77xs Privacy Policy — How We Protect Your Personal Data

1. Who We Are

77xs is an internationally licensed online gaming and sports betting platform accessible at https://77xs.app. References to "77xs", "we", "us", or "our" in this Policy refer to the operators and licensees of the 77xs platform. 77xs acts as the data controller in respect of the personal data of its registered members and website visitors.

We serve members across Pakistan, including players in Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, and other cities. This Policy applies to all members regardless of their city or region of residence within our service territory. For any privacy-related queries, you may contact us directly at [email protected] — please note this address is displayed as plain text and is not a clickable link.

2. Personal Data We Collect

77xs collects personal data through several channels: during account registration, in the course of ongoing platform use, through KYC verification, via payment transactions, and through automated technical processes. The categories of personal data we collect include:

2.1 Identity & Registration Data

• Full legal name as it appears on a government-issued identity document;
• Date of birth (for age verification purposes — members must be 21 or older);
• Gender (optional, collected during registration);
• Nationality and country of residence;
• Username and encrypted account password;
• National Identity Card (CNIC) number or passport number, where required for KYC.

2.2 Contact Data

• Email address;
• Mobile phone number (used for account verification and support communications);
• Residential address including city, province, and postal code.

2.3 Financial & Payment Data

• Deposit and withdrawal transaction records;
• Payment method identifiers (e.g., JazzCash account number, EasyPaisa wallet ID, HBL or UBL account reference, SadaPay ID, or partial card details);
• Account balance history and wagering transaction logs;
• Bonus credit and redemption records.

2.4 KYC Verification Documents

• Copies of government-issued photo identity documents (CNIC, passport, driving licence);
• Proof of address documents (utility bills, bank statements);
• Proof of payment method ownership;
• Any additional documents submitted during enhanced due diligence.

2.5 Technical & Usage Data

• IP address and approximate geolocation data;
• Device type, operating system, and browser information;
• Session duration, login timestamps, and access logs;
• Pages visited, games accessed, and features used within the platform;
• Cookie identifiers and similar tracking technologies (see Section 6).

2.6 Communications Data

• Records of support communications, including live chat transcripts and email correspondence;
• Feedback, survey responses, and complaint records;
• Marketing preferences and communication opt-in/opt-out status.

3. How We Use Your Personal Data

77xs uses the personal data we collect for the following specific purposes:

Purpose	Data Categories Used
Account creation & management	Identity data, contact data, login credentials
Age & identity verification (KYC)	Identity data, KYC documents, date of birth
Processing deposits & withdrawals	Financial data, payment method identifiers, identity data
Fraud prevention & security monitoring	Technical data, financial data, identity data, usage data
Regulatory compliance & AML obligations	Identity data, KYC documents, financial data
Customer support communications	Contact data, communications data, account data
Marketing & promotional communications	Contact data, usage data (with consent only)
Responsible gaming monitoring	Usage data, financial data, account behaviour
Platform improvement & analytics	Technical data, usage data (anonymised where possible)

4. Legal Basis for Processing

77xs processes personal data only where a valid legal basis exists. The legal bases upon which we rely are as follows:

• Contractual necessity: Processing required to fulfil our contractual obligations to you as a 77xs member, including account management, payment processing, and providing access to gaming services;
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) regulations, KYC obligations under our gaming licence, and fraud prevention requirements;
• Legitimate interests: Processing necessary for 77xs's legitimate business interests, including platform security, fraud detection, responsible gaming monitoring, and improving our services — provided such interests are not overridden by your fundamental rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — in particular, for marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Sharing Your Personal Data

77xs does not sell your personal data. We may share your personal data with third parties only in the following limited and controlled circumstances:

5.1 Payment Service Providers

To process deposits and withdrawals, 77xs shares necessary financial and identity data with payment processors including JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, and card payment networks. All payment partners are contractually obligated to process your data solely for the purpose of completing transactions and to maintain appropriate data security standards.

5.2 KYC & Identity Verification Providers

77xs works with regulated third-party KYC and identity verification providers to fulfil its compliance obligations under its international gaming licence. These providers receive the minimum necessary personal and documentary data required to complete verification and are contractually prohibited from using your data for any other purpose.

5.3 Regulatory & Law Enforcement Authorities

77xs may be required to disclose personal data to regulatory authorities, law enforcement agencies, or gaming licensing bodies where required by applicable law, court order, or regulatory obligation. Such disclosures will be limited to what is strictly necessary and will be made in accordance with applicable legal requirements.

5.4 Technology & Infrastructure Partners

77xs uses third-party technology providers for hosting, security, analytics, and platform operations. These providers act as data processors under contract and may process personal data on 77xs's behalf solely to deliver the agreed services. All such partners are bound by data processing agreements that require compliance with applicable data protection standards.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or a material part of 77xs's business assets, personal data held by 77xs may be transferred to the acquiring entity. In such circumstances, 77xs will notify affected members before their personal data becomes subject to a different privacy policy.

