Privacy Policy — 77xc
Your Data. Our Responsibility.

Introduction

This Privacy Policy (the "Policy") is issued by 77xc (hereinafter "77xc", "we", "us" or "our") and applies to all personal data collected, processed and stored in connection with your use of the 77xc online gaming and sports betting platform accessible at https://77xc.cam (the "Platform").

We are committed to protecting your privacy and handling your personal data in accordance with internationally recognised data protection principles, including principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality.

By accessing the Platform, creating an account, making a deposit or placing a wager, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which are incorporated by reference.

Definitions

Data Controller

77xc acts as the Data Controller in respect of all personal data collected through the Platform. As Data Controller, we determine the purposes for which and the means by which your personal data is processed.

Where 77xc engages third-party service providers to assist with specific data processing activities (such as identity verification or payment processing), those providers act as Data Processors under contractual obligations consistent with this Policy. 77xc remains responsible for ensuring that such processors handle your data in a manner consistent with the principles set out in this Policy.

Data We Collect

4.1 Registration Data

When you create an account, we collect: full legal name, date of birth, residential address, email address, username, and a hashed version of your password. This information is required to establish your account and verify your eligibility to use the Platform.

4.2 Identity Verification (KYC) Data

To comply with our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we may collect copies of government-issued identification documents (such as a National Identity Card (CNIC), passport or driving licence), proof of residential address, and documentation relating to the payment method you use. For Pakistani players, this typically includes a CNIC or similar nationally recognised identity document.

4.3 Financial and Payment Data

We collect records of deposit and withdrawal transactions including amounts, timestamps, payment method references, and transaction identifiers. Where payment is made through third-party payment rails (such as mobile wallet services or bank transfers — referenced here as familiar Pakistani payment options only, with no implication of endorsement), we may receive a transaction reference from the payment provider. We do not store full card numbers or mobile banking credentials.

4.4 Technical and Device Data

When you access the Platform, we automatically collect: IP address, browser type and version, operating system, device type, screen resolution, referral URL, pages visited, session duration, and error logs. This data is used for platform security, fraud detection, and performance optimisation.

4.5 Gameplay and Betting Activity

We maintain logs of your betting and gaming activity on the Platform, including wager amounts, game selections, outcomes and session durations. This data is used for account management, dispute resolution, responsible gambling monitoring, and regulatory compliance.

4.6 Communications Data

If you contact our support team via live chat or email, we retain records of those communications — including the content of messages, timestamps and resolution outcomes — for quality assurance and dispute resolution purposes.

Legal Basis for Processing

We process your personal data on the following legal bases:

• Contractual Necessity: Processing your registration data, financial transactions, and account management activity is necessary for the performance of the contract between you and 77xc.
• Legal Obligation: KYC verification, AML monitoring and record retention are required to comply with applicable regulatory and legal obligations imposed on operators in the licence jurisdiction.
• Legitimate Interests: Fraud prevention, platform security, abuse detection, and business analytics are processed on the basis of 77xc's legitimate interests, balanced against your rights and privacy interests.
• Consent: Non-essential cookies and optional marketing communications are processed on the basis of your explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

How We Use Your Data

Data Sharing & Disclosure

7.1 Service Providers

We share personal data with trusted third-party service providers who process data on our behalf under binding contractual obligations. These include identity verification and KYC providers, payment processing intermediaries, fraud prevention services, customer support platform providers, and cloud infrastructure operators. All such providers are required to process data solely in accordance with our documented instructions and this Policy.

7.2 Regulatory and Law Enforcement Disclosure

We may disclose personal data to regulatory authorities, law enforcement bodies, or courts where required to do so by applicable law, court order, or regulatory directive. Such disclosures are made only to the extent strictly required by the relevant legal obligation and, where permitted, we will notify you of any such disclosure.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of 77xc's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material change in the applicable privacy terms at the earliest practicable opportunity.

7.4 No Sale of Personal Data

77xc does not sell, rent or trade your personal data to third parties for their own independent marketing or commercial purposes. Payment provider names referenced on this Platform (such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are cited as familiar Pakistani payment references only. We do not share data with these providers beyond what is technically necessary to process a specific transaction you have initiated, and we make no claim that these providers endorse 77xc or support gambling.

International Data Transfers

As an online platform serving users across multiple jurisdictions, including Pakistan, some of the personal data we collect may be transferred to, stored in, or processed in countries outside your country of residence. Such transfers may include transfers to the operator's licence jurisdiction or to the jurisdiction in which our service providers operate.

