Contents
- 1. Introduction
- 2. Definitions
- 3. Data Controller
- 4. Data We Collect
- 5. Legal Basis
- 6. How We Use Your Data
- 7. Data Sharing
- 8. Cookies & Tracking
- 9. Data Retention
- 10. Data Security
- 11. Your Rights
- 12. International Transfers
- 13. Children's Privacy
- 14. Third-Party Services
- 15. Policy Amendments
- 16. Contact Us
1. Introduction
This Privacy Policy ("Policy") describes how x77com ("we", "us", "our", "the Platform") collects, uses, stores, shares and protects the personal data of users ("you", "your", "User") who access and use the x77com online betting and gaming platform at https://x77com.cam.
x77com is committed to handling your personal data responsibly and in accordance with applicable data protection principles. This Policy is designed to give you clear, honest and comprehensive information about our data practices so you can make informed decisions about your privacy when using our services.
By registering an account, accessing the Platform or using any of our services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this Policy, you should discontinue use of the Platform and may request account closure by contacting our support team.
This Policy is effective as of the date stated above and supersedes all prior versions. We recommend reviewing this page periodically to stay informed of any updates. Significant changes will be communicated through a notice on the Platform or, where contact details are available, by email.
2. Definitions
The following terms have the meanings set out below throughout this Policy:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person, including name, email address, date of birth, financial details and device identifiers. |
| "Processing" | Any operation performed on personal data, including collection, recording, storage, adaptation, retrieval, use, disclosure and deletion. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data. For the purposes of this Policy, the Data Controller is x77com. |
| "Data Processor" | A third party that processes personal data on behalf of the Data Controller under a written agreement. |
| "KYC" | Know Your Customer — the identity and age verification process required to access full platform functionality. |
| "Cookie" | A small text file stored on your device by a web browser, used to remember preferences or collect analytical data. |
| "CNIC" | Computerised National Identity Card — Pakistan's primary government-issued identity document. |
| "Sensitive Data" | A subset of personal data warranting heightened protection, including identity documents, financial records and, where applicable, information on self-exclusion or responsible gambling status. |
3. Data Controller
x77com is the Data Controller responsible for the personal data collected through this Platform. As Data Controller, we determine the purposes and means by which your personal data is processed and are accountable for the lawful handling of that data.
For all data-related enquiries, including requests to exercise your rights under Section 11, please contact us using the details provided in Section 16 of this Policy.
4. Personal Data We Collect
We collect personal data in the following categories, depending on how you interact with the Platform:
4.1 Registration & Account Data
When you create an account, we collect:
- Full legal name;
- Date of birth (to verify minimum age eligibility of 18+ or higher as required);
- Residential address — including city (such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) and country;
- Email address and phone number;
- Username and encrypted password;
- Preferred currency (PKR or other supported currencies).
4.2 Identity Verification (KYC) Data
To comply with our identity verification obligations, we may collect:
- Government-issued photo identification — such as a Pakistani CNIC or passport;
- Proof of residential address — such as a utility bill or bank statement;
- Selfie or liveness verification image;
- Source of funds documentation where required by internal risk or compliance procedures.
4.3 Financial & Transaction Data
When you deposit, withdraw or place bets, we process:
- Deposit and withdrawal transaction records, including amounts in PKR or other currencies;
- Payment method details (such as bank account numbers, mobile wallet identifiers for methods like Easypaisa or JazzCash — as initiated by you);
- Betting and gaming history, including markets wagered, stakes and outcomes;
- Bonus and promotional activity records.
4.4 Technical & Usage Data
When you access the Platform, we automatically collect:
- IP address and approximate geolocation;
- Device type, operating system and browser information;
- Session activity, pages visited, clicks and interaction logs;
- Referral source and traffic attribution data;
- Cookie and tracking technology data (see Section 8).
4.5 Communications Data
When you contact our support team, we retain:
- The content and metadata of live chat conversations, emails and support tickets;
- Records of any complaints, disputes or responsible gambling tool requests you submit.
