Privacy Policy —
77hm Data Practices

1 Introduction

77hm ("we", "us", "our" or the "Operator") is committed to protecting the privacy and personal data of every individual who visits, registers with or uses the 77hm platform at https://77hm.cam (the "Platform"). This Privacy Policy (the "Policy") sets out, in a transparent and structured manner, how we collect, process, store, share and protect personal information in connection with the Platform and all associated services.

This Policy applies to all users of the 77hm Platform, including registered account holders, prospective players who browse the site without registering, and any other individuals whose data we process in connection with the operation of the Platform. By accessing the Platform or creating an account, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

77hm processes personal data in accordance with the data protection legislation applicable in the jurisdiction where the Operator is registered and licensed. We do not represent that this Policy satisfies any specific data protection requirements that may apply under Pakistani law. Players accessing the Platform from Pakistan are solely responsible for assessing their own legal obligations.

2 Definitions

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

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including name, address, email, IP address, device identifiers, payment details and gameplay history.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, transfer and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this case, 77hm.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller under a binding data processing agreement.
• "Consent" means a freely given, specific, informed and unambiguous indication of the data subject's agreement to the processing of their Personal Data.
• "KYC" means Know Your Customer — the identity and age verification process required to operate a regulated gaming account.
• "Cookies" means small text files placed on your device by the Platform to facilitate session management, analytics and personalisation.

3 Data We Collect

77hm collects the following categories of Personal Data in connection with the operation of the Platform:

3.1 Registration Data

When you create a 77hm account, we collect your full legal name, date of birth, email address, mobile telephone number, residential address (including city, such as Karachi, Lahore, Islamabad or Rawalpindi) and chosen account credentials.

3.2 Identity & KYC Documents

To comply with age verification and anti-money-laundering obligations, we collect copies of government-issued identity documents (e.g., CNIC, passport, driving licence), proof-of-address documents and, where required, source-of-funds documentation.

3.3 Financial Data

We collect records of deposits, withdrawals and transaction histories associated with your account. We do not store full payment card numbers or mobile wallet PINs. Payment method identifiers (e.g., registered mobile number for Easypaisa or JazzCash wallet references) are retained solely for transaction reconciliation and fraud prevention purposes.

3.4 Usage & Gameplay Data

We collect detailed records of your activity on the Platform, including pages visited, games played, bets placed, wager amounts, session durations, login timestamps and interaction with promotional offers.

3.5 Technical & Device Data

We automatically collect IP addresses, browser type and version, operating system, device identifiers, screen resolution, referring URLs and geolocation data (at city or country level) when you access the Platform.

3.6 Communications Data

We retain records of your communications with 77hm support, including live chat transcripts, email correspondence and feedback submissions, for quality assurance, dispute resolution and training purposes.

4 How We Collect Your Data

77hm collects Personal Data through the following channels:

• Directly from you — when you register an account, complete KYC, make a deposit or withdrawal, contact support or respond to a survey.
• Automatically — through cookies, web beacons, server logs and analytics tools that record your interaction with the Platform.
• From third-party KYC providers — identity verification partners may return supplementary data about the documents you submit, including validation status and fraud signals.
• From payment processors — transaction confirmation, payment status updates and chargeback notifications are passed back to 77hm by our payment service partners.
• From fraud detection services — third-party risk and fraud intelligence providers may share signals with us to help identify potentially fraudulent account activity.

5 Legal Bases for Processing

We process your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity — processing required to operate your account, process transactions and deliver the services you have requested.
• Legal obligation — processing required to comply with applicable laws, including anti-money-laundering requirements, age verification mandates and the operator's licence conditions.
• Legitimate interests — processing necessary for fraud prevention, platform security, responsible gambling monitoring and service improvement, where these interests are not overridden by your rights.
• Consent — processing for marketing communications, optional analytics and non-essential cookies, where you have provided explicit and informed consent. Consent can be withdrawn at any time.

