Privacy Policy — 77pak Online Casino

1.1 This Privacy Policy ("Policy") is issued by 77pak ("we", "us", "our") and applies to all personal data collected from individuals ("you", "User", "Player") who access or use the 77pak platform at 77pak.biz, including all associated game lobbies, the sportsbook, the payment portal, the customer support interface, and any related digital service provided under the 77pak brand (collectively, the "Platform").

1.2 77pak is committed to protecting the privacy and personal data of all Users — in particular the Pakistani players who form our primary audience across Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and beyond. This Policy explains our data practices in plain, accurate terms so that you can make informed decisions about your use of the Platform.

1.3 This Policy should be read in conjunction with the 77pak Terms & Conditions, which govern the overall relationship between 77pak and its Users. In particular, the obligations regarding identity verification (KYC) and age confirmation described in the Terms & Conditions require the collection and processing of personal data as described in this Policy.

1.4 By creating a 77pak Account or by continuing to use the Platform following publication of this Policy or any subsequent amendment, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2.1 For the purposes of this Policy, the data controller responsible for your personal data is the 77pak platform operator — an internationally licensed online gaming entity that operates 77pak.biz and all associated Platform services.

2.2 77pak's data processing activities are conducted in compliance with the obligations imposed by its international gaming license, which includes data protection standards applicable to licensed gaming operators. Details of the licensing authority are available to Users upon request through the 77pak support team.

2.3 All formal data protection enquiries, requests to exercise data rights, and privacy complaints should be directed to 77pak through the contact details set out in Section 15 of this Policy.

3.1 77pak collects only the personal data that is necessary for one or more of the specific purposes described in Section 5. The categories of personal data we collect are as follows:

3.2 77pak does not collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health data) except where strictly required by regulatory obligation — for example, where a responsible gaming assessment necessitates collection of information relevant to gambling-related harm.

4.1 77pak collects personal data through the following mechanisms:

• Direct provision by the User: During Account registration, identity verification (KYC), payment transactions, customer support interactions, and form submissions on the Platform;
• Automated collection during Platform use: Technical data including IP address, device identifiers, and session data is collected automatically when you access the 77pak Platform, regardless of whether you are logged into an Account;
• Payment service providers: When processing deposits or withdrawals through JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, Raast, 1LINK, or other accepted payment channels, transactional confirmation data is shared with 77pak by the relevant payment service provider;
• Identity verification services: 77pak may engage third-party identity verification providers to assist with the authentication of identity documents submitted during KYC. Data shared with such providers is limited to what is strictly necessary for verification purposes;
• Cookies and tracking technologies: 77pak uses cookies and similar technologies as described in Section 10 of this Policy.

5.1 77pak uses personal data collected from Users for the following specific purposes, each of which corresponds to a legal basis described in Section 6:

1. Account Creation and Management: To register your Account, maintain your profile, verify your identity and age (21+ requirement), and manage your ongoing relationship with the Platform;
2. Payment Processing: To process deposits and withdrawals through your chosen payment method, maintain transaction records, and facilitate reconciliation of payment disputes;
3. Regulatory Compliance and AML: To fulfil 77pak's obligations under its international gaming license, including Know Your Customer (KYC) verification, Anti-Money Laundering (AML) monitoring and reporting, and compliance with any regulatory directive or law enforcement request;
4. Platform Security and Fraud Prevention: To detect and prevent unauthorised Account access, fraudulent transactions, bonus abuse, multiple-Account creation, and other integrity violations;
5. Gameplay Administration: To maintain accurate records of wagering activity, calculate and credit winnings and bonus outcomes, manage responsible gaming tool settings, and resolve any gameplay disputes;
6. Responsible Gaming: To monitor gameplay patterns for indicators of at-risk or problem gambling behaviour, to apply responsible gaming tools (deposit limits, self-exclusion) as configured by the User, and to fulfil 77pak's duty of care obligations under its licensing terms;
7. Customer Support: To respond to support enquiries, resolve complaints, and maintain records of User communications for training and quality assurance purposes;
8. Service Improvement: To analyse aggregated and anonymised Platform usage data to improve game offerings, payment processes, and overall user experience — this analysis is conducted on data that cannot be used to identify individual Users;
9. Marketing Communications: To send promotional offers, bonus notifications, and Platform updates to Users who have actively opted in to receive marketing communications. Users may withdraw marketing consent at any time through their Account settings.

