Privacy Policy — 777hd Online Gaming Platform

777hd ("we", "us", "our" or "the Platform") is an English-language online gaming information platform serving Pakistani users and others who access the website at https://777hd.cam. We are committed to handling your personal data responsibly, transparently and in accordance with applicable data protection principles.

This Privacy Policy describes the categories of personal data we collect when you visit or use the Platform, the purposes for which that data is processed, the basis on which we rely to do so, and the rights available to you in relation to your personal information. It also explains how we use cookies and similar technologies, how long we retain your data, and how you may contact us with questions or requests.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our data practices as described here, please do not use the Platform. This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the Platform more broadly.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers and usage data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 777hd in its capacity as operator of the Platform.
• "Data Processor" means any third party that processes Personal Data on behalf of and under the instructions of the Data Controller.
• "User", "you" or "your" means any individual who accesses the Platform, whether registered or browsing anonymously.
• "Cookies" means small text files placed on your device by a website to store preference or session data, as further described in Section 9.
• "Operator" means the underlying gaming or gambling service provider associated with this Platform, which operates as a separate legal entity with its own privacy practices.

We collect personal data in two principal ways: data you provide to us directly and data we collect automatically when you interact with the Platform. The categories of data we may collect are set out in the table below.

• 3.1 We do not knowingly collect Special Category Data (such as health data, religious beliefs or biometric data) through the Platform. If such data is incidentally shared with us, we will delete it promptly.
• 3.2 We do not collect payment card numbers, bank account details or mobile wallet credentials (such as Easypaisa or JazzCash account numbers) directly. All financial transactions are handled by the Operator's payment infrastructure.
• 3.3 Where you provide data relating to third parties (for example, a referral), you confirm that you have that person's consent to share their information with us for the stated purpose.

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

• 4.1 Platform Operation: To deliver, maintain and improve the functionality of the Platform, including presenting content accurately, managing user accounts and providing technical support.
• 4.2 User Communication: To respond to your enquiries, provide customer support and send service-related notices (such as changes to this Privacy Policy or the Terms & Conditions).
• 4.3 Security & Fraud Prevention: To detect, investigate and prevent fraudulent activity, unauthorised access and other conduct that may violate our Terms & Conditions or applicable law.
• 4.4 Legal Compliance: To meet our obligations under applicable law and to cooperate with regulatory or law enforcement authorities where required.
• 4.5 Analytics & Improvement: To understand how users interact with the Platform in aggregate, identify areas for improvement and measure the effectiveness of content updates. This analysis is conducted on anonymised or pseudonymised data wherever possible.
• 4.6 Responsible Gambling Monitoring: To identify usage patterns that may indicate problem gambling behaviour, enabling us to direct users to our Responsible Gambling resources or support tools provided by the Operator.

We rely on the following legal bases to process your personal data, consistent with internationally recognised data protection principles:

• 5.1 Contractual Necessity: Processing is necessary to perform our obligations to you under the Terms & Conditions, such as providing access to Platform content and maintaining your account.
• 5.2 Legitimate Interests: Processing is necessary for our legitimate business interests — including platform security, fraud prevention and aggregate analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• 5.3 Legal Obligation: Processing is necessary to comply with a legal obligation, such as responding to a valid court order or regulatory request from a competent authority.
• 5.4 Consent: Where we rely on your consent (for example, for non-essential cookies or optional marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. To withdraw consent, contact us at the email address set out in Section 14.

• 6.1 We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include encrypted data storage, access controls and regular security reviews.
• 6.2 Access to personal data within our organisation is restricted to individuals who require it to perform their job functions, and all such individuals are bound by confidentiality obligations.
• 6.3 No method of data transmission over the internet or electronic storage is 100% secure. While we use commercially reasonable measures to protect your data, we cannot guarantee absolute security. In the event of a data breach that poses a risk to your rights, we will notify you as required by applicable law.
• 6.4 You are responsible for keeping your account credentials confidential. If you suspect that your account has been compromised, please contact us immediately at the address provided in Section 14.

