatically collect:

• Device and Technical Data: IP address, device type, operating system, browser type and version, screen resolution.
• Usage Data: Pages visited, features used, time spent on pages, click patterns, betting and gaming activity logs.
• Session Data: Login timestamps, session duration, logout events.
• Location Data: General geographic location inferred from IP address (country, city level). We do not collect precise GPS-level location without explicit consent.

3.3 Data from Third Parties

We may receive Personal Data about you from third-party service providers engaged to assist with KYC verification, fraud detection, payment processing and responsible gambling compliance. Such data is used only for the specific purpose for which it was obtained and is subject to the same protections as data collected directly.

04 Data Processing

77y888 processes your Personal Data for the following purposes:

• Account Creation and Management: Registering your account, maintaining account records, communicating account-related information and managing your account preferences.
• KYC and Age Verification: Verifying your identity, age and eligibility to use the Platform in accordance with our Terms and applicable regulatory requirements.
• Transaction Processing: Processing deposits and withdrawals via referenced payment methods, reconciling account balances and maintaining financial records.
• Fraud Prevention and AML Compliance: Monitoring account activity for signs of fraud, money laundering, collusion or other prohibited conduct. Complying with anti-money laundering obligations applicable to the Platform's licensing jurisdiction.
• Responsible Gambling Management: Recording and enforcing responsible gambling limits set by you, administering self-exclusion periods and monitoring for signs of problem gambling behaviour.
• Platform Operation and Improvement: Analysing usage patterns to improve platform performance, user experience and game offering. Diagnosing and resolving technical issues.
• Customer Support: Responding to enquiries, resolving disputes and maintaining support records.
• Legal and Regulatory Compliance: Meeting obligations under applicable law, responding to lawful requests from regulatory or law enforcement authorities, and maintaining records for audit purposes.
• Marketing Communications: Sending promotional offers and platform updates to players who have opted in to marketing communications. You may opt out at any time by contacting support or adjusting your account communication preferences.

05 Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing, 77y888 processes your Personal Data under one or more of the following bases:

• Contractual Necessity: Processing required to perform our contractual obligations to you under the Terms & Conditions, including account management, transaction processing and KYC verification.
• Legal Obligation: Processing necessary to comply with applicable legal and regulatory requirements, including anti-money laundering obligations.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, responsible gambling monitoring and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit consent, including marketing communications and certain optional data collection. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing

We may share your Personal Data with the following categories of recipients, strictly for the purposes described in this Policy:

6.1 Service Providers and Data Processors

We engage trusted third-party service providers who process data on our behalf, under contractual data processing agreements, for purposes including:

• KYC and identity verification providers
• Payment processors and fraud detection services
• Cloud hosting and data storage providers
• Customer support technology providers
• Analytics and platform performance monitoring services
• Responsible gambling technology providers

All Data Processors are contractually required to handle your data securely and only for the purposes we specify.

6.2 Regulatory and Legal Authorities

We may disclose Personal Data to regulatory bodies, law enforcement agencies or other governmental authorities when required to do so by applicable law, court order or to protect the safety and security of the Platform and its users.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the Platform's business, Personal Data held by 77y888 may be transferred to the successor entity, subject to the same privacy protections set out in this Policy.

6.4 No Sharing with Pakistani Payment Providers for Marketing

Payment references on the 77y888 platform, including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah, are contextual references only. 77y888 does not share your Personal Data with these institutions for marketing purposes, nor does it represent that these providers have any relationship with or endorsement of the Platform.

07 Data Retention

77y888 retains Personal Data only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory and audit obligations. The following indicative retention periods apply:

Data Category	Retention Period
Account registration and identity data	Duration of active account + 5 years after account closure
KYC documents	Duration of active account + 5 years after account closure (AML compliance)
Transaction and financial records	7 years from the date of the transaction
Betting and gaming activity logs	5 years from the date of activity
Support communications	3 years from the date of the communication
Self-exclusion records	Indefinitely (to prevent re-registration during an active exclusion period)

After the applicable retention period, Personal Data is securely deleted or anonymised. Data required for ongoing legal proceedings or regulatory investigations may be retained beyond the above periods until those matters are resolved.

