77td Privacy Policy

This Privacy Policy ("Policy") describes how 77td ("77td", "we", "us" or "our"), the operator of the online betting platform accessible at https://77td.cam, collects, processes, stores and discloses personal data relating to users ("you", "your") of the Platform.

This Policy applies to all personal data we collect through the Platform, whether provided directly by you during registration, deposited through your use of the Platform's services, or collected automatically through your interaction with the website. It applies to all users of the Platform, including registered account holders and unregistered visitors.

We are committed to handling your personal data responsibly, transparently and in compliance with applicable data protection law. We encourage you to read this Policy carefully before using the Platform. By using the Platform or registering an account, you confirm that you have read and understood this Policy.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy.

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

77td, the operator of the Platform at https://77td.cam, acts as the Data Controller in respect of personal data collected through the Platform. As Data Controller, we are responsible for ensuring that your personal data is processed lawfully, fairly and transparently, and only for the purposes described in this Policy.

Where we engage third-party service providers to process personal data on our behalf — for example, payment processors, KYC verification services, or analytics providers — those parties act as Data Processors under contractual agreements that require them to handle your data securely, confidentially and only in accordance with our instructions.

We collect personal data across several categories, depending on how you interact with the Platform. The table below summarises the main categories of personal data we collect and their purpose:

We do not collect sensitive categories of personal data — such as racial or ethnic origin, political opinions, religious beliefs, health data or biometric data — except where such data is incidentally present in KYC documents (e.g., a photograph on a CNIC or passport). Such incidental sensitive data is used solely for identity verification purposes and is not processed for any other purpose.

We collect personal data through the following channels:

• Direct Provision: Data you provide when completing the account registration form, submitting KYC documents, contacting our support team or responding to promotions.
• Automated Collection: Data collected automatically as you use the Platform, including via cookies, log files, and similar tracking technologies embedded in the Platform's code.
• Transaction Records: Data generated when you make deposits, place bets, request withdrawals or interact with the Platform's financial features.
• Third-Party Sources: In limited circumstances, we may receive data from third-party KYC verification partners, fraud-prevention services or identity databases for the purpose of verifying your identity or detecting fraudulent activity. Such third-party data sources will be identified to you where required by applicable law.

We process your personal data on the following legal bases, depending on the nature of the processing activity:

• Contractual Necessity: Processing required to perform the contract between you and 77td — including account management, transaction processing, bet settlement and customer support delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations, including KYC/AML requirements, age verification, record-keeping obligations and cooperation with lawful authority requests.
• Legitimate Interests: Processing carried out for 77td's legitimate business interests, provided those interests are not overridden by your privacy rights — including fraud prevention, platform security, responsible gambling monitoring and general analytics. We apply a balancing test before relying on this basis.
• Consent: Where we send direct marketing communications or use non-essential cookies, we will seek your explicit consent first. You may withdraw consent at any time by contacting support or managing your account preferences.

We use the personal data we collect for the following purposes:

• Account Operation: Creating, maintaining and managing your 77td account, including processing your deposits, bets, bonuses and withdrawal requests.
• Identity & Age Verification: Confirming that you meet the minimum age requirement (18+ or higher) and verifying your identity as required for KYC and AML compliance.
• Transaction Processing: Processing PKR-denominated deposits and withdrawals, recording transaction history and managing payment-method references such as those associated with Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah. These payment-provider names are contextual references only and do not imply any data-sharing arrangement with those providers.
• Customer Support: Responding to queries, resolving disputes, processing complaints and maintaining support records for quality assurance.
• Responsible Gambling Monitoring: Monitoring account activity for signs of problem gambling behaviour, applying deposit or loss limits at your request, and administering self-exclusion requests.
• Fraud & Security: Detecting, investigating and preventing fraudulent transactions, unauthorized account access, money laundering and other prohibited conduct.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the Platform's performance, content and user experience.
• Legal Compliance: Meeting our obligations under applicable law, including responding to lawful requests from governmental or regulatory authorities.
• Marketing (with consent only): Sending promotional communications about 77td offers, bonuses and platform updates, where you have given explicit consent to receive such communications. You can withdraw marketing consent at any time.

77td does not sell, rent or trade your personal data to third parties for their own marketing purposes. We disclose personal data only in the following limited circumstances:

• Service Providers (Data Processors): We share data with third-party service providers who process data on our behalf under contractual data-processing agreements. These may include payment processors, KYC verification platforms, cloud infrastructure providers, fraud-detection services and customer support platform providers. These parties are permitted to use your data only as instructed by 77td and for the specific purposes of their service.
• Legal & Regulatory Authorities: We may disclose personal data to law enforcement agencies, regulatory bodies, courts or other governmental authorities where required by law, regulation, court order or as otherwise legally required.
• AML & Fraud Prevention: We may share data with fraud-prevention and AML compliance databases where required for the detection and prevention of money laundering, fraud or other financial crime.
• Business Transfers: In the event of a merger, acquisition, restructuring or sale of assets affecting 77td, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

The Platform uses cookies and similar tracking technologies to ensure core functionality, manage user sessions and collect analytics data. The main categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function — including session management, login authentication and security tokens. These cannot be disabled without disrupting core Platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised data about how users navigate and interact with the Platform. This helps us identify errors, improve page performance and understand usage patterns. These are activated only with your consent.
• Functional Cookies: Store your preferences such as language settings, odds format and session preferences so you do not need to re-enter them on each visit.
• Marketing Cookies: Used to track interactions with promotional content and to manage marketing consent records. These are activated only where you have provided explicit consent.

