Privacy Policy

1 Introduction

Welcome to on77 ("we", "us", "our"). on77 is a Pakistan-focused online gaming platform available at https://on77.bid. We offer casino games, Test Cricket betting, SadaPay transfers, Jackpot Slots, and live dealer tables — all denominated in Pakistani Rupees (PKR) and supported by a 24/7 English-language support team.

This Privacy Policy explains what personal information we collect from users in Pakistan and elsewhere, why we collect it, how we process it, who we may share it with, and what rights you hold as a data subject. By registering an account or using any on77 service, you acknowledge that you have read and understood this Policy.

If you have questions about this Policy at any time, our support team is available around the clock. Please refer to the Contact section at the end of this document.

2 Data We Collect

We collect personal data in three broad ways: data you provide directly, data generated automatically through your use of our platform, and data obtained from trusted third parties for verification purposes.

We do not collect special-category sensitive data (such as biometric data for identification purposes, health data, or political opinions) beyond what is strictly required for responsible gaming checks or legally mandated anti-money-laundering (AML) verification.

3 How We Use Your Data

Your personal information is used exclusively for the purposes listed below. We do not use it for any undisclosed or unrelated purpose.

• Account Management: Creating, maintaining, and authenticating your on77 account.
• Service Delivery: Processing your deposits and withdrawals in PKR via Easypaisa, JazzCash, SadaPay, Raast, and supported banks; crediting winnings; running game sessions.
• KYC & AML Compliance: Verifying your identity and age (18+ requirement) as required by applicable law and our internal responsible gaming framework.
• Fraud Prevention & Security: Detecting and preventing unauthorised access, bonus abuse, collusion, and money laundering.
• Customer Support: Resolving account queries, disputes, and technical issues reported via our support channels.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling behaviours and applying self-exclusion or cooling-off limits where relevant.
• Communications: Sending you transactional notifications (deposit confirmed, withdrawal processed) and, where you have opted in, promotional updates about new games or platform features.
• Legal Obligations: Retaining records as required by applicable regulations and responding to lawful requests from authorities.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game selection, performance, and the overall user experience.

We apply the principle of data minimisation: each processing activity uses only the minimum data necessary to achieve its stated purpose.

4 Legal Basis for Processing

We rely on the following legal bases when processing your personal data:

• Contractual Necessity: Processing required to perform the services you have requested — account creation, payments, gameplay, and support.
• Legal Obligation: Processing mandated by AML, KYC, and record-keeping laws applicable to online gaming platforms.
• Legitimate Interests: Fraud prevention, platform security, and improving our services — provided these interests are not overridden by your rights.
• Consent: Marketing communications and non-essential cookies, where you have provided clear, freely given consent. You may withdraw consent at any time.

5 Data Sharing & Disclosure

on77 does not sell, rent, or exchange your personal data with advertisers, data brokers, or unrelated commercial entities. We share data only in the following limited circumstances:

• Payment Processors: Tokenised transaction data is shared with Easypaisa, JazzCash, SadaPay, and our banking partners (HBL, UBL, MCB, Bank Alfalah, Meezan Bank) solely to process your financial transactions.
• KYC / Identity Verification Providers: Document images and identity data are shared with our appointed third-party KYC provider under strict data processing agreements.
• Game Software Providers: Minimum session and account data (a user ID and game stake) is shared with game studios to run your game sessions. These providers are contractually bound to process this data only for game delivery purposes.
• Customer Support Platforms: Support tickets may be processed via a third-party helpdesk tool operating under a data processing agreement with on77.
• Regulatory & Law Enforcement Authorities: We will disclose information to competent authorities when legally required by a valid court order, subpoena, or government directive — or where we are under a statutory obligation to report suspicious activity.
• Corporate Restructuring: In the event of a merger, acquisition, or asset sale, user data may be transferred as part of that transaction. We will notify affected users in advance wherever practicable.

