Privacy Policy — How 1777cx Handles Your Personal Data

Introduction

This Privacy Policy ("Policy") explains how 1777cx ("Platform", "we", "us", "our") collects, uses, discloses, stores and protects personal data obtained from users ("User", "you", "your") who access the 1777cx website at https://1777cx.cam and any associated services, applications or subdomains.

We are committed to protecting your privacy and handling your personal data with care, transparency and integrity. This Policy has been written to be clear and accessible — not buried in impenetrable legal language — so that Pakistani users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar can understand exactly what we do with their information.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform. By registering an Account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

Definitions

For the purposes of this Policy, the following terms have the meanings set out below:

Data Controller

1777cx operates as the Data Controller in respect of personal data collected through the Platform. As Data Controller, we are responsible for deciding how and why your personal data is processed.

Where third-party service providers are engaged to process data on our behalf — for example, payment processors, KYC verification providers or analytics platforms — they act as Data Processors under written agreements that restrict how they may use your data and require them to maintain appropriate security standards.

1777cx does not designate any Pakistani government body, financial institution or payment provider as a Data Controller or joint Data Controller in respect of this Platform. References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Platform are contextual references to payment methods familiar to Pakistani users and do not reflect a data-sharing or data-processing relationship with these institutions unless you initiate a transaction through such a provider, at which point their own privacy policies apply.

Data We Collect

We collect and process the following categories of personal data, depending on how you interact with the Platform:

4.1 Registration Data

When you create an Account, we collect: full name, date of birth, email address, country and city of residence, and a chosen username and password (stored in hashed form — we never store plain-text passwords).

4.2 Identity Verification (KYC) Data

To comply with our age verification and anti-money laundering ("AML") obligations, we may collect copies of government-issued identity documents. For Pakistani users, this typically means:

• A valid CNIC (Computerized National Identity Card) or unexpired Passport;
• Proof of address documentation where required;
• Selfie photographs or liveness-check images for biometric identity confirmation.

4.3 Financial Transaction Data

When you make deposits or withdrawals, we collect data necessary to process the transaction, including payment method type, transaction reference numbers, amounts and timestamps. We do not store full card numbers or sensitive authentication data beyond what is necessary and permitted under applicable payment security standards.

4.4 Betting & Gaming Activity Data

We collect records of bets placed, games played, markets accessed, deposit and withdrawal history, bonus claims and account balance movements. This data is used for account management, regulatory compliance, dispute resolution and responsible gambling monitoring.

4.5 Technical & Device Data

When you access the Platform, we automatically collect: IP address, browser type and version, operating system, device type, session duration, pages visited, referring URL and geolocation data derived from your IP address. This data helps us detect fraud, maintain platform security and improve performance.

4.6 Communication Data

If you contact our Support team via Live Chat, email or the Help Center, we retain records of those communications — including the content of messages — for quality assurance, dispute resolution and compliance purposes.

Lawful Basis for Processing

We process your personal data on one or more of the following lawful bases, as appropriate to the specific processing activity:

• Contractual Necessity: Processing required to create and operate your Account, process transactions and deliver Platform services as set out in the Terms & Conditions.
• Legal Obligation: Processing required to comply with applicable AML laws, age verification requirements, fraud prevention obligations and regulatory reporting duties.
• Legitimate Interests: Processing for fraud detection, platform security, service improvement and responsible gambling monitoring, where those interests are not overridden by your rights and freedoms.
• Consent: Where we rely on consent — for example, for non-essential marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• Creating, managing and securing your Account;
• Verifying your identity and age as part of the KYC process;
• Processing deposits, withdrawals and bonus credits;
• Delivering, maintaining and improving Platform features and services;
• Detecting, investigating and preventing fraud, money laundering and abuse of the Platform;
• Monitoring gambling activity for responsible gambling purposes, including triggering intervention where patterns suggest problem gambling;
• Communicating with you about your Account, Platform updates, promotions (where you have not opted out) and regulatory notices;
• Responding to Support requests and resolving disputes;
• Complying with applicable legal, regulatory and audit obligations;
• Conducting analytics to understand Platform usage and improve user experience.

Data Sharing with Third Parties

1777cx does not sell your personal data. We may share your data with the following categories of third party, strictly for the purposes described:

7.1 KYC & Identity Verification Providers

Third-party identity verification services process your KYC documents under contract with us. They are bound by data processing agreements prohibiting use of your data for any purpose other than verification on our behalf.

7.2 Payment Processors

Transaction data is shared with payment processing partners to complete deposits and withdrawals. Payment providers operate under their own regulatory frameworks and privacy policies. When you initiate a transaction via a payment provider (including any provider familiar to Pakistani users), that provider's own privacy terms apply to their handling of your financial data.

7.3 Fraud Prevention & AML Services

We may share limited data with specialist fraud prevention and AML screening services to fulfil our legal obligations. Such sharing is performed under strict contractual and legal constraints.

7.4 Analytics Providers

Anonymised or pseudonymised usage data may be shared with analytics providers to help us understand platform performance. This data does not identify you personally.

7.5 Legal & Regulatory Disclosure

We may disclose personal data to law enforcement agencies, regulatory authorities, courts or other public bodies where required by law, court order or regulatory obligation — including in connection with AML investigations or legal proceedings.

7.6 Business Transfers

In the event of a merger, acquisition, restructuring or sale of the Platform, personal data held by 1777cx may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

International Data Transfers

The Platform operates internationally and your personal data may be transferred to, and stored or processed in, countries other than your country of residence — including countries where data protection laws may differ from those applicable in Pakistan.