You can manage your cookie preferences through your browser's settings. Disabling non-essential cookies will not prevent you from using the core Platform features, though some preference-based functionality may be reduced. For strictly necessary cookies, no opt-out is available as they are required for the Platform to operate.

We retain personal data for as long as is necessary for the purposes described in this Policy and to comply with applicable legal obligations. The general retention principles we follow are:

• Active Accounts: Account data is retained for the full duration of your account's active status on the Platform.
• Closed Accounts: Following account closure, we retain identity data, KYC documents and transaction records for a minimum period of five (5) years to satisfy AML regulatory obligations. The precise retention period may be longer depending on the legal requirements of the jurisdiction in which 77td is licensed.
• Support Records: Customer support communications are retained for a minimum of three (3) years from the date of the interaction, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of your marketing consent (or withdrawal of consent) are retained for as long as they are operationally relevant to managing your communication preferences.
• Technical & Log Data: Server logs and technical access records are retained for up to twelve (12) months unless required for longer by a specific fraud investigation or legal obligation.

When personal data is no longer required and no legal retention obligation applies, it is securely deleted or anonymised so that it can no longer be linked to you as an individual.

77td applies industry-standard technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss or destruction. These measures include:

• Encryption of personal data in transit using TLS (Transport Layer Security) protocols.
• Encryption of sensitive data at rest within our storage systems.
• Access controls restricting personal data access to authorised personnel only, on a need-to-know basis.
• Regular internal security assessments and vulnerability monitoring.
• Staff training on data protection obligations and handling procedures.
• Incident response procedures for detecting, reporting and managing data security incidents.

Whilst we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we commit to notifying affected users and relevant authorities of any data breach in accordance with applicable legal requirements and within the timeframes prescribed by law.

As a platform operating internationally, it is possible that personal data collected from users in Pakistan may be transferred to, stored in or processed in countries outside Pakistan, including countries where 77td's cloud infrastructure, KYC providers or payment processors are based.

Where such transfers occur, we take steps to ensure that your personal data receives an adequate level of protection, including through the use of contractual safeguards with our data processors (such as data processing agreements incorporating appropriate data-transfer mechanisms).

By using the Platform, you acknowledge that your personal data may be transferred internationally in the manner described above.

Subject to applicable law and certain statutory exceptions (for example, where data retention is required by AML regulations), you have the following rights in relation to your personal data:

To exercise any of the above rights, please contact our support team via the 24/7 live chat on the Platform or by email at [email protected] (plain text — not a clickable link). We aim to acknowledge all rights requests within a reasonable timeframe and to respond substantively as required by applicable law.

The Platform may reference third-party services in the context of payment methods or technology partners. Any reference to services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah is for illustrative and user-guidance purposes only. 77td does not share personal data with these payment providers unless required to complete a specific user-requested transaction through their infrastructure. These references do not imply endorsement, data-sharing partnerships or affiliation.

Where you interact with any third-party service linked to or referenced by the Platform, that third party's own privacy policy governs the collection and use of data in that interaction. 77td is not responsible for the privacy practices of third-party services.

The Platform is strictly for adults aged 18 years or older — or the higher minimum age required by the applicable operator or license jurisdiction. 77td does not knowingly collect personal data from individuals under the age of 18.

If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data and close the associated account. If you have reason to believe that a minor has registered on the Platform, please contact us immediately via the support channel.

77td is an English-language platform built for Pakistani users across cities including Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. While we serve Pakistani users, 77td is not registered in Pakistan and does not operate under the jurisdiction of the Pakistan Telecommunication Authority, the State Bank of Pakistan, or any other Pakistani regulatory authority.

Pakistan's Personal Data Protection Bill (and any enacted legislation that follows from it) may be relevant to your rights as a Pakistani user. We encourage Pakistani users who have concerns about their data rights to seek independent legal advice regarding the application of Pakistani data protection law to their specific situation.

This Policy is provided in English in accordance with 77td's platform language. If you have questions about this Policy that you would prefer to discuss in Urdu, please contact our support team and request Urdu-language assistance through the live chat channel.

77td reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or operational requirements. When we make material changes to this Policy, we will update the "Last Updated" date at the top of the page and, where appropriate, notify registered users via email or a prominent notice on the Platform.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree to the updated Policy, you should stop using the Platform and may request account closure through the support channel.

If you have any questions, concerns or requests relating to this Privacy Policy or the way your personal data is handled, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the Platform. This is the fastest way to raise a privacy concern or submit a data rights request. Ask for the Privacy or Data Protection team when connecting.
• Email: [email protected] — please include "Privacy Request" in the subject line and write from your registered email address to allow account verification.

We take all privacy-related queries seriously and aim to acknowledge requests promptly. Formal data rights requests will be handled in accordance with applicable legal timeframes. Support is available in English, with Urdu assistance also available on request through the live chat queue.