2777cb Privacy Policy — How We Handle Your Personal Data

This Privacy Policy ("Policy") sets out the data processing practices of 2777cb ("we," "us," or "our") in connection with the operation of the online casino and sportsbook platform accessible at 2777cb.asia and all associated subdomains, mobile-optimised interfaces, and services (collectively, the "Platform").

2777cb is committed to handling the personal data of all registered players — the overwhelming majority of whom are based in Pakistan — with transparency, integrity, and in full compliance with the obligations imposed by our international gaming license. This Policy should be read in conjunction with the 2777cb Terms & Conditions and Responsible Gaming Policy.

If you have any questions about how 2777cb handles your personal data that are not answered by this Policy, please contact our Data Privacy team at [email protected] before registering an Account or continuing to use the Platform.

For the purposes of applicable data protection law, 2777cb is the data controller in respect of the personal data collected and processed in connection with your use of the Platform. As data controller, 2777cb determines the purposes for which, and the means by which, your personal data is processed.

2777cb operates under an internationally recognised gaming license that imposes binding obligations in respect of data collection, retention, security, and Player rights — obligations that go beyond mere legal minimum standards and reflect a genuine commitment to data protection best practice. All data processing activities described in this Policy are conducted in accordance with those obligations.

Our designated data protection contact for all privacy-related inquiries is the 2777cb Privacy Team, reachable at [email protected] with the subject line "Privacy Inquiry." All formal data subject requests should be submitted to this address as detailed in Section 11 below.

2777cb collects only the personal data that is necessary for the purposes described in Section 5 of this Policy. The categories of personal data we process are as follows:

3.1 Registration and Identity Data

• Full legal name as it appears on your CNIC or passport
• Date of birth (for mandatory age verification — 21+ requirement)
• Email address (used as your primary login and communication channel)
• Pakistani mobile telephone number (for OTP authentication and account communications)
• Residential address in Pakistan
• Nationality and country of residence

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents: CNIC (Computerised National Identity Card), passport, or equivalent
• Proof of address documentation (e.g., utility bill, bank statement)
• Selfie or live photograph where required for enhanced verification
• Source of funds declaration where required by our AML obligations

3.3 Financial and Transaction Data

• JazzCash account number and associated mobile number
• EasyPaisa account number and associated mobile number
• HBL, UBL, or Meezan Bank account details (IBAN, account name) where used for deposits or withdrawals
• Complete deposit and withdrawal history including amounts in PKR, dates, methods, and statuses
• Cryptocurrency wallet addresses where USDT transactions are used

3.4 Gaming Activity Data

• Full bet history: game titles, wager amounts, outcomes, and settlement details
• Session data: login times, session duration, games accessed, and navigation patterns within the Platform
• Bonus usage: bonuses claimed, wagering progress, and expiry outcomes
• Responsible gaming tool settings: deposit limits, loss limits, and self-exclusion records

3.5 Technical and Device Data

• IP address at the time of each login and transaction
• Device type, operating system version, and browser type
• Mobile network information (carrier identification — Jazz, Telenor, Zong, Ufone, etc.)
• Cookie identifiers and session tokens (see Section 6)
• Geolocation data (country and region level) derived from IP address

3.6 Communication Data

• Records of all customer support interactions via live chat, email, and any other communication channel
• Complaint and dispute correspondence
• Feedback and survey responses where voluntarily submitted

2777cb collects personal data through the following channels:

• Direct submission: Information you provide during registration, KYC verification, deposit or withdrawal processing, customer support interactions, and when you update your Account settings.
• Automated collection: Technical data — including IP addresses, device identifiers, session data, and cookie information — collected automatically when you access and interact with the 2777cb Platform.
• Payment processor integration: Transaction reference data shared by JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank in connection with the processing of your deposits and withdrawals.
• Identity verification providers: Where 2777cb uses third-party KYC technology providers to verify documents submitted during the verification process, those providers may return enhanced identity data to 2777cb to assist in confirming authenticity.
• Fraud and risk screening tools: Automated systems that analyse patterns of usage data to detect potentially fraudulent, abusive, or money-laundering behaviour. These systems do not make final decisions about your Account — outputs are always reviewed by 2777cb personnel.

The table below sets out each purpose for which 2777cb processes personal data and the corresponding legal basis relied upon:

The 2777cb Platform uses cookies and similar tracking technologies to operate and improve the Platform, maintain your logged-in session, remember your preferences, and analyse usage patterns. Cookies are small data files stored on your device by your browser.

