Privacy Policy — 777xs

777xs ("we", "us", "our" or the "Operator") operates the online gaming platform accessible at https://777xs.cam (the "Platform"). We are committed to protecting the privacy and personal data of everyone who uses our Platform, particularly our users in Pakistan.

This Privacy Policy (the "Policy") describes what personal data we collect from you, why we collect it, how we use and protect it, with whom we may share it, and what rights you have in relation to that data. It applies to all personal data collected through the Platform — including via account registration, deposits and withdrawals, game play, support interactions, and general browsing of the site.

This Policy should be read alongside our Terms & Conditions. In the event of any conflict between this Policy and the Terms & Conditions on a data-protection matter, this Policy shall take precedence.

We may update this Policy from time to time. The effective date shown at the top of this page reflects the most recent revision. Continued use of the Platform after a material update constitutes acceptance of the revised Policy.

The following terms carry specific meanings throughout this Policy:

• "Controller" means the entity that determines the purposes and means of processing personal data — in this case, 777xs.
• "Data Subject" means any identified or identifiable natural person whose personal data is processed — in this context, you, the Platform user.
• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, phone number, device identifiers, IP address and payment details.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, disclosure, deletion or destruction.
• "Processor" means a third party that processes personal data on behalf of the Controller in accordance with written instructions.
• "Sensitive Personal Data" means personal data revealing racial or ethnic origin, political opinions, religious beliefs, trade-union membership, health data, sexual orientation, or biometric data used for identification purposes.
• "KYC" means Know Your Customer — the identity verification process applied to Account holders.
• "AML" means Anti-Money Laundering — regulatory requirements governing the detection and prevention of financial crime.
• "Cookie" means a small text file placed on your device by the Platform to enable or improve functionality, analytics and personalisation.

The categories of personal data we collect from or about you depend on how you interact with the Platform. The table below summarises the main categories:

4.1 Data You Provide Directly

We collect data that you voluntarily provide when you register an Account, complete KYC verification, make deposits or withdrawal requests, contact our support team, or update your account settings. This includes all information submitted through registration forms, the cashier, and support channels.

4.2 Data Collected Automatically

When you access or interact with the Platform, certain technical and usage data is collected automatically through cookies, server logs and similar technologies. This includes your IP address, device information, browser type, pages visited, session duration and interactions with game content.

4.3 Data From Third-Party Sources

We may receive data about you from third parties in specific circumstances, including:

• Identity verification providers used in our KYC process to confirm the authenticity of documents you submit.
• Payment processors who facilitate deposit and withdrawal transactions — for example, processors associated with Easypaisa, JazzCash, Raast and bank transfer services familiar to Pakistani users. Note that these payment providers are referenced as contextual examples only and do not endorse or partner with 777xs.
• Fraud detection and AML screening services used to comply with anti-money-laundering obligations.
• Analytics providers that aggregate anonymised usage data about Platform performance.

We process your personal data for the following specific, documented purposes. We do not use personal data for any purpose incompatible with those stated below without first obtaining your consent or establishing another appropriate legal basis.

5.1 Account Management

To create, maintain and administer your Account, verify your identity and age, enforce single-account rules, and process account closures or self-exclusion requests.

5.2 Payment Processing

To process deposits and withdrawals, verify that payment methods belong to you, detect and prevent fraudulent transactions, and comply with AML obligations. Financial data associated with payment transactions is handled with particular care and is subject to additional access controls.

5.3 Legal and Regulatory Compliance

To fulfil KYC and AML obligations under applicable law, respond to lawful requests from regulatory authorities, and maintain records as required by applicable financial regulations. This represents a core and unavoidable use of personal data that cannot be opted out of while maintaining an active Account.

5.4 Platform Security and Fraud Prevention

To detect, investigate and prevent fraudulent activity, unauthorised account access, collusion, bonus abuse and other prohibited conduct as described in the Terms & Conditions. Technical data including IP addresses and device identifiers is used for this purpose.

5.5 Customer Support

To respond to your queries, complaints and requests through Live Chat, email and the Help Centre. Communications data is retained to maintain a service history and ensure consistent support quality.