4.6 Responsible Gambling Data
If you use responsible gambling tools — including deposit limits, self-exclusion requests, cooling-off periods or loss limit settings — we record those preferences and decisions. This data is treated as Sensitive Data and handled with heightened care. It is used solely for the purpose of implementing your requested restrictions and complying with responsible gambling obligations.
5. Legal Basis for Processing
We process your personal data on one or more of the following legal grounds:
| Legal Basis | Examples of Processing Activities |
|---|---|
| Contract performance | Creating and managing your account; processing deposits, withdrawals and bets; providing customer support. |
| Legal obligation | KYC identity and age verification; anti-money laundering (AML) checks; fraud detection; retaining transaction records as required. |
| Legitimate interests | Platform security monitoring; fraud prevention; improving user experience; analytics and service optimisation. |
| Consent | Sending optional marketing communications (where applicable); placing non-essential cookies on your device (where required by applicable law). |
| Vital interests / public task | Safeguarding vulnerable users; responding to court orders or regulatory directions from competent authorities. |
6. How We Use Your Personal Data
x77com uses your personal data for the following purposes:
6.1 Account Administration
To create, manage and maintain your account; to authenticate your identity at login; to apply account settings and preferences you have specified; and to communicate account-related information such as security alerts and policy updates.
6.2 Identity Verification & Compliance
To verify your identity and age as part of our KYC process; to conduct anti-money laundering and fraud prevention checks; to comply with our internal risk management policies; and to respond to requests from competent legal or regulatory authorities where legally required.
6.3 Transaction Processing
To process deposits and withdrawals; to settle bets and credit winnings; to record and reconcile financial transactions; and to investigate and resolve payment disputes or chargebacks.
6.4 Customer Support
To respond to your enquiries, complaints and disputes; to provide account assistance, technical support and general help through Live Chat, email and the Help Centre; and to maintain records of support interactions for quality assurance and dispute resolution purposes.
6.5 Responsible Gambling
To implement and maintain responsible gambling tools you have activated, including deposit limits, loss limits, session reminders, cooling-off periods and self-exclusion. To monitor account activity for indicators of potentially harmful gambling behaviour and to act in accordance with our responsible gambling obligations.
6.6 Platform Security & Fraud Prevention
To monitor for suspicious, fraudulent or abusive activity; to investigate potential breaches of our Terms & Conditions; to detect and prevent multiple-account abuse; and to protect the integrity of betting markets and casino games.
6.7 Analytics & Service Improvement
To analyse user behaviour and platform performance in aggregate or pseudonymised form; to improve page speed, game loading performance and the overall user experience; and to make informed decisions about feature development and content priorities.
6.8 Marketing Communications
Where you have provided consent or where we have a legitimate interest basis, we may send you promotional communications about offers, new games, platform features and seasonal campaigns. You may opt out of marketing communications at any time through your account settings or by contacting support. Withdrawing consent for marketing does not affect your account access or the processing of data necessary to fulfil our contractual obligations to you.
7. Data Sharing & Disclosure
We do not sell your personal data to third parties. We may share your personal data in the following limited circumstances:
7.1 Service Providers (Data Processors)
We engage trusted third-party service providers who process personal data on our behalf under written data processing agreements. These include:
- Payment processing and fraud screening providers — to process transactions you initiate;
- KYC and identity verification technology providers — to automate and support identity checks;
- Cloud hosting and infrastructure providers — to store and serve platform data securely;
- Customer support platform providers — to manage live chat and ticket systems;
- Analytics and performance monitoring tools — to measure platform usage in aggregate.
All Data Processors are bound by contractual obligations to process your data solely for specified purposes, to maintain appropriate security standards and not to retain data beyond the agreed period.
7.2 Legal Disclosure
We may disclose personal data to competent governmental, regulatory, law enforcement or judicial authorities where we are required to do so by applicable law, court order or regulatory obligation. We will inform you of such disclosures unless legally prohibited from doing so.
7.3 Business Transfers
In the event of a merger, acquisition, restructuring or sale of all or substantially all of our business or assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such change in data controllership through a notice on the Platform.