Where personal data is transferred internationally, we take appropriate measures to ensure that such transfers comply with applicable data protection requirements and that your data receives a level of protection consistent with this Policy. Such measures may include contractual clauses, data processing agreements or other legally recognised safeguards.

By using the Platform, you acknowledge that your data may be transferred and processed in jurisdictions outside Pakistan in connection with the operation of Platform services.

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable legal and regulatory obligations, whichever period is longer.

General retention principles:

• Active Account Data: Retained for the duration of the Account and for a defined period following Account closure, to meet regulatory requirements.
• KYC & AML Records: Typically retained for a minimum of five (5) years from the date of the last transaction, in accordance with common AML regulatory requirements. Actual retention periods are governed by the laws of the Platform's licence jurisdiction.
• Transaction Records: Retained for the period required by the applicable financial regulations in the Platform's licence jurisdiction.
• Communication Records: Support communications are retained for dispute resolution and audit purposes, typically for a period of two (2) to five (5) years.
• Anonymised Analytics Data: May be retained indefinitely once stripped of personal identifiers.

When data is no longer required and no legal obligation mandates its retention, we delete or irreversibly anonymise it.

Cookies & Tracking Technologies

The Platform uses cookies and similar tracking technologies to operate core functionality, analyse usage and improve the user experience. The following types of cookies may be used:

• Essential Cookies: Required for the Platform to function. These include session management cookies that keep you logged in and security tokens that protect your Account. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect anonymised or pseudonymised data about how users navigate the Platform — pages visited, session durations, device types. This helps us improve the Platform for Pakistani users and all others.
• Functional Cookies: Store your preferences, such as language settings and display options, to personalise your experience.
• Security Cookies: Help detect and prevent fraudulent account activity and unauthorised access attempts.

You may manage your cookie preferences through your browser settings. Note that disabling non-essential cookies will not affect your core account functionality, but may limit certain personalisation features.

Security Measures

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/SSL Encryption: All data in transit between your browser and the Platform is encrypted. Look for the padlock icon in your browser address bar.
• Encrypted Storage: KYC documents and sensitive personal data are stored using encryption at rest.
• Access Controls: Access to personal data within the Platform is restricted to personnel who require it for their role, under a principle of least privilege.
• Password Security: Passwords are stored in hashed, salted form. We do not have access to your plain-text password and will never ask for it via email, chat or phone.
• Fraud & AML Monitoring: Automated and manual controls monitor for suspicious activity patterns on an ongoing basis.
• Secure KYC Portal: Identity documents must be submitted exclusively through the Platform's HTTPS-secured upload portal — not via email or unsecured messaging.

While we take these measures seriously, no internet-based system can be guaranteed to be 100% secure. In the event of a data security incident that poses a risk to your rights, we will take prompt action and notify affected users as required by applicable law.

Your Data Rights

Depending on the data protection laws applicable in your jurisdiction, you may have some or all of the following rights in respect of your personal data. To exercise any of these rights, please contact us via the Help Center or Support email.

Minors — Protection of Children's Data

The Platform is strictly not available to persons under the age of 18, or the higher minimum age required by the operator's licence jurisdiction. We do not knowingly collect or process the personal data of minors.

Age is verified as part of the KYC process. Where the Platform becomes aware that a minor has registered an Account — whether through KYC verification, parental complaint or any other means — the Account will be closed immediately, all balances will be handled in accordance with the Platform's minor account policy, and the relevant personal data will be securely deleted or retained only to the extent required by law.

If you believe a minor has accessed the Platform or provided personal data, please contact Support immediately so that we can take appropriate action.

Specific Notes for Pakistani Users

1777cx operates as an English-language platform specifically designed to serve users across Pakistan, including in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We recognise that Pakistani data protection law is at an evolving stage, and we are committed to transparency about how your data is handled.

14.1 CNIC Data

A CNIC (Computerized National Identity Card) is a sensitive Pakistani identity document. Where you submit your CNIC for KYC purposes, it is processed exclusively for age verification, identity confirmation and AML compliance. It is stored in encrypted form and is not used for any other purpose. CNIC data is never transmitted through email or unsecured channels.

14.2 Payment References

References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on the Platform are provided as familiar payment context for Pakistani users only. They do not reflect a data-sharing relationship. When you initiate a payment through any third-party provider, that provider's own privacy policy governs their handling of your transaction data.

14.3 No Pakistani Government Data Sharing

1777cx does not share your personal data with any Pakistani government body, financial regulator, or the State Bank of Pakistan as part of routine Platform operations. Disclosure to any authority would only occur where required by a valid legal order from a competent jurisdiction.

Changes to This Privacy Policy

We reserve the right to update or amend this Privacy Policy at any time. The effective date of the current version is displayed at the top of this page. Where a material change is made, we will take reasonable steps to notify registered users — for example, via a notice on the Platform or an email to the address registered to your Account.

Your continued use of the Platform after the effective date of any update constitutes your acceptance of the revised Policy. If you do not agree with any change, you should stop using the Platform and may close your Account in accordance with the Terms & Conditions.

We encourage you to review this Policy periodically to stay informed about how your data is being protected and used.

Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact our Support team via the Help Center on the Platform.

Our Support team operates in English. Urdu-language assistance is available on request for Pakistani users who prefer to communicate in Urdu.

For responsible gambling enquiries, self-exclusion requests or account restriction tools, please visit our Responsible Gambling page or contact Support directly.

To review the full terms governing your use of the Platform, including account rules, bonus conditions and payment policies, please read our Terms & Conditions.