6 How We Use Your Data

77hm uses the Personal Data we collect for the following purposes:

• Creating, maintaining and managing your 77hm account.
• Verifying your identity and age as part of the KYC process prior to processing withdrawals.
• Processing deposits and withdrawals and reconciling transaction records in PKR.
• Detecting, investigating and preventing fraudulent activity, collusion and money laundering.
• Monitoring gameplay patterns for responsible gambling purposes and applying player protection measures where warranted.
• Providing customer support and resolving disputes in connection with your account or transactions.
• Improving the Platform's features, performance and content through aggregated analytics.
• Sending transactional communications, including account notifications, security alerts and withdrawal confirmations.
• Sending promotional and marketing communications, subject to your prior consent.
• Complying with the Operator's legal and regulatory obligations under applicable licensing conditions.

7 Disclosure to Third Parties

77hm does not sell your Personal Data to third parties. We may share your data with the following categories of recipients, strictly for the purposes described in this Policy:

7.1 Service Providers

We engage Data Processors — including KYC verification providers, payment processors, cloud hosting providers, analytics platforms and customer support tools — who process Personal Data on our behalf under binding contractual terms that restrict their use of your data to the delivery of services to 77hm.

7.2 Game Content Suppliers

Third-party game providers who supply casino titles and live dealer content accessible via the Platform may receive technical identifiers (such as a pseudonymous player token) necessary to operate the game session. These providers are required to handle such data in accordance with their own certified data security standards.

7.3 Regulatory and Law Enforcement Authorities

We may disclose Personal Data to competent regulatory authorities, law enforcement agencies or courts where required to do so by applicable law, a valid court order or the conditions of the Operator's licence. We will notify you of any such disclosure where we are legally permitted to do so.

7.4 Business Transfers

In the event of a merger, acquisition, asset sale or corporate restructuring involving 77hm, your Personal Data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and any resulting changes to this Policy.

8 International Data Transfers

As an online platform operating across multiple jurisdictions, 77hm may transfer your Personal Data to countries outside your country of residence, including countries where data protection laws may differ from those applicable in your jurisdiction. Where such transfers occur, we take appropriate safeguards to ensure that your Personal Data receives an adequate level of protection, including the use of contractual data transfer mechanisms and data processing agreements with all relevant parties.

By creating an account and using the 77hm Platform, you acknowledge and consent to the transfer of your Personal Data to servers and processors located outside Pakistan where necessary for the operation of the Service.

9 Data Retention

77hm retains Personal Data for as long as your account remains active and for the minimum period required by the Operator's legal, regulatory and contractual obligations thereafter. Specific retention periods include, but are not limited to:

• KYC and identity documents: retained for a minimum of five (5) years following account closure, in line with standard anti-money-laundering record-keeping requirements.
• Financial transaction records: retained for a minimum of five (5) years to satisfy financial reporting and audit obligations.
• Gameplay and session logs: retained for a minimum of three (3) years for dispute resolution and responsible gambling monitoring purposes.
• Support communications: retained for a minimum of two (2) years following the resolution of the relevant enquiry.
• Marketing consent records: retained until consent is withdrawn and for a reasonable period thereafter to demonstrate compliance.

Once the applicable retention period has expired and no further legal basis for processing exists, Personal Data is securely deleted or anonymised so that it can no longer be attributed to an individual.

10 Cookies & Tracking Technologies

77hm uses cookies and similar tracking technologies to ensure the Platform functions correctly, to remember your preferences and to understand how users interact with the site. The categories of cookies we use are as follows:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without affecting Platform functionality.
• Functional cookies: Enable enhanced functionality such as remembering your language preference, account dashboard layout and display settings.
• Analytics cookies: Collect aggregated, anonymised data about how users navigate the Platform, which we use to improve performance and content. These are deployed only with your consent.
• Marketing cookies: Used to track the effectiveness of promotional campaigns and to serve relevant offers. These are deployed only with your explicit prior consent.

You can manage your cookie preferences through your browser settings or through the consent management tool available on the Platform. Withdrawing consent for non-essential cookies will not affect Platform access but may reduce certain personalisation features.

11 Marketing Communications

77hm may send you promotional communications — including notifications about new game releases, sports betting promotions, PSL T20 markets, ICC tournament special offers and loyalty programme updates — by email or push notification, provided that you have given your prior, explicit consent to receive such communications during registration or through your account settings.

