77cd Privacy Policy

This Policy explains what personal data 77cd collects about you, why we collect it, how we use it, with whom we may share it, how long we keep it, and what rights you have in relation to your personal data. We are committed to being transparent and straightforward in how we communicate our data practices — players in Pakistan and elsewhere deserve to understand clearly how the platform they trust handles their personal information.

77cd operates under an international gaming licence framework that imposes legally binding data protection, KYC, and AML obligations on us. Compliance with those obligations requires us to collect and retain certain categories of personal data. Where we do so, we explain our lawful basis in Section 5 of this Policy.

For the purposes of applicable data protection law, 77cd is the data controller in respect of the personal data it collects and processes from players and users of the 77cd platform. As data controller, 77cd determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable legal requirements.

Where 77cd engages third-party service providers to process personal data on its behalf (for example, payment processors and identity verification providers), those parties act as data processors and are contractually required to process your data only on 77cd's instructions and in accordance with appropriate security standards.

If you have any questions regarding 77cd's role as data controller or wish to exercise any of your data subject rights, please contact 77cd using the details provided in Section 15 of this Policy.

77cd collects personal data from you in three primary ways: data you provide directly, data collected automatically when you use the platform, and data received from third parties in connection with payment processing and identity verification. The categories of personal data we collect are set out in the table below.

77cd does not collect or process any special categories of sensitive personal data (such as health data, racial or ethnic origin data, religious beliefs, or biometric data) except where strictly required by KYC regulations and with your explicit consent or under a specific legal obligation.

77cd uses the personal data it collects for the following purposes:

• Account creation and management: To register your 77cd account, verify your identity and age, maintain your PKR Wallet, and manage your account settings and preferences.
• Payment processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, USDT TRC20, and any other supported payment methods, and to maintain accurate transaction records.
• Gaming services: To allow you to play casino games, place sports bets, participate in promotions, and access all features of the 77cd platform.
• KYC and AML compliance: To verify your identity, assess the source of funds where required, detect suspicious activity, prevent money laundering, and comply with our obligations under the 77cd international gaming licence framework.
• Fraud prevention and security: To detect, investigate, and prevent fraud, cheating, collusion, account takeover attempts, and other prohibited activities on the 77cd platform.
• Customer support: To respond to your queries, complaints, and requests, and to maintain records of your communications with the 77cd support team.
• Responsible gaming: To monitor your gaming behaviour in connection with responsible gaming obligations, enforce self-exclusion periods, apply deposit and loss limits you have set, and identify players who may need support.
• Platform improvement: To analyse aggregated, anonymised usage data to improve the performance, features, and user experience of the 77cd platform.
• Legal compliance: To comply with applicable laws, regulations, court orders, and regulatory requirements, and to defend 77cd's legal rights where necessary.
• Marketing communications: To send you promotional offers and updates about 77cd, where you have consented to receive such communications or where we have a legitimate interest in doing so, subject always to your right to opt out (see Section 11).

77cd processes your personal data on the following legal bases, as applicable to each processing activity:

• Performance of a contract: Processing necessary to create and manage your 77cd account, process payments, deliver gaming services, and fulfil our obligations under the Terms and Conditions is carried out on the basis that it is necessary for the performance of our contract with you as a registered player.
• Legal obligation: Processing carried out to comply with KYC, AML, licensing, tax, and other regulatory requirements is carried out on the basis that it is necessary for compliance with a legal obligation to which 77cd is subject.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement is carried out on the basis of 77cd's legitimate interest in operating a safe, fair, and compliant gaming platform, provided such interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications is carried out on the basis of your consent, where we have obtained such consent. You may withdraw your consent at any time as described in Section 11.

77cd does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly for the purposes described:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers receive the minimum personal and financial data necessary to process your deposit and withdrawal transactions. These providers are independently regulated financial institutions operating under their own data protection obligations.
• Identity verification providers: Third-party KYC and identity verification services may receive copies of your identification documents and personal details for the purpose of performing age and identity verification in accordance with our gaming licence requirements.
• Gaming software providers: Game providers whose titles are offered on the 77cd platform may receive anonymised or pseudonymised technical data necessary to operate their games. They do not receive your full identity or contact data unless required for regulatory purposes.
• Regulatory and law enforcement authorities: 77cd may be required by law, court order, or regulatory directive to disclose personal data to gaming regulators, financial intelligence units, tax authorities, law enforcement agencies, or other competent authorities. 77cd will comply with all such lawful requests.
• Legal and professional advisers: 77cd's legal counsel, auditors, and other professional advisers may access personal data on a confidential, need-to-know basis where required to provide professional services to 77cd.
• Fraud prevention networks: 77cd may share data with cross-industry fraud prevention databases or networks where necessary to prevent, detect, or investigate suspected fraud or financial crime affecting the 77cd platform.

In all cases where 77cd shares data with third-party processors, those processors are contractually required to maintain appropriate technical and organisational security measures and to use your data only for the specific purpose for which it was shared.

The 77cd platform uses cookies and similar tracking technologies to operate core site functionality, maintain your session when you are logged in, remember your preferences, and collect anonymised analytics data to help us understand how the platform is used and where it can be improved.

The categories of cookies used by 77cd include:

• Strictly necessary cookies: Required for the 77cd platform to function. These include session cookies that keep you logged in during your visit and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as display settings or preferred language, to provide a more personalised experience on 77cd.
• Analytics cookies: Used to collect anonymised data about how players navigate and use the 77cd platform, which pages are most visited, and where users experience difficulties. This data is used exclusively to improve the platform and is not linked to your identity.

You can control cookie settings through your browser preferences. Note that disabling strictly necessary cookies may prevent certain features of the 77cd platform from functioning correctly. For mobile users in Pakistan accessing 77cd via a smartphone browser, cookie settings can typically be managed through the browser's privacy settings menu.

