77ck Privacy Policy

This Privacy Policy ("Policy") describes the data processing practices of the legal entity operating the 77ck online gaming platform at 77ck.im ("77ck", "we", "us", "our"). 77ck acts as the data controller for all personal data collected from players using the 77ck platform and is responsible for determining the purposes and means of processing that personal data.

This Policy applies to all personal data collected from players and prospective players in connection with their access to and use of the 77ck platform, including the website at 77ck.im, any associated mobile applications, customer support interactions, and marketing communications.

By registering a player account on the 77ck platform, you confirm that you have read and understood this Privacy Policy and you consent to the collection, processing, and use of your personal data as described herein. Where processing is based on consent, you have the right to withdraw that consent at any time, subject to the limitations described in Section 9.

77ck collects the following categories of personal data from players. We have organised these into categories for clarity:

2.1 Identity & Registration Data

• Full legal name (as it appears on your CNIC);
• Date of birth (used to verify the 21+ age requirement);
• Pakistani CNIC number and CNIC document images (front and back);
• Gender (optional, collected for account personalisation only);
• Nationality and country of residence.

2.2 Contact Data

• Email address (primary communication channel);
• Mobile phone number (used for OTP verification and account security);
• Residential address (used for KYC and fraud prevention purposes).

2.3 Financial & Payment Data

• JazzCash account mobile number and registered name;
• EasyPaisa account mobile number and registered name;
• Bank account details (HBL, UBL, Meezan Bank) including account title and IBAN where applicable;
• Cryptocurrency wallet addresses (for USDT/TRC20 and Bitcoin transactions);
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method references.

2.4 Gaming & Betting Activity Data

• All bets placed, including game type, stake amount, outcome, and timestamp;
• Sports betting selections including match, market type, odds, and settlement result;
• Session duration and login/logout timestamps;
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status).

2.5 Technical & Device Data

• IP address at time of login and registration;
• Device type, operating system, and browser version;
• Mobile network operator (e.g., Jazz, Telenor, Zong, Ufone) where available;
• Geolocation data (country and city level only, not precise GPS coordinates).

2.6 Communications Data

• Customer support chat transcripts and email correspondence;
• Complaint records and dispute history;
• Responses to surveys or promotions where participation is voluntary.

77ck collects personal data through the following channels and mechanisms:

3.1 Direct Collection

The majority of personal data we hold about you is provided directly by you when you: register a player account on the 77ck platform; submit KYC verification documents; make a deposit or withdrawal request; contact our customer support team; participate in a promotion or complete a survey; or set responsible gaming tool preferences in your account settings.

3.2 Automated Technical Collection

When you access and use the 77ck platform, certain technical data is collected automatically by our systems and third-party analytics tools, including: your IP address; device identifiers; browser type and version; pages visited and time spent; referring URLs; and session activity logs. This data is primarily used for platform security, fraud prevention, and performance optimisation purposes.

3.3 Third-Party Sources

In limited circumstances, 77ck may receive personal data about you from third-party sources, including:

• Identity verification service providers used to confirm the authenticity of your CNIC;
• Payment processors (JazzCash, EasyPaisa, banking partners) who may confirm transaction details;
• Fraud prevention and anti-money laundering screening databases;
• Publicly available sanctions and politically exposed persons (PEP) watchlists.

77ck processes your personal data on the following legal bases, consistent with internationally recognised data protection principles:

77ck uses the personal data it collects for the following specific purposes:

5.1 Account Operations

To create, maintain, and manage your player account; to authenticate your identity at login; to process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, USDT, and Bitcoin; and to provide you with access to all games and betting markets available on the 77ck platform.

5.2 Regulatory Compliance

To fulfil our Know Your Customer (KYC) obligations; to conduct anti-money laundering (AML) and counter-terrorist financing (CTF) screening; to comply with responsible gaming requirements including age verification, self-exclusion enforcement, and mandatory intervention for at-risk players; and to submit required reports to our licensing authority.

5.3 Security and Fraud Prevention

To detect, investigate, and prevent fraudulent, abusive, or illegal activity on the platform; to enforce our one-account-per-player policy; to identify and block duplicate accounts; to monitor for unusual transaction patterns indicative of money laundering; and to protect the security and integrity of the 77ck platform and its players.

5.4 Customer Support

To respond to your queries, complaints, and account requests in a timely and effective manner; to investigate disputed transactions or game outcomes; and to maintain records of all support interactions for quality assurance and regulatory purposes.

