77ccb Privacy Policy — How We Handle Your Personal Data

77ccb collects personal data across three main contexts: registration, ongoing account activity, and passive platform usage. The categories of data collected are as follows:

77ccb does not collect sensitive personal data such as racial or ethnic origin, religious beliefs, biometric data, or health information, except where a player voluntarily discloses such information in the course of a responsible gaming self-assessment.

Personal data collected by 77ccb is used exclusively for the following purposes:

• Account creation and management: Processing your registration, maintaining your Account, and verifying your identity in accordance with KYC requirements under our gaming licence.
• Payment processing: Executing deposits and withdrawal requests via JazzCash, EasyPaisa, Raast, bank transfer, and other supported PKR payment methods. Financial data is passed to payment processors only to the minimum extent required to complete each transaction.
• Fraud prevention and AML compliance: Monitoring account and transaction activity to detect and investigate fraud, money laundering, and misuse of the Platform in accordance with applicable anti-money laundering obligations.
• Customer support: Processing, tracking, and resolving support requests submitted via Live Chat or email, including maintaining records of correspondence for dispute resolution purposes.
• Regulatory compliance: Retaining records as required under the conditions of 77ccb's gaming licence, including records of player identity, transaction history, and responsible gaming interactions.
• Platform improvement: Analysing aggregated and anonymised usage patterns to improve Platform performance, game selection, and user experience. This analysis does not involve personal identification.
• Marketing communications: Sending promotional emails or in-account notifications about bonuses, offers, and new features — but only where you have opted in to receive such communications. You may withdraw consent at any time by contacting support.

77ccb processes personal data under the following legal bases:

• Contract performance: Processing necessary to provide the gaming services you have registered for, including account management, bet settlement, and payment processing.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering legislation, gaming licence conditions, and age verification obligations.
• Legitimate interests: Processing for fraud detection, platform security, internal analytics, and responsible gaming enforcement, where these interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw this consent at any time without affecting other processing activities.

5.1 We do not sell your data. 77ccb does not sell, rent, or trade your personal data to any third party for their own commercial purposes. This is an unconditional commitment.

5.2 Permitted sharing. Your personal data may be shared with the following categories of third party, strictly for the purposes described:

• Payment processors (JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, 1LINK): Provided with the minimum financial data necessary to execute deposit and withdrawal transactions. These processors operate under their own privacy policies and are independently regulated.
• KYC verification providers: Third-party identity verification services receive your submitted identity documents and CNIC data solely to complete the verification process required under our gaming licence.
• Game software providers: Certified third-party game suppliers may receive anonymised session identifiers necessary to deliver their games on the 77ccb Platform. No personal identity data is shared with game suppliers.
• Regulatory authorities: Gaming regulators, financial intelligence units, and law enforcement agencies may receive personal data where required by applicable law, a court order, or a valid regulatory directive.
• Group companies: Data may be shared within the 77ccb corporate group for internal administrative and compliance purposes, subject to equivalent data protection standards.

5.3 International transfers. Where personal data is transferred outside Pakistan — for example, to a KYC verification provider or a game software supplier based in another jurisdiction — 77ccb ensures that appropriate contractual safeguards are in place to maintain a standard of protection equivalent to that described in this Policy.

77ccb retains personal data only for as long as necessary for the purposes set out in this Policy, or as required by applicable law and licensing conditions. The following retention periods apply:

After the applicable retention period expires, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original information.

77ccb applies a layered approach to data security. The following technical and organisational measures are in place to protect your personal data:

• Encryption in transit: All data transmitted between your device and the 77ccb Platform is encrypted using TLS 1.2 or higher. The platform operates exclusively over HTTPS.
• Encryption at rest: Personal data stored in 77ccb's databases is encrypted using AES-256. Encryption keys are managed separately from the encrypted data stores.
• Access controls: Access to personal data within 77ccb is granted strictly on a need-to-know basis. All internal access to player data is logged and subject to periodic review.
• Two-factor authentication: 77ccb accounts support two-factor authentication (2FA), which is strongly recommended for all players. Players in Lahore, Karachi, Islamabad, and other major cities are encouraged to enable 2FA from Account settings.
• Penetration testing: The 77ccb Platform undergoes periodic security assessments by independent third-party security professionals to identify and remediate vulnerabilities.
• Incident response: In the event of a data breach that poses a risk to player privacy, 77ccb will notify affected players and, where required, the relevant regulatory authority, within the timeframes specified under applicable obligations.

77ccb uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and maintain session security. The following cookie categories are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens and CSRF protection cookies. They cannot be disabled without breaking core functionality.
• Functional cookies: Used to remember your language preference, display settings, and previously selected payment method. These improve your experience but are not essential to core function.
• Analytics cookies: Used in anonymised form to understand how players navigate the Platform — which pages are most visited, where sessions typically end, and which features are underused. 77ccb does not use Google Analytics or other third-party analytics services that transmit identified player data externally.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may result in reduced Platform functionality, including the inability to maintain a logged-in session. Disabling functional or analytics cookies will not affect your ability to place bets or access your Account.

Subject to applicable law and licensing obligations, you hold the following rights in relation to your personal data held by 77ccb. To exercise any of these rights, contact us at [email protected] with your registered account email and a clear description of your request. Requests will be acknowledged within three (3) business days and completed within thirty (30) calendar days.

• Right of access: You may request a copy of all personal data we hold about you, along with information about how it is processed. This is commonly referred to as a Subject Access Request (SAR).
• Right to rectification: Where personal data we hold is inaccurate or incomplete, you have the right to request correction. For identity and KYC data, updated documentation may be required.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes collected, where consent has been withdrawn, or where processing was unlawful. Note that data subject to legal retention obligations (such as AML-required transaction records) cannot be deleted until the applicable retention period has elapsed.
• Right to restriction of processing: You may request that we restrict processing of your data while a dispute or complaint is being resolved, or while we verify the accuracy of data you have contested.
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV) for the purpose of transferring it to another service provider.
• Right to object: You may object to processing of your data for direct marketing purposes at any time. We will action this immediately. You may also object to other processing based on legitimate interests, though we may be required to continue processing where compelling legitimate grounds exist.

The 77ccb Platform is strictly intended for adults. You must be at least twenty-one (21) years of age to register an Account or use any feature of the Platform. 77ccb does not knowingly collect personal data from individuals under the age of 21.

Where 77ccb becomes aware that an Account has been created by or on behalf of a person under 21 years of age, the Account will be immediately suspended, all related personal data will be deleted in accordance with our data minimisation obligations, and any balance in the Account will be forfeited in line with our Terms & Conditions.

If you believe a minor may have created a 77ccb Account, please contact us immediately at [email protected] so that we can investigate and take the necessary action without delay.

77ccb reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. When material changes are made, we will update the effective date at the top of this document and, where practicable, provide registered players with advance notice via their registered email address or an in-account notification.

Continued use of the 77ccb Platform after a revised Privacy Policy becomes effective constitutes your acknowledgement of the updated terms. If you do not agree with any revision, you should cease using the Platform and may request account closure in accordance with our Terms & Conditions.

For all privacy-related queries, data subject access requests, or complaints regarding how 77ccb processes your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 from within your logged-in 77ccb Account — the fastest way to reach our support team for straightforward queries.
• Email: [email protected] — for formal data subject requests, complaints, or detailed privacy inquiries. Please include your registered email address and a clear description of your request.