77cd implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• TLS encryption for all data transmitted between your device and the 77cd platform, protecting your data in transit from interception.
• Encryption at rest for all stored personal data, including identity verification documents, financial data, and account records.
• Isolated, access-controlled storage for KYC documents, with access restricted to authorised personnel with a documented need to review such materials.
• Regular security assessments and penetration testing of the 77cd platform infrastructure.
• Multi-factor authentication requirements for internal staff accessing systems containing player data.
• Formal data breach response procedures, including assessment, containment, and notification protocols.

In the event of a data breach that poses a risk to your rights and interests, 77cd will notify affected players and relevant regulatory authorities in accordance with applicable legal requirements and without undue delay.

77cd retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting requirements. The key retention periods that apply to different categories of 77cd player data are as follows:

• Active account data: Identity, contact, financial, gaming, and account data associated with an active 77cd account is retained for the full duration of your account's active status.
• Closed account data: Following account closure — whether initiated by you or by 77cd — personal data is generally retained for a period of five (5) years from the date of closure. This retention period is required to comply with AML record-keeping obligations, gaming licence requirements, and to handle any post-closure complaints or legal claims.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of collection or from the date of account closure, whichever is later, as required by applicable AML and gaming regulations.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction in accordance with standard financial record-keeping requirements.
• Support communications: Records of customer support interactions are retained for a period of three (3) years from the date of the interaction, unless a specific matter requires extended retention for legal or compliance reasons.
• Self-exclusion records: Records of self-exclusion requests are retained indefinitely to prevent individuals from circumventing exclusions by registering new accounts at a later date.

Where retention of personal data beyond these periods serves no legitimate purpose and is not required by law, 77cd will securely delete or anonymise that data.

77cd respects your rights in relation to your personal data. Depending on applicable law, you may have the following rights in relation to the personal data 77cd holds about you:

To exercise any of these rights, please contact the 77cd support team using the details provided in Section 15. 77cd will respond to all valid requests within 30 days of receipt. In certain circumstances, 77cd may be unable to comply with a request — for example, where deletion of data would prevent 77cd from meeting its AML or gaming licence obligations — in which case we will explain the reason for our inability to comply.

77cd may send you promotional emails, SMS messages, or on-platform notifications about bonuses, new games, sporting events, and other 77cd offers where you have consented to receive such communications at the time of registration or subsequently, or where 77cd has a legitimate interest in informing you of relevant platform updates.

You may opt out of marketing communications from 77cd at any time by:

• Clicking the "unsubscribe" link included in any marketing email sent by 77cd.
• Updating your communication preferences in your 77cd account settings.
• Contacting the 77cd support team and requesting that your account be removed from marketing lists.

Please note that opting out of marketing communications will not affect transactional or account-related communications from 77cd. You will continue to receive communications that are necessary for the operation of your account, such as payment confirmations, security alerts, and responses to your support queries, regardless of your marketing communication preferences.

The 77cd platform is strictly for persons aged 21 years and above. 77cd does not knowingly collect personal data from individuals under the age of 21. If 77cd becomes aware that personal data has been collected from a person under the age of 21 — whether through misrepresentation during registration or otherwise — 77cd will take immediate steps to close the relevant account, delete the collected data to the extent not required for legal reporting purposes, and report the matter to relevant authorities where required.

If you are a parent or guardian and believe that a minor under the age of 21 has accessed the 77cd platform or provided personal data to 77cd, please contact our support team immediately at the details provided in Section 15. We take these matters very seriously and will act promptly upon receiving such a report.

As an internationally operating gaming platform, 77cd's data infrastructure and certain third-party service providers may be located outside Pakistan. Where personal data is transferred to countries outside Pakistan for processing purposes — for example, to identity verification providers, cloud infrastructure providers, or gaming software partners — 77cd takes steps to ensure that appropriate safeguards are in place to protect your personal data in accordance with the standards set out in this Privacy Policy.

Such safeguards may include standard contractual clauses between 77cd and the recipient entity, transfer only to jurisd ictions with adequate data protection standards, or other legally recognised data transfer mechanisms.

If you have questions about the specific safeguards applied to international transfers of your data, please contact 77cd using the details in Section 15.

77cd may update this Privacy Policy from time to time to reflect changes in our data practices, changes in applicable law, or changes to the features and services offered on the 77cd platform. Where changes to this Policy are material — meaning they significantly affect how 77cd collects, uses, or protects your personal data — 77cd will provide reasonable advance notice of the changes via:

• A prominent notice displayed on the 77cd platform upon your next login following the update.
• An email notification to your registered email address.
• An SMS notification to your registered mobile number, where appropriate.

Your continued use of the 77cd platform after the effective date of an updated Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree with the updated Privacy Policy, you should cease using the 77cd platform and contact support to arrange closure of your account and return of any eligible balance.

The effective date of the current version of this Privacy Policy is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how 77cd is protecting your data.

If you have any questions, concerns, or requests in relation to this Privacy Policy, how 77cd processes your personal data, or any of your data subject rights, please contact the 77cd support team. We aim to respond to all privacy-related queries within a reasonable timeframe, typically within 30 days of receipt.

Contact 77cd Privacy Enquiries:

Email: [email protected] (plain text — not a clickable link)

In your message, please include:

• Your full name and 77cd account username (if you have an account).
• A clear description of your query or the data subject right you wish to exercise.
• Any supporting information or documentation that may assist 77cd in responding to your request.

Where your query relates to a formal complaint about 77cd's handling of your personal data, we will work with you in good faith to resolve the matter. If you remain dissatisfied following 77cd's response, you may have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction or under the jurisdiction applicable to 77cd's international gaming licence.