Privacy Policy — 77ad

1. Introduction

This Privacy Policy ("Policy") describes how 77ad ("the Platform", "we", "us", "our"), accessible at https://77ad.cam, collects, uses, stores, shares and protects personal data relating to users ("you", "User") of the Platform, including visitors who browse without registering.

This Policy applies to all personal data processed in connection with the 77ad Platform, including data collected through the website, mobile interfaces, customer support channels and third-party integrations used to deliver the Platform's services. It should be read alongside our Terms & Conditions and our Responsible Gambling Policy.

By registering an account or continuing to use the Platform after being presented with this Policy, you acknowledge that you have read and understood its contents. If you do not agree with this Policy, you should cease using the Platform and may request account closure by contacting support.

2. Definitions

• Personal Data: Any information that identifies or can reasonably be used to identify a natural person, directly or in combination with other data.
• Processing: Any operation performed on personal data, including collection, storage, use, disclosure, alteration or deletion.
• Data Controller: The entity that determines the purposes and means of processing personal data — in this context, the operator of the 77ad Platform.
• Data Processor: A third party that processes personal data on behalf of the Data Controller, subject to a data processing agreement.
• KYC Data: Identity and address documents submitted by Users for account verification, including CNIC, passport copies, proof-of-address documents and payment method verification.
• Cookies: Small data files placed on a User's device by the Platform to enable functionality, session management and analytics.
• Sensitive Data: A subset of personal data warranting heightened protection, including financial information, identity documents and data revealing health status.

3. Data We Collect

77ad collects personal data through three primary channels: information you provide directly, data generated automatically by your use of the Platform, and data received from third-party service providers. The following table summarises the categories:

77ad does not intentionally collect special-category sensitive data beyond what is strictly necessary for compliance or responsible gambling purposes. We do not request religious affiliation, political opinions or biometric data beyond document photographs submitted for KYC.

4. Legal Basis for Processing

77ad processes personal data on the following legal grounds, depending on the purpose:

• Contractual Necessity: Processing required to perform our obligations under the account agreement, including account management, payment processing and customer support.
• Legal Obligation: Processing necessary to comply with KYC, anti-money laundering (AML), responsible gambling and other applicable regulatory requirements.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection and improvement of Platform features, where these interests are not overridden by your rights.
• Consent: Processing for non-essential communications or analytics where we have obtained your explicit consent. You may withdraw consent at any time without affecting processing already carried out.

5. How We Use Your Data

Personal data collected by 77ad is used for the following purposes:

• Account Creation & Management: Registering your account, maintaining account records and verifying your identity and age eligibility.
• KYC & Compliance: Verifying identity documents, processing withdrawal requests and meeting anti-money laundering and responsible gambling obligations.
• Transaction Processing: Facilitating deposits and withdrawals in PKR, coordinating with payment service providers (such as those offering Easypaisa, JazzCash, Raast and bank transfer rails), and maintaining financial records. Payment-provider names are cited as familiar Pakistani references; we do not assert that any provider endorses gambling.
• Gameplay & Platform Operation: Delivering sports betting markets, casino games, live dealer tables and instant games; personalising the lobby; and ensuring fair play.
• Fraud Prevention & Security: Detecting and preventing unauthorised access, multi-accounting, bonus abuse and other prohibited conduct.
• Customer Support: Responding to queries, resolving disputes and maintaining support records.
• Responsible Gambling: Monitoring betting patterns for indicators of problem gambling, enforcing self-exclusion decisions and responding to limit-setting requests.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve product performance, navigation and content.
• Communications: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) and — where you have consented — promotional communications.

6. Data Sharing & Disclosure

77ad does not sell, rent or trade your personal data to third parties. Data may be shared only in the following circumstances:

• Service Providers: Third-party vendors who process data on our behalf under binding data processing agreements — including KYC verification providers, payment processors, fraud detection services, cloud hosting providers and customer support platforms.
• Regulatory & Law Enforcement: Where required by applicable law, court order or regulatory directive, 77ad may disclose data to competent authorities. We will notify you of such disclosure where legally permitted to do so.
• AML & Fraud Consortia: Where permitted by law, account data and transaction patterns may be shared with industry anti-fraud networks to prevent financial crime.
• Business Transfers: In the event of a merger, acquisition or asset sale, User data may be transferred as part of the transaction, subject to equivalent privacy protections.

7. International Data Transfers

77ad and some of its service providers operate in jurisdictions outside Pakistan. Where personal data is transferred internationally, 77ad ensures that appropriate safeguards are in place, including:

• Standard contractual clauses recognised by the data protection authority of the operator's licensing jurisdiction.
• Transfer to jurisdictions that maintain an adequate level of data protection as recognised by applicable frameworks.
• Service provider agreements that contractually obligate recipients to protect data to an equivalent standard.