5.5 Marketing Communications (Consent-Based Only)

Where you have provided explicit consent, to send you information about new games, promotions, bonus offers, and other marketing communications relevant to your gaming preferences. You can opt out of marketing communications at any time by updating your account notification settings or by contacting our support team.

5.6 Platform Improvement

To analyse aggregated, anonymised usage data in order to improve the performance, functionality, and user experience of the 77ck platform, including optimising the platform for the mobile devices and network conditions common among Pakistani players.

77ck does not sell your personal data. We share personal data with third parties only in the limited circumstances described below, and only to the extent necessary for each specific purpose:

6.1 Service Providers

77ck engages carefully selected third-party service providers who process data on our behalf under strict data processing agreements, including: identity verification providers (to confirm CNIC authenticity); payment processors (JazzCash, EasyPaisa, banking partners); cloud hosting and infrastructure providers; customer support platform providers; and fraud detection and AML screening service providers. All service providers are contractually required to handle your data in accordance with the standards set out in this Policy.

6.2 Game Providers

The games available on the 77ck platform are provided by licensed third-party game developers and studios. These providers may receive limited technical data (such as a player session token or anonymised player ID) to facilitate game operation and RNG certification. Game providers do not receive your full personal details, CNIC information, or financial data.

6.3 Regulatory and Legal Authorities

77ck will disclose personal data to regulatory authorities, law enforcement agencies, or courts when required to do so by applicable law, licensing requirements, court order, or other legal process. This includes disclosures required in connection with AML/CTF investigations, gaming regulatory inquiries, or fraud prosecutions.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the 77ck business, player personal data may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and of any material changes to the applicable privacy policy prior to the transfer taking effect.

77ck uses cookies and similar tracking technologies on the 77ck.im website to support platform functionality, security, and performance. The following categories of cookies are used:

7.1 Strictly Necessary Cookies

These cookies are essential for the 77ck platform to function correctly. They maintain your login session, remember your account preferences, and protect the platform from cross-site request forgery (CSRF) attacks. These cookies cannot be disabled without materially impairing your ability to use the platform.

7.2 Functional Cookies

These cookies remember your language preferences, game lobby sorting preferences, and display settings to provide a more personalised experience on subsequent visits. They do not track your activity across other websites.

7.3 Analytics Cookies

77ck uses privacy-respecting analytics tools to understand how players use the platform — which pages are most visited, how long sessions typically last, and which device types are most common. This data is collected in aggregated, anonymised form and is used solely to improve the platform experience. You may opt out of analytics cookies via your account settings or browser controls.

7.4 Cookie Management

You can manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies will prevent you from logging in to your 77ck account. Disabling analytics cookies will not affect your ability to use the platform but will mean that your session data is excluded from our platform improvement analytics.

77ck retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by our regulatory and licensing obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data destruction procedures.

Subject to applicable data protection law and our regulatory obligations, you hold the following rights with respect to the personal data that 77ck holds about you:

9.1 Right of Access

You have the right to request a copy of all personal data that 77ck holds about you. We will provide this information in a structured, commonly used format within 30 days of receiving a verified request.

9.2 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Please note that corrections to identity data (such as your name or date of birth) may require documentary evidence such as an updated CNIC.

9.3 Right to Erasure ("Right to Be Forgotten")

You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected and no overriding legal basis for retention exists. Please note that we are legally obligated to retain certain data (particularly KYC and financial transaction records) for mandatory regulatory retention periods, and this obligation overrides any erasure request for data in those categories.

9.4 Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data in certain circumstances, including where you contest the accuracy of the data or where you have objected to processing based on legitimate interests pending verification of whether those interests override your rights.

9.5 Right to Data Portability

Where processing is based on your consent or on contract performance, you have the right to receive your personal data in a structured, machine-readable format (such as JSON or CSV) for transfer to another service provider.

9.6 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 communications, we will cease such communications immediately and permanently without requiring justification.

9.7 How to Exercise Your Rights

To exercise any of the above rights, please contact the 77ck Data Privacy team at [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 48 hours and complete it within 30 calendar days. We may ask you to verify your identity before processing the request.