5.6 Responsible Gambling Monitoring

To monitor account activity for signs of problem gambling behaviour and to action responsible gambling requests such as deposit limits, cooling-off periods and self-exclusion. This processing is conducted in your interest as a player protection measure.

5.7 Platform Analytics and Improvement

To understand how users interact with the Platform, identify technical issues, optimise performance and improve the user experience. Analytics data is aggregated and pseudonymised where possible.

5.8 Marketing Communications

To send you promotional offers, bonus notifications and platform updates where you have provided your consent to receive marketing communications. You may withdraw this consent at any time through your account settings or by contacting support.

Each processing activity described in Section 5 is carried out on one or more of the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you under the Terms & Conditions — including account management, payment processing and game delivery.
• Legal Obligation: Processing required to comply with applicable laws — primarily KYC identity verification and AML financial crime prevention obligations.
• Legitimate Interests: Processing carried out for purposes that are in our legitimate interests or those of third parties, provided those interests are not overridden by your rights and freedoms — including fraud prevention, platform security, analytics and improvement.
• Consent: Processing carried out on the basis of your freely given, specific and informed consent — most notably for marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing based on consent before withdrawal.
• Vital Interests: In exceptional circumstances, processing may be carried out to protect the vital interests of you or another person — for example, where a safeguarding concern arises in connection with a responsible gambling interaction.

We do not sell your personal data to third parties. We may share your data only in the limited circumstances described below.

7.1 Service Providers (Processors)

We engage carefully selected third-party service providers who process personal data on our behalf under written data processing agreements. Categories of processor include: identity verification and KYC providers, payment gateway operators, cloud infrastructure providers, customer support platform providers, and fraud and AML screening services. All processors are required to maintain appropriate data security standards.

7.2 Regulatory and Law Enforcement Authorities

We may disclose personal data to competent regulatory authorities, law enforcement agencies or courts where we are legally required to do so — for example, in response to a valid court order, regulatory request or AML reporting obligation.

7.3 Business Transfers

In the event of a merger, acquisition, asset sale or restructuring of the Operator's business, personal data held by us may be transferred to the acquirer or successor entity. You will be notified if your personal data becomes subject to a different privacy policy as a result of such a transaction.

7.4 With Your Consent

We may share your data with third parties not described above where you have given your prior explicit consent to such sharing.

Given the nature of online services, your personal data may be transferred to, stored in, or processed in countries other than Pakistan. Where such transfers occur, we take steps to ensure that your data receives a level of protection consistent with this Policy, including through the use of contractual safeguards with our data processors.

If you are located in Pakistan and your data is transferred internationally, such transfers are made in furtherance of the contractual relationship between you and 777xs and are subject to the data-protection requirements of the jurisdiction in which the Operator is incorporated or licensed.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following principles govern our retention practices:

• Active Accounts: Personal data associated with an active Account is retained for the duration of the account relationship and for a defined period thereafter.
• Closed Accounts: Following Account closure, we are typically required to retain certain records — including identity, transaction and communication data — for a minimum period to satisfy AML, tax and regulatory record-keeping requirements. This period is generally five to seven years from the date of account closure, depending on applicable law.
• KYC Documents: Identity documents submitted for verification are retained in accordance with the applicable KYC and AML regulatory requirements of the jurisdiction in which we operate.
• Marketing Data: Where you withdraw your consent to marketing communications, your data will be removed from active marketing lists promptly. A suppression record may be retained to prevent inadvertent future contact.
• Technical Logs: Server logs and session data are typically retained for a shorter period — sufficient for security monitoring and fraud detection purposes — before being deleted or anonymised.

When personal data is no longer required, it is securely deleted or anonymised in accordance with our internal data-destruction procedures.

The Platform uses cookies and similar tracking technologies to enable core functionality, analyse usage patterns, and improve your experience. The categories of cookies used are described below.

10.1 Essential Cookies

These cookies are strictly necessary to operate the Platform. They enable functions such as session management, login persistence and security features. Essential cookies cannot be disabled without impairing core Platform functionality.

10.2 Analytics Cookies

Analytics cookies help us understand how users interact with the Platform — which pages are most visited, where users drop off, and how different features perform. Data collected is aggregated and does not directly identify you. These cookies may be set by us or by third-party analytics providers.