6.1 77pak processes personal data on the following legal bases, consistent with the data protection framework applicable under its licensing jurisdiction:

• Contractual Necessity: Processing required to perform the contract between 77pak and the User — including Account management, payment processing, and gameplay administration — is conducted on the basis that such processing is necessary to deliver the services the User has requested;
• Legal Obligation: Processing required to comply with 77pak's regulatory obligations under its gaming license — including KYC identity verification, AML monitoring, age verification, and regulatory reporting — is conducted on the basis of legal obligation;
• Legitimate Interests: Processing for Platform security, fraud prevention, and service improvement is conducted on the basis of 77pak's legitimate interests in maintaining a secure, fair, and operationally sound gaming environment — provided these interests are not overridden by the rights and interests of individual Users;
• Consent: Processing for marketing communications and optional personalisation features is conducted on the basis of explicit, freely given consent, which may be withdrawn at any time without affecting the User's ability to access the core Platform services.

7.1 77pak does not sell, rent, or trade personal data to any third party for that party's own commercial purposes. Personal data is shared with third parties only in the following limited and controlled circumstances:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, Raast, 1LINK, and cryptocurrency processing partners receive transaction-specific data necessary to process payments. These providers operate under their own privacy policies and data protection obligations;
• Identity Verification Providers: Third-party KYC service providers engaged to assist with CNIC and identity document verification receive only the data strictly necessary for verification completion;
• Game Technology Providers: Licensed game providers whose titles appear in the 77pak lobby may receive technical session data necessary for game operation and RNG auditing purposes, on terms that prohibit the use of such data for any purpose other than the specific technical function;
• Regulatory Authorities and Law Enforcement: 77pak will disclose personal data to its licensing regulatory authority, financial intelligence units, or law enforcement agencies where required by law, regulatory directive, or court order — without prior User notice where the law prohibits such notification;
• Professional Advisors: Lawyers, auditors, and compliance consultants engaged by 77pak may access personal data to the extent strictly necessary for the specific professional service being provided, subject to confidentiality obligations.

8.1 77pak retains personal data for no longer than is necessary for the purposes for which it was collected, subject to overriding legal and regulatory retention requirements. The following retention framework applies:

• Account Data and Identity Documents: Retained for the duration of the active Account relationship plus a minimum of five (5) years following Account closure, in compliance with AML record-keeping obligations under 77pak's gaming license;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with financial record-keeping requirements applicable to licensed gaming operators;
• Gameplay Records: Retained for the duration of the active Account relationship plus three (3) years following Account closure, for dispute resolution and responsible gaming monitoring purposes;
• Customer Support Records: Retained for three (3) years from the date of the most recent interaction within a support thread;
• Technical and Security Logs: Retained for twelve (12) months from the date of generation, except where a security incident requires extended preservation for investigation purposes;
• Marketing Preferences: Retained for the duration of the Account relationship. If a User withdraws marketing consent, the withdrawal record itself is retained to document the opt-out.

8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to any identifiable individual.

9.1 77pak implements a layered technical and organisational security framework to protect personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between User devices and the 77pak Platform is encrypted using industry-standard SSL/TLS protocols — the same encryption standard used by Pakistani commercial banks for online transactions;
• Encrypted Data Storage: Sensitive personal data — including identity document images, financial account details, and authentication credentials — is stored in encrypted form in access-controlled environments;
• Access Controls: Access to User personal data within 77pak's operational infrastructure is restricted to personnel with a documented, legitimate need for that access. All internal data access is logged and auditable;
• Intrusion Detection: 77pak employs automated systems to detect and respond to suspicious network activity, unusual login patterns, and potential data access anomalies;
• Vendor Security Standards: All third-party service providers with access to User data are contractually required to maintain security standards consistent with 77pak's own obligations.

9.2 Notwithstanding the above, no digital security system is completely infallible. In the event of a data security incident affecting User personal data, 77pak will notify affected Users and the applicable regulatory authority in accordance with the breach notification obligations applicable under its licensing framework, without undue delay.

9.3 Users are responsible for maintaining the security of their own Account credentials. 77pak recommends enabling two-factor authentication, using a strong unique password, and avoiding Account access from shared or public devices.

