Privacy Policy — he77

he77 (hereinafter "he77", "we", "us" or "our") operates the online betting information and gaming platform accessible at he77.cam (the "Platform"). This Privacy Policy (the "Policy") describes the personal data we collect from users of the Platform, the purposes for which we process it, the lawful basis for such processing, how long we retain it and the rights available to data subjects.

This Policy applies to all users of the Platform, including visitors who have not registered an account and registered users located in or accessing the Platform from any jurisdiction, including Pakistan. By using the Platform, you confirm that you have read and understood this Policy.

he77 processes personal data in accordance with applicable data protection legislation in the operator's licensing jurisdiction. he77 does not claim to be subject to the jurisdiction of Pakistani data protection authorities and does not represent that its data processing practices are certified or approved by any Pakistani government body, including the National Database and Registration Authority (NADRA) or the Pakistan Telecommunication Authority (PTA). This Policy does not constitute legal advice.

he77 collects the following categories of personal data depending on how you interact with the Platform:

3.1 Account Registration Data

• Full legal name
• Date of birth (to verify age eligibility — 18+ or the higher minimum required by the operator/license jurisdiction)
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
• Email address
• Username and encrypted password credentials
• Contact telephone number (where provided)

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents (national identity card, passport, driving licence)
• Proof of address documentation (utility bills, bank statements or official correspondence)
• Selfie or live verification images as required by the KYC process
• Payment method ownership documentation (e.g., redacted bank statements)

3.3 Financial Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method identifiers (wallet IDs, masked card or bank account references)
• Transaction references for payments processed via instruments such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah or other supported channels — collected for transaction management only, not for any third-party marketing purpose
• Currency and conversion records where applicable

3.4 Wagering and Activity Data

• Bet placement history, bet types, markets, stakes and outcomes
• Game participation records (casino, live dealer, esports)
• Session logs including login timestamps, session duration and activity patterns
• Responsible gambling tool usage (deposit limits set, self-exclusion requests, session time alerts)

3.5 Technical and Device Data

• IP address and geolocation data (country and city level)
• Device type, operating system and browser version
• Referring URL and navigation path on the Platform
• Cookie identifiers and analytics identifiers (see Section 10)

3.6 Communications Data

• Support ticket and live chat transcripts
• Email correspondence with he77 support
• Feedback, complaint and dispute records

Personal data is collected through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, place a wager, contact support or submit any information voluntarily through the Platform.
• Automatically — through cookies, server logs, analytics tools and similar technologies that record your interaction with the Platform (see Section 10 for details).
• Third-party sources — where permitted by applicable law, we may receive data from identity verification providers, fraud prevention services, payment processors or publicly available sources to supplement or verify the information you have provided.
• Responsible gambling monitoring — the Platform may collect data regarding your gambling behaviour patterns as part of its responsible gambling obligations, including indicators of problem gambling behaviour.

he77 processes personal data only where a valid lawful basis exists. The following bases apply to our processing activities:

he77 uses your personal data for the following purposes:

• Account management: Creating and maintaining your registered Account, authenticating login sessions and enabling Platform features.
• Identity verification: Conducting KYC checks to confirm your identity, age and address as required.
• Payment processing: Processing deposits, withdrawals and refunds in PKR and facilitating transactions through supported payment channels.
• Service delivery: Providing access to sports betting markets (including cricket, PSL, ICC tournaments, football, UFC and other sports), live casino, slots and all other Platform features.
• Responsible gambling: Monitoring gambling behaviour patterns to detect potential harm indicators, enforcing deposit/loss/session limits and processing self-exclusion requests.
• Fraud prevention and security: Detecting and preventing fraudulent activity, duplicate account creation, money laundering, bonus abuse and other prohibited conduct.
• Legal and regulatory compliance: Meeting obligations under applicable law and licensing conditions, including record-keeping and reporting requirements.
• Customer support: Responding to queries, resolving complaints and maintaining support interaction records.
• Platform improvement: Analysing aggregated usage data to improve the Platform's design, functionality and content.
• Marketing (where consented): Sending promotional communications about he77 offers, bonuses and features to users who have explicitly opted in. Consent may be withdrawn at any time.

he77 does not sell, rent or trade your personal data to third parties for their own marketing or commercial purposes. Personal data may be shared in the following limited circumstances:

• Identity verification providers: Third-party KYC and AML service providers used to verify your identity and conduct due diligence checks as required by applicable compliance obligations.
• Payment processors: Payment service providers and technical intermediaries used to process deposit and withdrawal transactions. These processors act under contractual obligations limiting their use of your data to the purposes of transaction processing.
• Game and software providers: Third-party casino game suppliers whose software is integrated into the Platform may receive session and wagering data necessary for game operation and fairness verification.
• Analytics providers: Aggregated, anonymised or pseudonymised data may be shared with analytics service providers for the purpose of improving Platform performance and user experience.
• Legal and regulatory authorities: Personal data will be disclosed to law enforcement, regulatory bodies or courts where required by applicable law, court order or regulatory demand, or where disclosure is necessary to protect the rights, property or safety of he77, its users or the public.
• Business transfers: In the event of a merger, acquisition, restructuring or sale of all or part of he77's business, personal data may be transferred to the relevant third party as part of that transaction, subject to equivalent privacy protections being maintained.

he77 operates internationally and your personal data may be transferred to, stored in or processed by servers and service providers located outside your country of residence, including countries outside Pakistan. Some of these jurisdictions may not provide the same level of data protection as the laws applicable in your country.

Where personal data is transferred internationally, he77 takes appropriate steps to ensure that adequate protections are in place, including reliance on approved standard contractual clauses, adequacy decisions or other legally recognised transfer mechanisms applicable under the operator's licensing jurisdiction's data protection framework.

By using the Platform and providing your personal data, you acknowledge that your data may be processed in jurisdictions outside Pakistan. he77 does not represent that international transfers of your data have been approved or sanctioned by any Pakistani authority.

he77 retains personal data for as long as necessary to fulfil the purposes for which it was collected, to comply with applicable legal and regulatory obligations, and to resolve disputes or enforce our agreements. The following general retention periods apply:

After the applicable retention period, personal data is securely deleted or anonymised. Anonymised data (which can no longer identify you) may be retained indefinitely for statistical and analytical purposes.

he77 uses cookies and similar tracking technologies to operate the Platform, maintain session security, analyse usage patterns and, where consented, deliver relevant communications. A cookie is a small text file stored on your device by your web browser.

10.1 Categories of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function — including session authentication, security tokens and load balancing. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Store user preferences such as language settings, accepted responsible gambling tool configurations and display preferences to improve your experience.
• Analytics Cookies: Collect aggregated data about how users navigate the Platform, which pages are visited most frequently and where users exit. This data helps us improve the Platform. Where consent is required, these cookies are only activated upon your agreement.
• Marketing Cookies: Used to deliver targeted promotional content based on your activity on the Platform. These are only activated where you have explicitly consented to marketing communications.

10.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the Platform. For strictly necessary cookies, no opt-out is available as they are essential to Platform operation.

The Platform is strictly intended for adults aged 18 years or above, or the higher minimum age required by the operator/license jurisdiction. he77 does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a person under the minimum eligible age, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the Platform or provided personal data to he77, please contact our support team immediately via the email address provided in Section 15.

Subject to the applicable data protection law of the operator's licensing jurisdiction and any overriding legal obligations, you have the following rights in respect of the personal data held about you by he77:

To exercise any of these rights, please contact he77 support using the contact details in Section 15. We will respond to valid requests within a reasonable period and in accordance with applicable law. Requests may require identity verification before they can be actioned. Where a request is refused, we will provide a written explanation.

he77 implements technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include, without limitation:

• Encryption of personal data in transit using TLS protocols and at rest using industry-standard encryption algorithms.
• Access controls restricting data access to authorised personnel on a strictly need-to-know basis.
• Regular security assessments and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative system access.
• Incident response procedures for identifying, containing and reporting data security incidents.

While he77 takes all reasonable precautions to protect personal data, no data transmission over the internet or electronic storage system is completely secure. Users are encouraged to maintain strong, unique passwords and enable two-factor authentication on their Accounts. If you suspect a security breach affecting your Account, please contact support immediately.

he77 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered users via the Platform or by email to the registered address on file. The date of the most recent review is displayed at the top of this page.

Continued use of the Platform following any amendment to this Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should stop using the Platform and may request Account closure in accordance with the Terms & Conditions. We encourage you to review this Policy periodically to remain informed of how your data is handled.

If you have any questions, concerns or requests relating to this Privacy Policy, the personal data we hold about you or your data rights, please contact he77 through the following channels:

• Live Chat: Available on the Platform — typically the fastest response channel for data rights requests.
• Help Centre: Self-service knowledge base and support ticket submission available on the Platform.
• Support Email (plain text — not a clickable link): [email protected]

Support is available in English as the primary language. Urdu-language assistance is available on request via Live Chat. he77 aims to acknowledge all data rights requests within 5 business days and to provide a substantive response within 30 days of receipt, in accordance with applicable data protection law requirements.