6.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without rendering the Platform non-functional.
• Functional Cookies: Remember your preferences such as language settings, device type, and game lobby display options. These persist between sessions to improve your experience.
• Analytics Cookies: Collect anonymised data about how you navigate the Platform — which pages are visited most, which games are played, how long sessions last. This data is aggregated and cannot identify you personally.
• Security and Fraud Prevention Cookies: Assist in detecting unusual account access patterns, preventing bot activity, and identifying potential fraud attempts. These are a core component of 2777cb's account protection infrastructure.

6.2 Cookie Management

You can control non-essential cookies through your browser settings. Most modern browsers — including Chrome, Firefox, and Safari on Android and iOS devices — allow you to view, block, and delete cookies from the browser settings menu. Please be aware that disabling functional or analytics cookies may degrade your experience on the 2777cb Platform. Disabling strictly necessary cookies will prevent login and Platform use entirely.

2777cb does not use third-party advertising cookies or permit third-party advertising networks to place tracking cookies on the 2777cb Platform without your explicit consent.

2777cb does not sell, rent, or commercially distribute your personal data to any third party. Your data is shared only in the following strictly defined circumstances:

7.1 Service Providers and Processors

2777cb engages third-party service providers who process personal data on our behalf and strictly under our instruction in connection with the following services:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and cryptocurrency processing infrastructure — necessary to process your PKR deposits and withdrawals.
• KYC and identity verification: Third-party document verification technology providers who assist in confirming the authenticity of your CNIC or passport submission.
• Game content providers: Software studios whose games appear on the 2777cb Platform may receive anonymised session and game-round data necessary for game functionality, jackpot participation, and RNG audit compliance. They do not receive your name, contact details, or payment information.
• Cloud infrastructure: Hosting and data centre providers who store Platform data under contractual data processing agreements meeting our security requirements.
• Customer support platforms: Live chat and helpdesk software providers who process interaction records on behalf of 2777cb.

All third-party processors are contractually bound to process your data only as instructed by 2777cb, to maintain appropriate technical security measures, and not to retain or further process your data for their own purposes.

7.2 Regulatory and Legal Disclosure

2777cb may disclose personal data to competent regulatory authorities, law enforcement agencies, financial intelligence units, or courts of law where such disclosure is required by applicable law, court order, or the obligations imposed under our international gaming license — including anti-money laundering and counter-terrorism financing reporting requirements. Such disclosures are made only to the extent required and with appropriate care.

7.3 Business Transfers

In the event that 2777cb undergoes a merger, acquisition, asset sale, or restructuring, personal data held by 2777cb may be transferred to the acquiring or successor entity as part of that transaction, subject to written commitments that the acquirer will honour the protections described in this Policy. You will be notified of any such transfer and any material change to how your data is processed as a result.

As an internationally operated platform, 2777cb may transfer personal data to countries outside of Pakistan in connection with cloud hosting, game content provider infrastructure, or third-party service provider operations. Not all such countries maintain data protection standards equivalent to Pakistani law or to the standards imposed by our gaming license.

Where personal data is transferred internationally, 2777cb ensures adequate protections are in place through one or more of the following mechanisms:

• Contractual data processing agreements incorporating internationally recognised standard contractual clauses for data transfers;
• Transfer only to jurisdictions or processors certified under recognised international data protection frameworks;
• Implementation of technical and organisational security measures that compensate for any reduced legal protections in the destination jurisdiction.

You may request information about the specific safeguards applicable to any particular international transfer by contacting 2777cb at [email protected].

2777cb retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulatory obligation. The following retention schedules apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Where complete deletion is not technically feasible within standard database architectures, data is pseudonymised and access is restricted to authorised personnel only, pending scheduled deletion cycles.

2777cb implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

10.1 Technical Security

• Transport Layer Security: All data transmitted between your device and the 2777cb Platform is encrypted using TLS 1.3 with AES-256 encryption — the same standard used by major Pakistani commercial banks for online banking portals.
• Password security: Account passwords are stored using bcrypt hashing with unique salts. 2777cb never stores plaintext passwords and cannot retrieve your password — only reset it.
• Two-factor authentication (2FA): Available to all Players and strongly recommended. Adds a secondary verification layer via SMS OTP or authenticator app for every login event.
• Access controls: Personal data is accessible internally only to authorised 2777cb personnel who have a documented need to access it in connection with their role. Access is logged and monitored.
• Database encryption: Sensitive data categories — including KYC documents and financial account numbers — are stored in encrypted form within 2777cb's database infrastructure.