By using the Platform, you acknowledge that your data may be transferred to and processed in jurisdictions outside your country of residence. If you have concerns about a specific transfer, contact us at [email protected].

8. Data Retention

77ad retains personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable legal and regulatory obligations. General retention guidelines:

• Account Data: Retained for the duration of the account relationship and for a period following account closure as required by AML and gaming regulations — typically a minimum of five years.
• KYC Documents: Retained for the period mandated by the operator's licensing jurisdiction AML requirements, generally a minimum of five years from account closure.
• Transaction Records: Retained in accordance with financial record-keeping obligations applicable to the operator's licensing jurisdiction.
• Support Communications: Retained for a period sufficient to resolve disputes and maintain quality records, typically one to three years.
• Cookie & Analytics Data: Retained for the session or for a defined analytics window, typically not exceeding 26 months.

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

9. Your Rights

Subject to applicable law and certain exceptions, you hold the following rights in relation to personal data held by 77ad:

To exercise any of the above rights, contact the 77ad support team at [email protected]. We will respond within the timeframe required by applicable law, typically within 30 days. Identity verification may be required before processing a data request.

10. Cookies & Tracking Technologies

77ad uses cookies and similar tracking technologies to enable the Platform to function, improve user experience and analyse usage patterns. The following categories of cookies are used:

Most web browsers allow you to control cookies through browser settings. Disabling non-essential cookies will not prevent you from using the Platform, though some personalisation features may be reduced. 77ad does not use third-party advertising cookies or retargeting pixels on the Platform.

11. Data Security

77ad implements technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration or destruction. These include:

• Encryption in Transit: All data transmitted between your device and the Platform is protected using TLS encryption.
• Encryption at Rest: Sensitive personal data and KYC documents stored on Platform servers are encrypted at rest.
• Access Controls: Internal access to personal data is restricted to authorised personnel who require it for their role, subject to role-based access controls and audit logging.
• Two-Factor Authentication: User accounts may be protected with two-factor authentication. We strongly recommend enabling this feature.
• Penetration Testing: The Platform undergoes periodic security assessments to identify and remediate vulnerabilities.

While 77ad applies appropriate security measures, no system is completely impervious to breach. In the event of a data breach that poses a material risk to your rights, we will notify affected Users and relevant authorities as required by applicable law.

12. Minors

The 77ad Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. The Platform is not directed at minors and we do not knowingly collect personal data from individuals under the applicable minimum age.

Age verification is part of the registration and KYC process. Where it is determined that a User is under the applicable minimum age, the account will be immediately suspended, all activity will be voided, and any deposited funds will be returned in accordance with applicable law and operator policy.

If you believe a minor has registered on or is accessing the Platform, please contact us immediately at [email protected].

13. Third-Party Services

The 77ad Platform integrates third-party service providers to deliver key functions, including payment processing, KYC verification, fraud detection, game delivery and customer support tooling. When you interact with these integrations, the relevant third party may also process your data in accordance with their own privacy policies.

Familiar Pakistani payment references — such as Easypaisa, JazzCash, Raast and bank transfers via HBL, UBL, Meezan Bank and Bank Alfalah — are cited as contextual examples of payment rails familiar to Pakistani users. Where any such provider is integrated in the cashier, their applicable terms and privacy policies govern the data they independently collect. 77ad does not control the data practices of third-party payment providers.

The 77ad Platform does not contain links to external websites. No third-party advertising networks are permitted to place cookies or tracking scripts on the Platform.

14. Changes to This Privacy Policy

77ad reserves the right to update this Privacy Policy from time to time to reflect changes in legal requirements, Platform features or data processing practices. Material changes will be communicated via a Platform notice, an email to your registered address, or both.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the Platform following notification of a material change constitutes acceptance of the revised Policy. If you do not agree with the updated Policy, you must cease using the Platform and may request account closure.

15. Contact Us

For any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact the 77ad Data Support Team through the following channels:

• Email: [email protected] — response target within 24 hours on business days. For data subject requests, please use the subject line "Privacy Request".
• Live Chat: Available 24/7 via the widget on the Platform. For sensitive data requests, email is preferred to ensure a written record.

When submitting a data request, please include your registered username, a description of the request and any relevant account reference numbers. We will verify your identity before processing requests that involve disclosure or deletion of personal data.

77ad supports users across Pakistan — from Karachi and Lahore to Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. All privacy communications are handled in English; Urdu language assistance may be available on request via live chat.