6. Cookies & Tracking Technologies

77xs uses cookies and similar tracking technologies on the platform to ensure proper functionality, improve user experience, and support security and analytics. The categories of cookies we use are as follows:

• Essential cookies: Required for the platform to function. These include session management cookies, login authentication tokens, and security cookies. These cannot be disabled without affecting platform functionality;
• Functional cookies: Used to remember your preferences such as language settings, display options, and responsible gaming tool configurations;
• Analytics cookies: Used to collect aggregated, anonymised data about how members use the platform, which pages are visited most frequently, and where technical errors occur. This data is used solely to improve the platform;
• Marketing cookies: Used to track whether you arrived at 77xs via a promotional campaign. These cookies are only set with your consent and may be disabled via your cookie preferences.

You may manage your cookie preferences at any time through your browser settings or via the cookie preference centre available on the 77xs platform. Please note that disabling essential cookies will affect your ability to use the platform.

7. Data Retention

77xs retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and regulatory obligations. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your active membership and for a minimum of five (5) years following account closure, in compliance with AML and gaming licence record-keeping requirements;
• KYC documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Financial transaction records: Retained for a minimum of five (5) years in accordance with financial record-keeping obligations;
• Technical and usage logs: Retained for a maximum of twelve (12) months from the date of collection, after which they are deleted or fully anonymised;
• Marketing communications data: Retained until you withdraw consent or unsubscribe, after which it is deleted within 30 days;
• Support communications: Retained for three (3) years from the date of the communication, unless the subject matter relates to an unresolved dispute or regulatory matter.

8. Data Security

77xs implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 77xs platform;
• Encryption of sensitive data at rest, including KYC documents and payment information;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Two-factor authentication (2FA) available for all member accounts;
• Automated fraud detection and suspicious activity monitoring systems;
• Staff training on data protection obligations and security best practices.

While 77xs takes every reasonable precaution to protect your data, no online platform can guarantee absolute security. You also have a responsibility to keep your account credentials secure. Please review Section 5 of the 77xs Terms & Conditions for your account security obligations.

9. Your Data Protection Rights

As a 77xs member and data subject, you have the following rights in respect of your personal data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request":

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal and regulatory retention obligations;
• Right to Restriction: You have the right to request that we restrict processing of your personal data in certain circumstances, such as while a dispute is being resolved;
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to request that it be transmitted to another controller where technically feasible;
• Right to Object: You have the right to object to processing of your personal data based on legitimate interests, and to opt out of direct marketing communications at any time;
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

77xs will respond to all data rights requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reasons for it.

10. Children & Minors

The 77xs platform is strictly intended for adults aged 21 years and over. 77xs does not knowingly collect, process, or retain personal data from individuals under the age of 21. If we become aware that personal data has been submitted by a person under 21, we will immediately close the associated account, delete the data, and take appropriate action in accordance with our child protection obligations.

If you are a parent or guardian and believe that a minor may have registered an account on 77xs or submitted personal data to us, please contact us immediately at [email protected] so we can take prompt remedial action.

11. International Data Transfers

77xs operates as an internationally licensed gaming platform. As a result, your personal data may be processed by servers or service providers located outside of Pakistan. In all cases where personal data is transferred internationally, 77xs ensures that appropriate safeguards are in place to protect your data, including contractual clauses requiring recipient parties to maintain data protection standards consistent with this Policy and applicable international data protection frameworks.

By using the 77xs platform, you acknowledge that your personal data may be transferred to and processed in countries outside your country of residence, subject to the safeguards described in this section.

12. Third-Party Services & Links

The 77xs platform may reference or integrate with third-party services, including game software providers and payment gateways. These third parties operate their own privacy policies and data processing practices, for which 77xs accepts no responsibility. We encourage you to review the privacy policies of any third-party services you interact with. 77xs does not control and is not responsible for the content or privacy practices of any third-party service providers.

13. Updates to This Privacy Policy

77xs reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will notify registered members via email to the address on file or via a prominent in-platform notification prior to the changes taking effect. The version date at the top of this Policy indicates when it was last reviewed and updated.

Your continued use of the 77xs platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. We recommend reviewing this Policy periodically to remain informed of how your data is being handled.

14. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a concern about how 77xs handles your personal data, please contact our dedicated privacy support team:

• Email: [email protected] (plain text only — this is not a clickable link)
• Subject line: "Privacy Policy Query" or "Data Rights Request"
• Response time: We aim to respond to all privacy-related queries within 5 business days

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter through the dispute resolution mechanism available under the 77xs gaming licence framework, or to seek independent advice regarding your data protection rights.