10.1 77pak uses cookies and similar technologies on the Platform for the following specific purposes:

• Strictly Necessary Cookies: These cookies are essential for the basic functionality of the Platform — including maintaining your logged-in session, remembering your language preference, and enabling the payment processing interface. These cookies cannot be disabled without affecting Platform functionality;
• Security Cookies: Used to detect and prevent fraudulent activity, manage session timeouts, and identify multiple Account creation attempts across devices;
• Performance and Analytics Cookies: 77pak uses first-party analytics cookies to understand aggregate Platform usage patterns — such as which game categories are most visited and at what times. This data is used in anonymised, aggregated form only and is not linked to individual User profiles for external advertising purposes;
• Preference Cookies: Store your Platform preferences — such as display settings and notification choices — so that these are maintained across sessions.

10.2 77pak does not use third-party advertising or retargeting cookies that would enable external platforms (such as social media networks or advertising exchanges) to track your activity on the 77pak Platform for advertising purposes directed at you on other websites.

10.3 Users may manage cookie preferences through their browser settings. Disabling strictly necessary cookies will impair Platform functionality, including the ability to maintain an authenticated session.

11.1 Subject to the applicable data protection framework and the limitations imposed by 77pak's regulatory and legal obligations, Users hold the following rights in relation to their personal data:

11.2 To exercise any of the above rights, Users should submit a written request to 77pak through the contact details in Section 15. Requests will be acknowledged within 5 business days. 77pak may require identity verification before processing any data rights request to ensure that personal data is not disclosed to or acted upon by unauthorised parties.

12.1 The 77pak Platform is strictly for individuals aged 21 years and older. 77pak does not knowingly collect personal data from any person under the age of 21, and the collection of such data is not permitted under the terms of 77pak's international gaming license.

12.2 Where 77pak has reason to believe that personal data has been collected from an individual under the age of 21 — whether through attempted Account registration, attempted deposit, or any other Platform interaction — all data collected in connection with that individual will be permanently deleted without retention, and any associated Account will be permanently closed.

12.3 Parents and guardians who believe that a person under 21 may have registered or attempted to register an Account on 77pak should contact support at [email protected] immediately. 77pak treats all such reports as a matter of highest priority and will investigate and act without delay.

13.1 As an internationally licensed gaming operator serving Pakistani players, 77pak's data processing infrastructure — including certain third-party service providers engaged for payment processing, identity verification, and game technology delivery — may involve the transfer of personal data across international borders.

13.2 Where personal data is transferred to a jurisdiction outside Pakistan, 77pak ensures that appropriate safeguards are in place to protect the data. These safeguards include contractual data protection clauses in all agreements with international service providers, and vendor security assessments confirming that receiving parties maintain standards equivalent to those described in this Policy.

13.3 Users who wish to obtain more information about the specific international transfers applicable to their personal data may contact 77pak through the channels in Section 15.

14.1 77pak reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, updates to our Platform features, amendments to regulatory requirements under our gaming license, or developments in applicable data protection law.

14.2 When material changes are made to this Policy — meaning changes that affect how we collect, use, or share personal data in ways that are meaningfully different from the current Policy — 77pak will notify registered Users through the contact information held on their Account profile with a minimum of 14 days' advance notice before the changes take effect.

14.3 Non-material amendments — such as formatting corrections, clarifications that do not alter the substance of data practices, or updates to contact information — may be implemented without advance notice. The "Effective Date" published at the top of this Policy and in the Table of Contents will always reflect the date of the most recent version.

14.4 Continued use of the 77pak Platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy. Users who do not accept a material amendment to this Policy should exercise their Account closure right before the amendment takes effect.

15.1 All privacy-related enquiries, data rights requests, and complaints should be directed to 77pak through the following channel:

15.2 To assist 77pak in responding to your enquiry efficiently, please include:

• Your registered mobile number (for Account identification and verification purposes);
• A clear description of the nature of your enquiry or the specific data right you wish to exercise;
• Any relevant documentation supporting your request.

15.3 77pak will acknowledge all formal privacy enquiries within 5 business days and aims to provide substantive responses within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, the response period may be extended by a further 30 days, in which case 77pak will notify you of the extension and the reasons for it before the original deadline expires.

15.4 If you are dissatisfied with 77pak's response to a privacy complaint, you have the right to escalate the matter to the supervisory authority applicable under 77pak's licensing jurisdiction. Details of the applicable supervisory authority are available from the 77pak support team upon request.