We do not sell, rent or trade your personal data. We may share your data with third parties only in the limited circumstances described below:

• 7.1 Service Providers: We may share data with trusted third-party vendors who assist in the operation of the Platform, such as hosting providers, analytics platforms and customer support tools. These vendors act as Data Processors under contractual terms that prohibit them from using your data for any purpose other than providing the contracted service.
• 7.2 The Operator: Where you access the Operator's gaming platform via 777hd, limited data may be shared with the Operator to facilitate your registration or account linkage. The Operator maintains its own privacy policy which governs its use of that data.
• 7.3 Legal & Regulatory Compliance: We may disclose personal data to law enforcement agencies, courts or regulatory authorities where required to do so by law, court order or to protect the rights, property or safety of 777hd, our users or the public.
• 7.4 Business Transfers: In the event of a merger, acquisition, restructuring or sale of all or part of our business, your personal data may be transferred to a successor entity, subject to the same level of privacy protection as described in this policy.
• 7.5 We will never share your data with any Pakistani financial institution — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — in connection with gambling operations, and we do not engage with these providers directly in relation to user data.

Depending on your jurisdiction and applicable law, you may have some or all of the following rights in relation to your personal data. We will respond to any valid request within a reasonable timeframe, and no later than 30 days from receipt unless the complexity of your request requires an extension (in which case we will notify you).

• 8.1 Right of Access: You may request a copy of the personal data we hold about you, together with information about how it is processed.
• 8.2 Right to Rectification: You may ask us to correct any inaccurate or incomplete personal data we hold about you.
• 8.3 Right to Erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where processing is unlawful. This right is subject to certain legal exceptions, such as where we are required to retain data by law.
• 8.4 Right to Restrict Processing: You may ask us to suspend processing of your data in certain circumstances, for example while we investigate a dispute about its accuracy.
• 8.5 Right to Data Portability: Where processing is based on your consent or on a contract, you may request that we provide your data in a structured, commonly used and machine-readable format.
• 8.6 Right to Object: You may object to processing of your data where we rely on legitimate interests as our legal basis, including for direct marketing purposes.
• 8.7 Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

The Platform uses cookies and similar technologies (such as web beacons and local storage) to support core functionality and improve user experience. The categories of cookies we use are described below.

• 9.1 You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies and set preferences for specific websites. Note that disabling certain cookies may affect the functionality of the Platform.
• 9.2 We do not use advertising or targeting cookies to serve you personalised gambling advertisements on other websites.
• 9.3 Third-party analytics providers we use may set their own cookies subject to their respective privacy policies. We do not grant these providers access to your personally identifiable information.

• 10.1 We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulatory obligation.
• 10.2 Account data is generally retained for the duration of your active relationship with the Platform and for a reasonable period thereafter to handle any outstanding queries, disputes or legal obligations.
• 10.3 Technical and usage data collected via cookies and server logs is typically retained in identifiable form for no longer than 13 months, after which it is anonymised or deleted.
• 10.4 Communications data (such as support emails) is retained for as long as necessary to resolve the matter to which it relates, plus a reasonable additional period for audit and compliance purposes.
• 10.5 When personal data is no longer required, we ensure it is securely deleted or anonymised in accordance with our internal data lifecycle procedures.

11.1 The Platform may be operated using infrastructure located outside of Pakistan. As a result, your personal data may be transferred to, stored in or processed in countries other than your country of residence, including countries that may not offer the same level of data protection as Pakistan.

11.2 Where such transfers occur, we take appropriate steps to ensure that your data receives adequate protection, including by implementing contractual safeguards with our service providers and by relying on internationally recognised data transfer mechanisms where applicable.

11.3 By using the Platform, you acknowledge that your data may be transferred internationally as described in this section, subject to the protections outlined above.

• 12.1 If we become aware that we have inadvertently collected personal data from a person under the applicable minimum age, we will take immediate steps to delete that data from our systems.
• 12.2 If you are a parent or guardian and believe that your child has provided personal data to us, please contact us immediately at the address set out in Section 14 so that we can investigate and take appropriate action.
• 12.3 We support age-verification measures implemented by the Operator and encourage parents and guardians to make use of parental control software to restrict access to gambling-related content.

13.1 We may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements or platform features. The date of the most recent revision is displayed at the top of this page.

13.2 Where a change is material, we will make reasonable efforts to notify you — for example, by posting a prominent notice on the Platform or by contacting you at the email address associated with your account. Your continued use of the Platform following any update constitutes your acceptance of the revised policy.

13.3 We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

If you have any questions, concerns or requests relating to this Privacy Policy or our handling of your personal data, please contact our support team. We take all privacy enquiries seriously and will respond within a reasonable timeframe.