77ef Privacy Policy —
Your Data, Your Rights, Our Obligations

77ef is committed to the responsible, lawful, and transparent processing of personal data belonging to all individuals who interact with the 77ef platform, including registered Players, prospective players who browse 77ef.bid, and former Players whose data is retained in accordance with the retention obligations set out in this policy.

This Privacy Policy has been written in plain language as far as possible, consistent with its legal purpose. It sets out in specific terms what categories of personal data 77ef collects, the purposes for which that data is processed, the legal bases upon which processing is conducted, and the rights available to individuals in respect of their personal data. This policy should be read alongside 77ef's Terms and Conditions and Responsible Gaming Policy, which together form the complete framework governing the player relationship with 77ef.

For the purposes of applicable data protection law, the data controller in respect of personal data processed in connection with the 77ef platform is the operator of 77ef.bid, acting under its international gaming license. The data controller is responsible for determining the purposes and means of processing personal data collected through the platform.

Where 77ef engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, or analytics platforms — those parties act as data processors under 77ef's instruction and are bound by contractual data processing obligations that restrict their use of player data to the specific purposes authorised by 77ef.

All data protection queries, subject access requests, and complaints should be directed to 77ef's data contact at [email protected], with the subject line "Data Privacy Request" for prioritised routing to the relevant team.

77ef collects personal data across several categories in connection with the operation of its platform. The specific data collected from any individual Player will depend on the nature of their interaction with the 77ef platform. The following table outlines the main categories of personal data 77ef processes:

77ef does not intentionally collect sensitive personal data categories beyond those required for KYC purposes and responsible gaming compliance. 77ef does not collect biometric data from Players.

77ef collects personal data through the following channels and mechanisms:

• Direct submission by you: Information you provide when registering your 77ef Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to surveys or promotions.
• Automated technical collection: Technical data — including your IP address, device identifiers, browser type, and session activity — is collected automatically when you access 77ef.bid, through standard server logging and first-party cookies.
• Payment processors: When you make a deposit or withdrawal via JazzCash, EasyPaisa, Raast, or a Pakistani bank transfer, the relevant payment provider shares transaction confirmation data with 77ef for reconciliation purposes.
• Third-party identity verification services: Where 77ef uses a third-party KYC provider to verify your identity documents, that provider may transmit verification outcome data back to 77ef in addition to the documents you supplied directly.
• Anti-fraud and AML screening tools: 77ef uses automated screening tools that cross-reference player data against sanctions lists, politically exposed persons (PEP) databases, and fraud risk indicators.
• Analytics platforms: Aggregated, anonymised usage data is collected through first-party analytics tools to help 77ef understand platform usage patterns and improve the user experience. 77ef does not use third-party behavioural advertising platforms.

77ef processes personal data for the following specific purposes. Each purpose is paired with the legal basis on which processing is conducted (detailed further in Section 6):

77ef uses your identity and contact data to create and maintain your Player Account, authenticate your identity during login, process deposits and withdrawals to and from your Wallet, and communicate account-critical information such as password reset confirmations, withdrawal approvals, and security alerts. This processing is essential to the performance of your contract with 77ef and cannot be opted out of while you hold an active Account.

77ef is required by the terms of its international gaming license to conduct KYC verification, maintain records of all betting and financial transactions, screen players against sanctions databases, file suspicious transaction reports where mandated, and retain certain categories of player data for defined regulatory retention periods. This processing is non-optional and does not require your separate consent.

77ef processes gaming activity data — including session frequency, loss patterns, deposit frequency, and time-of-day usage — for the purpose of identifying players who may be showing early indicators of problem gambling. Where such indicators are detected, 77ef may proactively contact the affected player, apply responsible gaming interventions, or flag the account for review by the responsible gaming team. This processing is conducted in the legitimate interests of player welfare and in fulfilment of 77ef's licensing obligations.

77ef processes technical data, financial data, and gaming activity data to detect and prevent fraudulent activity, money laundering, bonus abuse, collusion, and unauthorised account access. Automated fraud detection systems may flag account activity for manual review based on predefined risk criteria.

Where you have provided explicit consent at the time of registration or subsequently through your Account Settings, 77ef may use your contact data to send promotional offers, bonus notifications, PSL betting alerts, and other marketing communications relevant to your gaming preferences. You may withdraw marketing consent at any time through your Account Settings or by emailing [email protected].