77ck implements a comprehensive, multi-layered security framework to protect all personal data held on the platform. Our security measures include the following technical and organisational controls:

10.1 Encryption

All data transmitted between your device and the 77ck platform is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest — including CNIC documents, payment details, and account credentials — is stored in encrypted form using AES-256 encryption. Encryption keys are managed separately from the encrypted data and are rotated on a scheduled basis.

10.2 Access Controls

Access to personal data within 77ck's internal systems is governed by a strict role-based access control (RBAC) framework. Staff members can only access the personal data that is necessary for their specific job function. All internal data access is logged and subject to regular audit review. Access rights are reviewed quarterly and revoked immediately upon staff departure.

10.3 Infrastructure Security

The 77ck platform is hosted on enterprise-grade cloud infrastructure protected by firewalls, intrusion detection systems, distributed denial-of-service (DDoS) mitigation, and continuous security monitoring. Regular penetration testing is conducted by independent security professionals to identify and remediate vulnerabilities before they can be exploited.

10.4 Incident Response

77ck maintains a documented data breach incident response plan. In the event of a confirmed data breach, our security team will contain the breach, assess the scope and risk to affected players, notify the relevant licensing authority, and — where the breach poses a risk to players' rights or interests — notify affected players within 72 hours of confirmation of the breach.

10.5 Your Role in Security

While 77ck takes all reasonable technical and organisational measures to protect your data, you also play an important role in maintaining account security. You are responsible for keeping your login credentials confidential, using a strong and unique password, enabling two-factor authentication where available, and logging out of your account on shared or public devices. If you suspect your account has been accessed without authorisation, contact our support team immediately.

The 77ck platform is strictly intended for adults aged 21 years and above. 77ck does not knowingly collect, process, or retain personal data from any individual under the age of 21.

Parents and guardians who are concerned that a minor in their household may have registered on the 77ck platform are encouraged to contact our support team immediately at [email protected]. We will treat all such reports as a priority and investigate within 24 hours. We also strongly recommend that parents install parental control software on shared devices to prevent access to gambling platforms.

12.1 As an internationally operating online gaming platform, 77ck may transfer your personal data to service providers and infrastructure systems located outside Pakistan. Such transfers may occur in the context of cloud hosting, identity verification services, payment processing, or fraud screening.

12.2 Where personal data is transferred to a country that does not have a formally recognised equivalent level of data protection, 77ck ensures that appropriate safeguards are in place prior to the transfer. These safeguards include contractual data protection clauses, data processing agreements incorporating internationally recognised model clauses, and where applicable, binding corporate rules.

12.3 By using the 77ck platform and accepting this Privacy Policy, you acknowledge that your personal data may be transferred to, stored in, and processed in jurisdictions outside Pakistan. We commit to ensuring that such transfers are handled with the same level of care and protection described in this Privacy Policy, regardless of where the processing takes place.

13.1 77ck may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable legal requirements, or the services we offer. The most current version of this Policy will always be published at 77ck.im/privacy-policy, with the "Last Updated" date clearly stated at the top of the page.

13.2 Where a change to this Policy is material — meaning it significantly affects how we collect, use, or share your personal data — we will notify you via the email address registered to your account at least 14 days before the change takes effect. For non-material updates such as typographical corrections or clarifications that do not alter the substantive privacy treatment of your data, changes may take effect upon publication without prior notice.

13.3 Your continued use of the 77ck platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not accept the changes, you should cease using the platform and request account closure before the effective date of the update.

13.4 Prior versions of this Privacy Policy are available upon written request to our support team and will be provided within 10 business days of receiving such a request.

14.1 Privacy Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 77ck processes your personal data, please contact our dedicated privacy team using the details below. We aim to acknowledge all privacy enquiries within 48 hours and to provide a full response within 14 business days.

Privacy Contact:
Email (plain text — not a link): [email protected]
Subject line: "Privacy Enquiry – [Your Account Username]"

14.2 Complaints

If you are not satisfied with our response to a privacy enquiry or data rights request, or if you believe that 77ck has processed your personal data in a manner inconsistent with this Policy or applicable data protection law, you have the right to escalate your complaint to:

• 77ck's internal complaints team (first step — contact support as above with subject line "Privacy Complaint");
• The relevant data protection supervisory authority in the jurisdiction in which 77ck holds its operating licence;
• Any other competent regulatory or supervisory authority with jurisdiction over the matter.

We take all privacy complaints seriously. Every complaint will be formally logged, investigated by a senior member of our privacy team, and responded to in writing within 30 calendar days.