7.4 Fraud & Security
We may share data with fraud prevention agencies, industry anti-fraud networks or law enforcement where we have reasonable grounds to believe fraudulent activity, money laundering or criminal conduct has occurred or is at risk of occurring.
8. Cookies & Tracking Technologies
x77com uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that help us operate the Platform effectively, remember your preferences and understand how users engage with our content.
8.1 Types of Cookies We Use
- Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens, security tokens and load-balancing cookies. These cannot be disabled without preventing core functionality.
- Functional cookies: Remember your preferences such as language settings, display options and responsible gambling limit configurations.
- Analytics cookies: Collect aggregate, anonymised data about how users navigate the Platform — helping us improve performance and user experience. We may use third-party analytics tools for this purpose.
- Marketing cookies: Track visits and activity to enable targeted promotional content, where applicable and with required consent. You may opt out of marketing cookies through your browser settings or by contacting support.
8.2 Managing Cookies
You can control and manage cookies through your browser settings. Most browsers allow you to refuse all cookies, accept only certain types or delete existing cookies. Note that disabling strictly necessary cookies will impair the Platform's ability to function correctly, including account login and transaction processing. Detailed browser cookie management instructions are available through your browser's help documentation.
9. Data Retention
We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, compliance or dispute resolution obligations. The following general retention periods apply:
| Data Category | Indicative Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + minimum 5 years post-closure | Legal obligation, contract |
| KYC identity documents | Minimum 5 years from account closure or last transaction | AML / legal obligation |
| Financial transaction records | Minimum 5–7 years depending on applicable requirements | Legal obligation |
| Support communications | 3 years from last interaction, or longer if dispute pending | Legitimate interest |
| Marketing consent records | Until consent withdrawn + reasonable compliance period | Consent, legal obligation |
| Self-exclusion records | Duration of exclusion + minimum 5 years | Legal obligation, responsible gambling |
| Technical & usage logs | Up to 24 months, in aggregate/pseudonymised form where possible | Legitimate interest |
On expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.
10. Data Security
x77com implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. Our security measures include, but are not limited to:
- Encryption in transit: All data transmitted between your device and the Platform is encrypted using industry-standard TLS/SSL protocols (HTTPS);
- Encryption at rest: Sensitive stored data, including identity documents and financial records, is encrypted at the storage layer;
- Access controls: Strict role-based access controls limit which staff members can access personal data, with access granted on a need-to-know basis only;
- Authentication: Strong password policies and optional two-factor authentication are available for User accounts;
- Security monitoring: Ongoing monitoring for suspicious activity, attempted breaches and anomalous behaviour;
- Third-party due diligence: Data Processors are assessed for security compliance before engagement and are subject to contractual security obligations.
Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights or freedoms, we will notify affected users and relevant authorities in accordance with applicable legal requirements as promptly as reasonably practicable.
11. Your Data Rights
Depending on your jurisdiction and the legal basis of processing, you may have the following rights in respect of your personal data held by x77com. To exercise any of these rights, please contact us using the details in Section 16.
Right of Access
Request a copy of the personal data we hold about you, along with information about how it is processed.
Right of Rectification
Request correction of inaccurate or incomplete personal data held in your account or records.
Right to Erasure
Request deletion of your personal data where retention is no longer necessary, subject to our legal and compliance obligations to retain certain records.
Right to Restrict Processing
Request that we restrict the processing of your personal data in certain circumstances, such as while a dispute is being investigated.
Right to Data Portability
Request a copy of your personal data in a commonly used, machine-readable format where processing is based on consent or contract.
Right to Object
Object to the processing of your personal data for direct marketing purposes or processing based on our legitimate interests, subject to applicable conditions.
12. International Data Transfers
x77com operates globally and may transfer your personal data to, or process it in, countries outside your jurisdiction of residence. This may include countries where the level of data protection law differs from that applicable in your home country.
Where we transfer personal data internationally, we take steps to ensure that adequate safeguards are in place. These may include contractual data protection clauses with the receiving party, use of approved transfer mechanisms under applicable data protection frameworks, or reliance on a derogation such as the performance of a contract between you and us.