Anonymised and aggregated data derived from player activity — with all identifying information removed — is used by 77ef to improve platform performance, optimise the user interface, identify in-demand game types, and prioritise feature development. This data cannot be used to identify individual players.

77ef processes personal data under the following legal bases in accordance with applicable data protection law:

• Contractual necessity: Processing required to deliver the services described in the 77ef Terms and Conditions — including Account management, payment processing, and bet settlement — is conducted on the basis that it is necessary for the performance of your contract with 77ef.
• Legal obligation: KYC verification, AML transaction monitoring, sanctions screening, regulatory record-keeping, and responsible gaming interventions are conducted on the basis that 77ef is legally or regulatorily obligated to perform them under the terms of its gaming license.
• Legitimate interests: Fraud prevention, platform security monitoring, responsible gaming pattern analysis, customer support quality management, and anonymised platform analytics are processed on the basis of 77ef's legitimate interests, balanced against the interests and rights of Players.
• Consent: Marketing communications — including promotional SMS messages, bonus notifications, and betting alerts via your registered mobile number — are sent only where you have given explicit, informed consent. Consent can be withdrawn at any time without affecting your Account status.

77ef does not sell your personal data to any third party. 77ef shares personal data with third parties only in the following limited and defined circumstances:

• Payment service providers: JazzCash, EasyPaisa, Raast, and partner banks (HBL, UBL, Meezan, 1LINK) receive the minimum personal data necessary to process your deposit or withdrawal transaction — typically your mobile number or account number and the transaction amount.
• KYC and identity verification providers: Third-party identity verification services receive copies of your KYC documents for the purpose of verifying their authenticity. These providers are contractually restricted from using your data for any purpose beyond the specific verification service they provide to 77ef.
• Regulatory and law enforcement authorities: 77ef is required to disclose player data to competent regulatory authorities, gaming license supervisory bodies, and law enforcement agencies where required by law or by the terms of 77ef's gaming license. 77ef will not disclose your data to any such authority except where legally compelled to do so.
• Anti-fraud and AML screening services: Automated screening tools may transmit limited data points — such as name, date of birth, and transaction amounts — to sanctions list and PEP database providers for compliance screening purposes.
• Game content providers: Where live dealer games are provided by third-party studio operators, your gaming session data (stakes, outcomes, game type) may be processed by the studio operator's systems as a technical necessity of delivering the game service. Game providers do not receive your identity or payment data.
• Professional advisers: 77ef's legal counsel, auditors, and compliance consultants may access personal data on a need-to-know basis, subject to professional confidentiality obligations.

77ef.bid uses cookies and similar first-party tracking technologies to operate the platform effectively and improve your experience. 77ef does not use third-party advertising cookies or cross-site tracking technologies.

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies that keep you logged in to your 77ef Account during a browsing session, and security cookies that protect against cross-site request forgery. These cookies cannot be disabled without preventing the platform from working correctly.
• Functional cookies: Store your preferences — such as language settings, preferred device, and responsible gaming limits you have set — so you do not need to re-enter them on each visit.
• Analytics cookies: First-party analytics cookies collect anonymised data about how players navigate 77ef.bid — which pages are visited most frequently, how long sessions last, and where players encounter difficulties. This data helps 77ef improve the platform. No personally identifiable information is included in analytics data.
• Responsible gaming cookies: Track session duration and display frequency of responsible gaming prompts in accordance with 77ef's player protection obligations under its gaming license.

You may manage cookie preferences through your browser settings. Blocking strictly necessary cookies will impair the functionality of the 77ef platform. You can clear existing cookies at any time through your browser's privacy settings.

77ef retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any longer retention period required by regulatory obligation or legal proceedings. The following retention periods apply as standard:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with 77ef's data disposal procedures.