10.3 Functional Cookies

These cookies remember your preferences — such as your language setting or display preferences — to provide a more personalised experience across sessions.

10.4 Marketing Cookies

Where you have given consent, marketing cookies may be used to present you with relevant promotional content. These cookies track your engagement with promotional material across sessions. You may withdraw your consent to marketing cookies at any time through your browser settings or our cookie preference centre.

Subject to applicable law and certain limitations, you have rights in relation to your personal data held by 777xs. These rights are described below. To exercise any of these rights, please contact us using the details in Section 16.

• Right of Access: You have the right to request confirmation of whether we process personal data about you and, if so, a copy of that data along with information about how it is used.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data we hold about you. You can update many account details directly through your account settings.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. This right is subject to limitations where we are required to retain data for legal or regulatory compliance purposes (see Section 9).
• Right to Restrict Processing: You may request that we limit the processing of your personal data in specific circumstances — for example, while a dispute about data accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request that we provide your personal data in a structured, commonly used and machine-readable format.
• Right to Object: You have the right to object to processing based on legitimate interests, including profiling for marketing purposes. Where you object to marketing processing, we will cease such processing promptly.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

We will respond to rights requests within a reasonable timeframe consistent with applicable law. We may need to verify your identity before processing a data rights request to protect against unauthorised access.

The 777xs Platform is strictly intended for adults aged 18 or older, or the higher minimum age required by the operator's license jurisdiction or applicable local law. We do not knowingly collect, solicit or process personal data from persons under 18 years of age.

If we become aware that personal data has been collected from a person under the minimum age, we will take immediate steps to delete that data and close the associated Account. If you believe that a minor has provided personal data to us, please contact us at the details in Section 16 so that we can investigate and take appropriate action.

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• HTTPS / TLS Encryption: All data transmitted between your device and the Platform is encrypted in transit using industry-standard TLS protocols.
• Access Controls: Personal data is accessible only to authorised personnel who have a legitimate need to process it for the purposes described in this Policy. Access is governed by role-based access controls and reviewed periodically.
• Pseudonymisation and Anonymisation: Where practicable, analytics and reporting functions use pseudonymised or anonymised data sets to reduce privacy risk.
• Infrastructure Security: Platform infrastructure is maintained with appropriate security patching, monitoring and intrusion detection to protect against external threats.
• Payment Data Handling: Financial transaction data is handled through PCI-DSS compliant payment processors. We do not store full payment card numbers on Platform servers.

While we apply these measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own account credentials. Please notify us immediately if you suspect any unauthorised access to your Account.

The Platform may integrate or interact with third-party services — including payment processors, identity verification providers, game content suppliers and analytics tools. Each of these third parties operates under its own privacy policy, and we encourage you to review their policies where relevant to your interactions.

We are not responsible for the privacy practices of third-party websites, applications or services that are not operated by 777xs. Links to third-party services do not constitute an endorsement of or affiliation with those services.

Where third parties process personal data on our behalf as Processors (as defined in Section 2), they do so under written contractual terms that require them to maintain appropriate security and handle data only for the purposes we specify.

We reserve the right to update this Privacy Policy at any time in response to changes in applicable law, our data processing practices, or the features and services available on the Platform. The effective date at the top of this page will reflect the date of the most recent update.

Where changes are material — for example, where we introduce a new category of data processing or a new third-party sharing arrangement — we will endeavour to provide you with advance notice, either through a prominent notice on the Platform or via email to your registered address.

Your continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you should discontinue use of the Platform and may close your Account in accordance with the Terms & Conditions.

If you have any questions, concerns or requests relating to this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 11, please contact the 777xs Data Privacy team through the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line for data rights requests.
• Live Chat: Available 24/7 from the Platform's Help Centre (account login required).
• Help Centre: Accessible from the Platform navigation for self-service information and to raise formal queries.

We will acknowledge your request promptly and respond within a reasonable period. We may require you to verify your identity before processing a data subject rights request to ensure we protect your information from unauthorised disclosure.

If you are not satisfied with our response to a privacy concern, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction. For Pakistani users, legal developments in data protection regulation may create additional supervisory bodies or rights in future — please monitor applicable Pakistani law developments accordingly.