77game Privacy Policy – How We Protect Your Personal Data

1 Who We Are (Data Controller)

For the purposes of this Privacy Policy, 77game acts as the Data Controller in respect of personal data collected through its platform at 77game.bio and any associated applications. As Data Controller, 77game determines the purposes and means by which your personal data is processed. References to "we", "us", or "our" in this policy refer to 77game in its capacity as Data Controller.

If you have any questions about how 77game processes your personal data, or wish to exercise your data rights, please contact us using the details in Section 13 of this policy.

2 Personal Data We Collect

77game collects personal data in the following categories:

77game does not collect special category data (such as racial or ethnic origin, health data, or biometric data) except where CNIC-based identity verification necessarily involves reviewing a document that incidentally contains such information, in which case it is processed solely for the purpose of age and identity verification and is not retained beyond what is required.

3 How 77game Uses Your Personal Data

77game processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your 77game account, including processing deposits and withdrawals in PKR via JazzCash, Easypaisa, HBL, UBL, and other supported methods;
• Identity and age verification: To verify that you are 18 years of age or older before allowing access to real-money games and withdrawal processing;
• Legal and regulatory compliance: To fulfil anti-money laundering (AML) obligations, fraud prevention requirements, and any other applicable regulatory obligations;
• Responsible gaming: To monitor account activity for signs of problem gambling behaviour and to enforce self-exclusion, deposit limits, and other responsible gaming tools activated on your account;
• Customer support: To respond to your queries, investigate complaints, and resolve disputes;
• Platform improvement: To analyse aggregated usage data to improve game performance, interface usability, and overall platform quality;
• Marketing communications: To send promotional offers, bonus notifications, and platform updates to users who have opted in to marketing communications. You may opt out at any time through your account settings or by contacting support;
• Security: To detect, prevent, and investigate fraudulent activity, cheating, bonus abuse, and unauthorised account access.

4 Legal Basis for Processing

77game processes your personal data on the following legal bases:

• Contract performance: Processing necessary to perform the contract between you and 77game, including operating your account, processing transactions, and delivering the gaming services you have requested;
• Legal obligation: Processing required to comply with applicable legal obligations, including AML requirements and age verification;
• Legitimate interests: Processing carried out in 77game's legitimate interests, including fraud prevention, platform security, and analysis of aggregate usage data to improve services, where those interests are not overridden by your data protection rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Sharing Your Personal Data

5.1 77game does not sell your personal data. We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

5.2 We may share your personal data with the following categories of recipients where necessary to deliver our services:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Visa/Mastercard network processors, and USDT wallet infrastructure providers, for the purpose of processing deposits and withdrawals;
• Identity verification services: Third-party KYC providers engaged to assist with document verification and age verification;
• Game software providers: Including Pragmatic Play, Evolution Gaming, PG Soft, and other certified studios, who receive limited technical data necessary to deliver game functionality;
• Technology and infrastructure providers: Hosting, cloud storage, content delivery, and cybersecurity providers engaged under data processing agreements that bind them to confidentiality and security obligations;
• Legal and regulatory authorities: Where required by applicable law, court order, or regulatory request, 77game may disclose personal data to relevant authorities without prior notice to the affected user.

5.3 All third parties with whom 77game shares personal data are contractually required to handle that data in accordance with applicable data protection standards and to use it solely for the specific purpose for which it was disclosed.

6 Cookies and Tracking Technologies

6.1 The 77game platform uses cookies and similar tracking technologies to ensure platform functionality, maintain your session while logged in, remember your preferences, and analyse how the platform is used in aggregate.

6.2 The following categories of cookies are used by 77game:

• Strictly necessary cookies: Required for the platform to function. These cannot be disabled as they enable core features such as account login sessions and security tokens;
• Performance and analytics cookies: Used to collect anonymised information about how users interact with the platform, helping us improve usability and performance;
• Functional cookies: Used to remember your preferences, such as language settings and UI customisations;
• Marketing cookies: Used only where you have given consent. These may track your interaction with 77game promotions to ensure relevant offers are shown.

6.3 You can manage cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality. Strictly necessary cookies cannot be opted out of while using the platform.

7 Data Retention

7.1 77game retains your personal data for as long as your account remains active and for a period thereafter as required by applicable legal, regulatory, and audit obligations. Specifically:

• Account data (identity, contact, financial records): Retained for a minimum of 5 years following account closure to meet AML and fraud prevention obligations;
• Transaction records: Retained for a minimum of 5 years from the date of each transaction;
• KYC verification documents: Retained for the duration of the account plus 5 years;
• Communications data: Support chat transcripts and complaint records retained for 3 years from the date of the interaction;
• Technical and usage data: Retained in identifiable form for up to 2 years; thereafter anonymised for aggregate analytics purposes.

7.2 Where you have activated self-exclusion, 77game will retain sufficient data to enforce the exclusion for its stated duration and to prevent re-registration in circumvention of the exclusion period.

8 Security Measures

77game implements a range of technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:

• 256-bit TLS/SSL encryption for all data transmitted between your device and the 77game platform;
• Encrypted storage of sensitive data including passwords (stored as salted hashes, never in plain text);
• Role-based access controls limiting access to personal data to authorised 77game personnel on a need-to-know basis;
• Regular security audits and penetration testing of the platform infrastructure;
• Two-factor authentication options for user accounts;
• Automated fraud detection and unusual activity monitoring systems.

Notwithstanding the above, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. If you become aware of any security vulnerability or suspected breach related to your 77game account, you must notify us immediately via live chat.

9 Your Data Rights

Subject to applicable law and certain exceptions, you hold the following rights in respect of your personal data held by 77game:

• Right of access: You may request a copy of the personal data 77game holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: In certain circumstances, you may request deletion of your personal data. Note that this right may be limited where 77game is required by law to retain data (e.g. for AML compliance);
• Right to restrict processing: You may request that 77game restricts the processing of your data in specific circumstances;
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format where processing is based on consent or contract;
• Right to object: You may object to processing based on legitimate interests or direct marketing at any time;
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of the above rights, please contact 77game support via live chat or the email address provided in Section 13. We will respond to valid requests within 30 days. We may require you to verify your identity before processing a data rights request.

10 Children's Privacy

The 77game platform is strictly intended for individuals aged 18 years and over. We do not knowingly collect personal data from individuals under the age of 18. If 77game becomes aware that personal data has been collected from a person under 18, that data will be deleted promptly and the associated account will be permanently closed. Parents or guardians who believe their minor child has registered an account with 77game are urged to contact support immediately via live chat so that corrective action can be taken without delay.

11 Third-Party Links

The 77game platform may contain links to third-party websites, including game provider information pages and payment provider portals. This Privacy Policy applies only to 77game and does not cover third-party websites or services. 77game is not responsible for the privacy practices of any third-party site. We encourage you to review the privacy policies of any third-party site you visit.

12 Changes to This Privacy Policy

77game may update this Privacy Policy from time to time to reflect changes in data processing practices, applicable law, or platform operations. When material changes are made, we will notify registered users via the mobile number or email address associated with their account or through a prominent notice on the 77game website. The "Last Updated" date at the top of this policy will always reflect the date of the most recent revision. Continued use of 77game following notification of changes constitutes your acceptance of the updated policy.

13 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 77game, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the 77game website – our preferred and fastest channel
• Email: [email protected] (plain text – not a clickable link)
• Response Times: Live chat within 2 minutes; email queries within 24–48 hours

When submitting a data rights request, please include your registered mobile number and account username to allow us to verify your identity and process your request efficiently. Support is available in English and Pakistani English, 24 hours a day, 7 days a week.