By using the Platform and providing personal data to x77com, you acknowledge that your data may be processed in jurisdictions outside Pakistan. x77com does not claim that such international transfers are subject to the oversight of Pakistani data protection authorities, as no comprehensive federal data protection legislation mandating such oversight is currently in force. Users should be aware of this when making decisions about providing personal data.
13. Children's Privacy
The x77com Platform is strictly intended for adults aged 18 years and over, or the higher minimum age required by the applicable operator license jurisdiction. We do not knowingly collect, process or retain personal data from any individual under the age of 18. Age verification is a mandatory component of our KYC process.
If we become aware that personal data has been provided by or collected from a person who is under the minimum age, we will immediately suspend the associated Account, delete the relevant personal data to the extent not required for legal compliance or fraud prevention purposes, and take appropriate remedial action.
If you believe that a minor has provided personal data to x77com or has accessed the Platform, please contact our support team immediately using the details in Section 16.
14. Third-Party Services & Links
The Platform may reference or interact with third-party services in the ordinary course of operations — for example, payment processing providers that you initiate a transaction through, or analytics tools that collect aggregate usage data. This Policy does not govern the data practices of any third-party service provider, payment institution or external platform.
References to payment methods familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are contextual references used to describe payment options that may be available in the cashier. When you initiate a transaction through any of these channels, your interaction with that provider is governed by their own terms and privacy policies. x77com is not responsible for the privacy practices of third-party payment providers.
15. Amendments to This Policy
x77com reserves the right to update, revise or replace this Privacy Policy at any time. When changes are made, we will update the effective date displayed at the top of this page. Where changes are material — for example, a significant change to the categories of personal data we collect or the purposes for which we use it — we will provide reasonable advance notice through a prominent notice on the Platform or, where contact details are available, by email.
Your continued use of the Platform following the publication of a revised Policy constitutes your acknowledgement of the updated terms. If you do not agree with any changes to this Policy, you should stop using the Platform and may request account closure by contacting our support team.
We recommend that you review this Privacy Policy periodically. Prior versions of this Policy are available on request from the support team.
16. Contact Us
For any questions, concerns or requests relating to this Privacy Policy or your personal data held by x77com, please contact our support team through any of the following channels:
- Live Chat: Available 24 hours a day, 7 days a week through your account dashboard. This is the fastest channel for general privacy queries.
- Help Centre: Self-service articles covering account, privacy and data topics are available through the Help Centre linked from within your account.
- Support Email: [email protected] — for written data rights requests, complaints or detailed queries. Please include your registered username, a clear description of your request and, where relevant, the section of this Policy your query relates to.
We aim to acknowledge all data rights requests within 5 business days of receipt and to provide a substantive response within 30 calendar days. Where a request is complex or involves a large volume of data, we may require additional time and will inform you accordingly.
Privacy at a Glance
We Never Sell Your Data
Your personal data is never sold, rented or traded to third parties for their own marketing purposes. Data shared with processors is governed by strict contractual obligations.
SSL-Encrypted Data
All data transmitted between your device and x77com is protected by TLS/SSL encryption. Sensitive data at rest is also encrypted using industry-standard protocols.
Your Rights Are Supported
Access, rectification, erasure and portability rights are available. Submit requests through Live Chat or the support email — we respond within 30 calendar days.
Defined Retention Periods
We retain data only as long as necessary for legal compliance, dispute resolution and contractual obligations — then securely delete or anonymise it.
Responsible Gambling Data Protected
Self-exclusion and limit-setting data is treated as Sensitive Data. It is used solely to implement your restrictions and is never used for marketing targeting.
Strict Age Verification
We do not knowingly collect data from persons under 18. KYC age checks are mandatory. Any underage data identified is deleted and the account closed immediately.
Your Data. Your Rights. Your Choice.
Now that you understand how x77com handles your data, visit our homepage to explore the platform. For any questions, our support team is available 24/7. 18+ only — local laws apply. Play responsibly.
By using x77com you confirm you are 18+ and have read and accepted our Terms & Conditions and this Privacy Policy. Responsible gambling tools are available at any time through your account settings.