77ef implements a multi-layered data security programme designed to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. The following technical and organisational security measures are in place:

• 256-bit SSL/TLS encryption: All data transmitted between your device and 77ef's servers — including login credentials, payment information, and personal data entered into forms — is encrypted in transit using industry-standard 256-bit SSL/TLS protocols.
• Encryption at rest: Sensitive personal data stored in 77ef's databases — including KYC documents, financial transaction records, and identity data — is encrypted at rest using AES-256 encryption.
• Access control: Access to personal data is restricted on a strict need-to-know basis. 77ef staff access to player data is role-based, logged, and subject to regular access review. No single team member has unrestricted access to all categories of player data.
• Multi-factor authentication: Administrative access to 77ef's data systems requires multi-factor authentication. Player accounts are protected by password-based authentication with optional SMS verification for new device logins.
• Penetration testing: 77ef's platform undergoes regular independent security penetration testing. Identified vulnerabilities are remediated according to a prioritised schedule based on severity.
• Data breach response: 77ef maintains an incident response plan for data security breaches. In the event of a breach that is likely to result in a risk to Players' rights and freedoms, affected Players and the relevant regulatory authority will be notified in accordance with applicable legal requirements.
• Third-party security assessments: All third-party data processors engaged by 77ef are assessed for their own data security practices before engagement and are required to maintain appropriate security standards as a contractual condition.

As an individual whose personal data is processed by 77ef, you hold the following rights in respect of your personal data. The exercise of these rights is subject to applicable legal limitations and regulatory obligations that may restrict 77ef's ability to comply with certain requests — for example, 77ef cannot delete financial transaction records that it is legally required to retain for AML purposes.

• Right of access: You may request a copy of all personal data that 77ef holds about you. 77ef will respond to verified subject access requests within 30 days of receipt.
• Right to rectification: If any personal data 77ef holds about you is inaccurate or incomplete, you may request that it be corrected. Basic account details such as your address can be updated directly through your Account Settings without needing to submit a formal request.
• Right to erasure ("right to be forgotten"): You may request that 77ef delete your personal data. This right is subject to overriding retention obligations — for example, 77ef cannot delete AML transaction records or regulatory KYC files during the mandatory retention period even if you close your Account.
• Right to restriction of processing: In certain circumstances — for example, where you contest the accuracy of your data, or where you object to processing on legitimate interests grounds — you may request that 77ef restrict the processing of your data while the matter is being resolved.
• Right to data portability: You may request a machine-readable copy of personal data you have directly provided to 77ef (such as account registration data and gaming preference settings) for the purpose of transferring it to another service provider.
• Right to object: You may object to the processing of your personal data where 77ef relies on legitimate interests as its legal basis. 77ef will cease that processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent — including marketing communications — you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

To exercise any of the above rights, please submit your request in writing to [email protected] with the subject line "Data Rights Request". 77ef will verify your identity before processing any request. Responses will be provided within 30 calendar days. Where a request cannot be fulfilled in full due to a legal limitation, 77ef will explain the specific restriction that applies.

77ef sends marketing communications — including bonus offers, PSL betting alerts, free spin promotions, and new game announcements — only to Players who have provided explicit, informed consent to receive such communications at the time of Account registration or subsequently through their Account Settings.

Marketing communications from 77ef may be sent via SMS to your registered Pakistani mobile number, and via email to your registered address. 77ef does not send promotional communications via third-party messaging applications or social media platforms.

You may opt out of marketing communications at any time by:

• Updating your communication preferences in your 77ef Account Settings.
• Sending a written opt-out request to [email protected] from your registered email address.
• Replying STOP to any promotional SMS received from 77ef's registered sending number.

Opt-out requests are processed within 3 business days. Account-essential communications — such as withdrawal confirmations, security alerts, and KYC request notifications — are not subject to marketing opt-out and will continue to be sent regardless of your marketing preference settings.

If you are a parent or guardian and believe that a person under 21 in your care has registered with or accessed the 77ef platform, please contact 77ef immediately at [email protected]. 77ef will investigate the matter and take appropriate action, including permanent Account closure and notification to relevant authorities if required.

77ef reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform features, or data processing practices. The effective date displayed at the head of this document will be updated when a new version takes effect.

Where changes to this Privacy Policy are material — meaning they significantly affect how your data is used or the rights available to you — 77ef will notify registered Players via their registered mobile number or email address with reasonable notice before the changes take effect. Minor clarifications or non-substantive updates may take effect without individual notification, provided the updated policy is published on 77ef.bid.

Your continued use of the 77ef platform following the effective date of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated policy, you should discontinue using the platform and request Account closure.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a complaint about how 77ef has handled your personal data, please contact 77ef using the details below. All privacy correspondence is handled by 77ef's data protection function and responses are provided within 30 calendar days.

If you are not satisfied with 77ef's response to a privacy complaint, you may escalate the matter to the supervisory authority under the jurisdiction of 77ef's international gaming license or seek independent legal advice regarding your data protection rights.