10.2 Organisational Security

• Regular data protection training for all personnel who handle personal data
• Documented incident response procedures including breach notification protocols
• Regular penetration testing and security audits of Platform infrastructure
• Vendor security assessments for all third-party processors

Subject to applicable law and the limitations necessarily imposed by our gaming license and AML obligations, you have the following rights in respect of your personal data held by 2777cb:

• Right of Access: You may request a copy of all personal data 2777cb holds about you. We will respond to verified access requests within 30 calendar days.
• Right to Rectification: If personal data held by 2777cb is inaccurate or incomplete, you have the right to request correction. Most registration details can be updated directly from your Account settings; changes to identity-verified data require re-submission of KYC documentation.
• Right to Erasure: You may request deletion of your personal data in certain circumstances — for example, where it is no longer necessary for the purpose collected. This right is subject to legal retention obligations: 2777cb cannot delete financial and identity records before the mandatory regulatory retention periods described in Section 9 have elapsed.
• Right to Restriction: You may request that 2777cb restricts the processing of your data while a rectification request is pending, or while a complaint is being investigated.
• Right to Object: You may object to processing carried out on the basis of legitimate interests. 2777cb will assess whether its interests override your objection on a case-by-case basis.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Data Portability: Where technically feasible and legally permissible, you may request a structured, machine-readable copy of personal data you have provided to 2777cb.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Rights Request," including your full name, registered email address, and a clear description of the right you wish to exercise. We may request additional verification to confirm your identity before processing the request.

If 2777cb becomes aware — through KYC verification, customer support interaction, or any other means — that personal data has been collected from a person under the age of 21, we will take immediate steps to: (a) suspend the relevant Account; (b) securely delete all personal data associated with that Account to the extent permitted by our regulatory obligations; and (c) refund any Real Funds deposited to the original payment method, less any winnings derived from gaming activity during the ineligible period, which are forfeited.

Parents and guardians who believe their child has registered a 2777cb Account should contact us immediately at [email protected]. We will treat all such reports as priority cases and respond within 24 hours.

2777cb may send promotional communications — including information about bonuses, new games, PSL-related betting promotions, and Platform updates — to registered Players who have consented to receive such communications during the registration process or at any subsequent point.

You may opt out of marketing communications at any time through any of the following methods:

• Clicking the "Unsubscribe" link in any marketing email sent by 2777cb;
• Updating your notification preferences in your Account settings;
• Contacting 2777cb support via live chat or email and requesting removal from marketing communications.

Opt-out requests are processed within 5 business days. Please note that opting out of marketing communications does not affect service-related communications, which include: account security alerts, deposit and withdrawal confirmations, KYC verification requests, responsible gaming notifications, and material policy updates. These communications are part of the service and cannot be unsubscribed from while your Account remains active.

2777cb does not share your personal data with third-party advertising networks for the purpose of targeting you with advertisements on external websites or social media platforms.

The 2777cb Platform does not contain links to third-party websites for commercial or advertising purposes. In the event that any future feature of the Platform includes a link to a third-party resource — for example, a responsible gaming support organisation — 2777cb will clearly identify such links. However, once you navigate away from the 2777cb Platform, this Privacy Policy no longer applies. You access any third-party website at your own risk and subject to that site's own privacy terms.

2777cb is not responsible for the privacy practices, content, or security of any third-party website, even if that website is referenced in any 2777cb communication or support material.

2777cb reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing practices, or the features of the Platform. When material changes are made that affect your rights or how your data is handled, we will:

• Update the "Last Updated" date at the top of this Policy;
• Post a prominent notice on the 2777cb Platform for a minimum of 14 days following the change;
• Send a notification to your registered email address summarising the key changes.

Your continued use of the 2777cb Platform following notification of a material update constitutes acceptance of the revised Policy. If you do not agree to any update, you should cease using the Platform and may request Account closure in accordance with the 2777cb Terms & Conditions. Non-material changes — such as typographical corrections or restructuring for clarity — may be made without advance notice.

For all privacy-related queries, data subject requests, or concerns about how 2777cb handles your personal data, please contact our Privacy Team using the following details:

• Email: [email protected] — please use the subject line "Privacy Inquiry" or "Data Rights Request" as appropriate
• Live Chat: Available 24/7 on the 2777cb Platform in Urdu and English — for urgent privacy or security concerns, live chat ensures the fastest response

We aim to respond to all privacy inquiries within 48 hours and to complete formal data subject requests within 30 calendar days. If your request is complex or involves a large volume of data, we may extend this timeline by up to an additional 60 days, in which case we will notify you of the extension and the reasons for it.

If you are not satisfied with 2777cb's response to a privacy concern or data subject request, you have the right to escalate your complaint to the data protection authority relevant to your jurisdiction, or to the regulatory body overseeing 2777cb's international gaming license. Details of the licensing regulatory authority are available upon request.

Privacy Policy last reviewed and updated: 1 January 2026. Version 3.1. © 2026 2777cb. All rights reserved.