You may withdraw your marketing consent at any time by updating your notification preferences in your account dashboard or by contacting support. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal, nor does it affect transactional communications which we are obliged to send you regardless of marketing preference.

12 Responsible Gambling & Data Processing

As part of our responsible gambling obligations, 77hm processes gameplay data — including session durations, wager frequency, deposit patterns and loss trajectories — to identify indicators of potentially problematic gambling behaviour. This processing is carried out under our legitimate interest in player welfare and, where applicable, as a regulatory obligation under the Operator's licence conditions.

Where our monitoring systems or support team identify concerning patterns, we may: (a) proactively contact you to offer responsible gambling tools; (b) impose temporary protective limits on your account; or (c) refer your case to a designated player-protection officer for assessment. Any such processing will be handled with appropriate care and confidentiality.

Players who have activated self-exclusion will have their account flagged to prevent further access. Self-exclusion records are retained for the full duration of the exclusion period and for a reasonable period thereafter to prevent inadvertent reactivation. For more information on available tools, visit our Responsible Gambling page.

13 Your Data Rights

Subject to applicable data protection legislation and any overriding legal obligations (including mandatory retention requirements), you have the following rights with respect to your Personal Data held by 77hm:

• Right of Access: You may request a copy of the Personal Data 77hm holds about you and information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data. For name or date-of-birth corrections, documentary evidence may be required.
• Right to Erasure: You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, provided no overriding legal retention obligation applies.
• Right to Restrict Processing: You may request that 77hm limits the processing of your Personal Data in certain circumstances, for example while a dispute is being investigated.
• Right to Data Portability: Where processing is based on your consent or a contract, you may request a machine-readable copy of the Personal Data you have provided to 77hm.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes, where your individual circumstances warrant such an objection.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time through your account settings or by contacting support.

To exercise any of the above rights, please contact us using the details provided in Section 17. We will respond to all verified requests within the timeframe required by applicable data protection law. We may require proof of identity before processing a data rights request.

14 Data Security

77hm takes the security of your Personal Data seriously. We implement a range of technical and organisational measures to protect your data against unauthorised access, accidental loss, disclosure or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• Role-based access controls ensuring that only authorised personnel can access Personal Data, and only to the extent required for their role.
• Regular penetration testing and vulnerability assessments of Platform infrastructure.
• Pseudonymisation of player identifiers where data is used for analytics purposes.
• Secure destruction of physical and electronic records once retention periods have expired.

Notwithstanding these measures, no internet-based transmission or storage system can be guaranteed as 100% secure. You are responsible for maintaining the security of your account credentials and for notifying 77hm immediately if you suspect any unauthorised access to your account.

15 Children & Minors

The 77hm Platform is strictly intended for adults aged 18 and above, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect Personal Data from individuals under the required minimum age. If we become aware that a minor has registered an account or provided Personal Data without proper parental consent, we will immediately suspend the account, delete the associated Personal Data and take such further action as is appropriate.

If you have reason to believe that a minor has accessed the 77hm Platform, please contact our support team immediately so that we can investigate and take appropriate action.

16 Amendments to This Policy

77hm reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable legislation or Platform functionality. When material changes are made, we will notify registered users by email or through a prominent notification on the Platform prior to the changes taking effect. The revised Policy will be posted on this page with an updated "Last Updated" date.

Your continued use of the 77hm Platform following the publication of an updated Policy constitutes your acceptance of the revised data practices. If you do not agree with any amendment, you must cease using the Platform and may request account closure under the terms of our Terms & Conditions.

17 Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data by 77hm, please contact us through the following channel:

Email: [email protected]

This email address is displayed as plain text only and is not a clickable link. We endeavour to respond to all data-related enquiries within five (5) business days. For account security concerns or urgent KYC queries, please use the live chat function within your account dashboard where available.

For information on responsible gambling tools, self-exclusion requests and player-protection resources, please visit our Responsible Gambling page or consult the FAQ for step-by-step guidance.