08 Security Measures

77y888 implements technical and organisational security measures proportionate to the sensitivity of the data we hold and the risks associated with our processing activities. These measures include:

• Encryption in Transit: All data transmitted between your browser or device and the Platform is encrypted using TLS (Transport Layer Security).
• Encryption at Rest: Sensitive data including KYC documents and financial records is encrypted at rest using industry-standard algorithms.
• Access Controls: Personal Data is accessible only to authorised personnel with a documented operational need. Access is governed by role-based permission controls and audit logging.
• Security Monitoring: Our systems are monitored for unauthorised access attempts, anomalous activity and potential security incidents on a continuous basis.
• Incident Response: We maintain a documented data breach response procedure. In the event of a breach likely to affect your rights and freedoms, we will notify affected players and relevant authorities as required under applicable law.

While we take reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials. If you suspect your account has been compromised, contact us immediately via Live Chat.

09 Cookies & Tracking Technologies

9.1 What Are Cookies

Cookies are small text files stored on your device when you visit a website. 77y888 uses cookies and similar technologies (including local storage and session tokens) to operate core platform functions and improve user experience.

9.2 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. These cannot be disabled without preventing you from using the Platform.
• Functional Cookies: Store your preferences such as language settings and responsible gambling limit configurations.
• Analytics Cookies: Collect aggregated, anonymised data about how users interact with the Platform, helping us identify usability issues and improve performance.
• Security Cookies: Help detect and prevent fraudulent activity and unauthorised account access.

9.3 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to block, delete or restrict cookies. Note that disabling essential cookies will impair core Platform functionality including login and account management. For specific instructions, refer to your browser's help documentation.

10 User Rights

Subject to applicable law and the limitations described below, you have the following rights in relation to your Personal Data held by 77y888:

To exercise any of the above rights, contact our support team via Live Chat or by email at [email protected] (plain text — not a clickable link). We will respond to verified requests within 30 days. We may request proof of identity before processing your request.

11 Minors & Age Policy

If you are a parent or guardian and believe that a minor has registered on the Platform or provided Personal Data to us, please contact our support team immediately via Live Chat or email. We take such reports seriously and will act promptly.

12 International Data Transfers

77y888 operates internationally and your Personal Data may be transferred to and processed in countries other than Pakistan. These may include countries where the applicable data protection laws differ from those in Pakistan.

Where we transfer data internationally, we take steps to ensure that appropriate safeguards are in place, including contractual protections with Data Processors. If you have concerns about international data transfers, you may contact our support team for further information.

13 Pakistan Context & Local Considerations

77y888 serves players located in Pakistan, including users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We are aware of the developing data protection regulatory landscape in Pakistan and are committed to handling personal data responsibly.

Pakistan's personal data protection framework is evolving. To the extent that any enacted Pakistani data protection legislation applies to the processing activities described in this Policy, 77y888 will endeavour to comply with applicable requirements. However, 77y888 does not represent itself as a registered data controller under Pakistani law at this time.

If you believe that your data protection rights under applicable Pakistani law have been infringed, you may wish to seek independent legal advice or contact the relevant Pakistani regulatory authority.

14 Policy Amendments

77y888 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, we will provide notice by email to registered players or by prominent notice on the Platform. The "Last Updated" date at the top of this page will always reflect the current version.

Continued use of the Platform after the effective date of any amended Privacy Policy constitutes your acknowledgement of the updated terms. We encourage you to review this Policy periodically.

15 Contact Us

For all privacy-related enquiries, data subject access requests or complaints regarding how 77y888 handles your Personal Data, please contact us through the following channels:

• Live Chat: Available 24/7 via the Help Center on the Platform. This is the fastest channel for urgent privacy concerns.
• Email: [email protected] (plain text — not a clickable link). Please mark the subject line as "Privacy Request" to ensure correct routing.

We aim to acknowledge all privacy-related requests within 5 business days and to resolve them within 30 calendar days. Complex requests may require additional time, in which case we will notify you of the extended timeline.