6 Data Retention

We retain personal data only for as long as is necessary to fulfil the purpose for which it was collected or as required by law. Our general retention schedule is as follows:

• Active Account Data: Retained for the lifetime of your account plus an additional 5 years following account closure, in line with standard AML record-keeping practices.
• Transaction Records: Retained for a minimum of 7 years from the date of each transaction to satisfy financial reporting and AML obligations.
• KYC Documents: Retained for 5 years from the date of verification or account closure, whichever is later.
• Support Communications: Retained for 3 years to allow us to revisit historical disputes where necessary.
• Technical Logs: Retained for 12 months and then automatically purged.
• Marketing Consent Records: Retained until you withdraw consent, plus an additional 2 years as evidence of prior consent.

When data is no longer required, it is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

7 Security Measures

Protecting your data is a top operational priority at on77. We implement the following technical and organisational safeguards:

• AES-256 encryption for all data at rest; TLS 1.3 for all data in transit.
• Multi-factor authentication (MFA) available on all user accounts and mandatory for internal administrative access.
• Regular third-party penetration testing and security audits of our platform infrastructure.
• Role-based access controls ensuring that employees can only access personal data required for their specific function.
• Continuous real-time monitoring with automated alerts for anomalous access patterns.
• Tokenised payment processing — raw payment credentials are never stored on on77 servers.
• Formal incident response plan with defined escalation procedures and notification timelines in the event of a data breach.

Despite these measures, no system is entirely immune to risk. We strongly encourage users to choose strong, unique passwords for their on77 accounts, enable MFA, and notify us immediately at [email protected] (plain text — not a link) if they suspect any unauthorised access.

8 Cookies & Tracking Technologies

on77 uses cookies and similar tracking technologies to ensure the platform functions correctly and to analyse how users interact with our services. We categorise our cookies as follows:

• Strictly Necessary Cookies: Required for core functionality such as session management, account authentication, and fraud prevention. These cannot be disabled without impairing the service.
• Analytics Cookies: Used to collect anonymised, aggregated data about how players navigate the platform — helping us identify popular games, technical issues, and areas for improvement. These are only placed with your consent.
• Preference Cookies: Remember your display settings and language preferences to deliver a more personalised experience. Placed with your consent.

We do not use third-party advertising or tracking cookies that follow you across the internet. You may manage your cookie preferences via the on-screen cookie consent banner or your browser settings at any time.

9 Your Privacy Rights

As a user of on77, you hold the following rights over your personal data. To exercise any of these rights, please contact us using the details in Section 13.

• Right of Access: You may request a copy of all personal data we hold about you, free of charge, within 30 days of your request.
• Right to Rectification: If any of your data is inaccurate or incomplete, you have the right to request correction.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may ask us to pause processing of your data in certain circumstances — for example, while a correction request is being resolved.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format so you can transfer it to another controller.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing. Where you object to marketing, we will stop immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

10 Minors & Age Policy

on77 is strictly an 18+ platform. We do not knowingly collect personal data from individuals under the age of 18. During registration, all users are required to confirm their age and, where required by our KYC process, to provide identity documents that verify they meet the minimum age requirement.

If we discover that personal data has been collected from a minor without verifiable parental consent, we will delete that data immediately and close the associated account. If you are a parent or guardian and believe your child has registered on on77, please contact our support team without delay.

11 International Data Transfers

on77 is primarily operated to serve players in Pakistan. Some of our service providers — including cloud infrastructure, KYC verification partners, and game software studios — may process data in jurisdictions outside Pakistan. Where such transfers occur, we ensure that appropriate safeguards are in place, including:

• Contractual clauses (standard contractual clauses or equivalent) requiring the recipient to protect data to the same standard as this Policy.
• Transfers only to countries or organisations that provide an adequate level of data protection.

We never transfer data internationally without a documented legal basis for doing so.

12 Changes to This Policy

on77 may update this Privacy Policy from time to time to reflect changes in our services, applicable law, or industry best practices. When we make material changes, we will:

• Post the updated Policy on this page with a revised effective date.
• Notify registered users via the email address associated with their account at least 14 days before significant changes take effect.
• In some cases, request renewed consent if the change affects processing activities that were previously based on consent.

We encourage you to review this page periodically. Your continued use of on77 after a Policy update constitutes acceptance of the revised terms.

13 Contact & Data Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or the personal data we hold about you, please reach our Data Protection team through the following channel:

Please include your registered username, the nature of your request, and any relevant details so we can process your enquiry efficiently and without unnecessary delay.