Where personal data is transferred internationally, we ensure that appropriate safeguards are in place — such as standard contractual clauses, data processing agreements, or other recognised transfer mechanisms — to protect your data to a standard consistent with this Policy.

Data Retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention principles apply:

• Account data and KYC documents: Retained for the duration of the account and for a minimum period of five (5) years following account closure, as required by standard AML record-keeping obligations in most jurisdictions.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, or longer where required by applicable law.
• Gameplay and betting logs: Retained for the duration of the account and for a minimum of two (2) years following closure, for dispute resolution and regulatory purposes.
• Support communications: Retained for a minimum of two (2) years from the date of the interaction.
• Technical and device data: Typically retained for up to twelve (12) months on a rolling basis, depending on operational and security requirements.
• Anonymised analytics data: May be retained indefinitely, as it cannot be used to identify any individual.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction or identification.

Cookies & Tracking Technologies

10.1 What Are Cookies

Cookies are small text files stored on your device by your browser when you visit the Platform. They enable the Platform to remember your preferences, maintain your login session, and collect anonymised analytics data about usage patterns.

10.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function correctly — including session management, login authentication, and security tokens. These cannot be disabled without impairing Platform functionality.
• Performance / Analytics Cookies: Used to understand how visitors interact with the Platform — page views, session lengths, error occurrences. Data is aggregated and anonymised wherever possible.
• Functional Cookies: Remember your preferences such as language selection, notification settings, and responsible gambling limit choices.
• Marketing / Targeting Cookies: Only activated with your explicit consent. Used to serve relevant promotional content based on your browsing behaviour. You may opt out at any time.

10.3 Managing Cookies

You can review and manage cookie settings through your browser's privacy or settings menu at any time. Disabling strictly necessary cookies may impair your ability to log in or use certain features of the Platform. Disabling analytics or marketing cookies will not affect your ability to place wagers or manage your account.

Your Rights

Subject to applicable law and the legal basis on which we process your personal data, you may have the following rights in relation to your personal data:

Children's Privacy

The 77xc Platform is strictly intended for adults. We do not knowingly collect personal data from individuals under the age of 18, or the higher minimum age required by the operator's licence jurisdiction. If we become aware that personal data has been collected from a person below the required minimum age, we will take immediate steps to delete that data and close the associated account.

Parents or guardians who believe that a minor has created an account on the Platform should contact our support team immediately. Parental control software is available as a third-party resource for families seeking to restrict access to gambling websites from shared devices.

Security Measures

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

• TLS/SSL Encryption: All data transmitted between your browser and the Platform is encrypted using industry-standard Transport Layer Security (TLS) protocols.
• Access Controls: Access to personal data within 77xc is restricted on a need-to-know basis using role-based access controls. All access is logged and monitored.
• Password Storage: Passwords are stored in hashed form using established cryptographic hashing algorithms. We do not store plain-text passwords.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts to add an additional layer of security beyond the password.
• Fraud Monitoring: Automated systems monitor account activity for patterns indicative of unauthorised access, fraud, or AML risk, with alerts escalated for manual review where necessary.
• Vendor Security: Third-party service providers who process personal data on our behalf are required to maintain security standards consistent with this Policy as a condition of their engagement.

No security system is entirely infallible. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, we will notify affected individuals and relevant authorities as required by applicable law.

Third-Party Services

The Platform may reference or interact with third-party services to facilitate specific functions — including payment processing and identity verification. The Privacy Policy of 77xc applies exclusively to data processed by 77xc. Third-party services operate under their own privacy terms, which you should review independently.

In particular, when you initiate a deposit or withdrawal using any payment method, you may interact with the interface of a payment provider. Any data shared directly with that provider — such as mobile wallet PIN entry or bank login credentials — is governed by the respective provider's own privacy and security policies, not this Policy. The payment provider names referenced on this Platform (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah) are cited as familiar Pakistani payment references only and do not imply any commercial endorsement of 77xc or of gambling services by those providers.

Changes to This Policy

We reserve the right to update or revise this Privacy Policy at any time. Material changes will be communicated to registered users via email notification to the registered account address and/or by posting a prominent notice on the Platform for a reasonable period prior to the changes taking effect.

The "Document version" date at the top of this Policy indicates the most recent update. Continued use of the Platform following any revision constitutes your acceptance of the updated Policy. If you do not accept the revised Policy, you should close your account before the effective date of the changes.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy, the processing of your personal data, or the exercise of your data subject rights, please contact the 77xc support team using the following channels:

Where you are not satisfied with our handling of a privacy concern, you may have the right to lodge a complaint with a relevant supervisory or data protection authority in the operator's licence jurisdiction. Details of the applicable authority will be provided upon request.