td77 Privacy
Policy

td77 ("we", "us", "our", or "the Platform") is committed to protecting the privacy of every individual who interacts with our services at td77.site. This Privacy Policy sets out in plain, legally precise terms how td77 handles the personal data of all users — including registered Pakistani players, site visitors, and any person who communicates with td77 through any support channel.

This Policy applies to all personal data processed by td77 in connection with the operation of the Platform — including data collected through the website, account registration, deposit and withdrawal transactions, betting and gaming activity, customer support interactions, promotional communications, and responsible gaming processes.

td77 acts as the data controller in respect of all personal data collected and processed pursuant to this Policy. We process personal data in compliance with applicable data protection principles — including collection for specified, legitimate purposes; data minimisation; storage limitation; accuracy; integrity and confidentiality; and accountability.

td77 collects the following categories of personal data from users of the Platform:

td77 does not collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) except where such data is voluntarily disclosed by the user in a support or responsible gaming context, in which case it is processed solely for the purpose for which it was shared.

td77 collects personal data through the following means:

• Direct Collection: Data you provide directly during account registration, KYC verification, deposit and withdrawal requests, support communications, promotional opt-ins, or responsible gaming tool setup.
• Automated Collection: Technical and usage data collected automatically by td77's systems when you access the Platform — including IP addresses, device identifiers, session logs, game activity records, and page interaction data. This collection occurs through server logs, cookies, and similar tracking technologies described in Section 10.
• Third-Party Sources: Identity verification and fraud screening data received from KYC and anti-money laundering (AML) service providers where you have been directed through a verification process. Payment data received from payment processing partners (JazzCash, EasyPaisa, bank payment gateways) confirming transaction status. td77 does not purchase personal data from data brokers or marketing data aggregators.
• Inferred Data: Behavioural inferences drawn from your gaming activity and browsing patterns on the Platform, used exclusively to personalise your experience and to support responsible gaming monitoring obligations.

td77 processes your personal data for the following specific, documented purposes:

• Account Management: Creating and maintaining your td77 account; authenticating your identity at login; managing account security settings and two-factor authentication.
• Payment Processing: Processing PKR deposits and withdrawals via your chosen payment method (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, SadaPay, USDT TRC20); maintaining accurate transaction records.
• Regulatory Compliance: Fulfilling our KYC obligations; conducting AML checks; verifying player age (21+ minimum) and identity; maintaining records required by our gaming licence; fulfilling any reporting obligations to regulatory authorities.
• Service Delivery: Providing access to casino games, sportsbook markets (including PSL cricket, American football, UFC), live dealer tables, and all other Platform features; personalising game recommendations and promotional offers based on your activity history.
• Fraud Prevention and Security: Detecting and preventing unauthorised account access, bonus abuse, match-fixing involvement, money laundering, and other forms of financial crime or Platform misuse.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling indicators; enforcing self-imposed limits and exclusions; communicating with players where responsible gaming concerns are identified.
• Customer Support: Responding to your enquiries, complaints, and requests through live chat, email, and other support channels; maintaining records of support interactions.
• Marketing Communications: Sending promotional emails, bonus notifications, and relevant Platform updates where you have consented to receive such communications. You may withdraw marketing consent at any time by updating your notification preferences within your Account settings.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform performance, game selection, and user experience across Pakistani devices and network conditions.

td77 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil the agreement between you and td77 — including account operation, payment processing, and game delivery — is conducted on the basis that it is necessary to perform the contract you entered when registering your Account.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements — including KYC, AML, age verification (21+), and licensing obligations — is conducted on the basis of legal obligation.
• Legitimate Interests: Processing for fraud prevention, platform security, technical data analysis, and responsible gaming monitoring is conducted on the basis of td77's legitimate interest in operating a safe, secure, and sustainable Platform, provided such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and optional analytics is conducted on the basis of your freely given, informed, and specific consent. Where consent is the legal basis, you retain the right to withdraw it at any time without affecting the lawfulness of prior processing.

td77 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following specific, necessary circumstances:

• Payment Service Providers: Financial data is shared with your chosen payment processor (JazzCash, EasyPaisa, banking gateway partners) exclusively to facilitate the processing of your deposits and withdrawals. These providers are contractually bound to data protection standards consistent with this Policy.
• KYC and AML Partners: Identity data and documentation may be shared with third-party identity verification and anti-money laundering screening services to fulfil our regulatory obligations. These providers act as data processors under instructions from td77.
• Gaming Technology Providers: Aggregated or session-level gaming activity data may be shared with licensed game providers (software studios) for the purpose of settling game outcomes and resolving technical disputes. Personal identity data is not shared with game providers.
• Regulatory Authorities: In compliance with our gaming licence and applicable law, td77 may be required to disclose player data to regulatory authorities, law enforcement agencies, or financial intelligence units. Such disclosures will be made only where legally required and will not exceed what is necessary.
• Professional Advisers: Legal, financial, or compliance advisers engaged by td77 may access limited personal data on a need-to-know basis, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of td77's business, personal data may be transferred to the successor entity, subject to the same privacy protections as those set out in this Policy. Users will be notified of any such transfer and the applicable privacy implications.

As an internationally operated online gaming platform, some personal data processing by td77 or its third-party service providers may involve the transfer of data outside Pakistan. Where such transfers occur, td77 takes the following steps to ensure your data remains protected:

• Transfers occur only to jurisdictions or service providers that maintain data protection standards consistent with international best practice, including standards equivalent to or exceeding GDPR principles;
• Where third-party processors are engaged outside Pakistan, td77 enters into contractual data processing agreements that impose binding data protection obligations on those processors;
• Transfers for KYC and AML purposes are limited to providers operating under recognised international compliance frameworks;
• No transfer of your personal data occurs for the purpose of avoiding Pakistani regulatory obligations.

If you wish to understand more about the safeguards applied to any specific international transfer of your personal data, you may contact td77's data privacy team using the contact details in Section 15.

td77 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable regulatory and legal obligations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with td77's data destruction procedures. Anonymised data (which can no longer be linked to any individual) may be retained indefinitely for aggregated statistical and analytical purposes.

td77 implements a comprehensive, layered security framework to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the td77 Platform is protected by 256-bit SSL/TLS encryption — the same standard used by international banking institutions.
• Encryption at Rest: Sensitive personal data stored on td77 servers, including identity documents and financial records, is encrypted at rest using industry-standard cryptographic algorithms.
• Password Security: Account passwords are never stored in plain text. td77 applies bcrypt hashing with appropriate salting, ensuring that passwords cannot be reconstructed even in the unlikely event of a storage compromise.
• Access Controls: Personal data is accessible only to td77 staff who require it for a specific, documented operational purpose. Access is controlled through role-based permissions and audit-logged.
• Two-Factor Authentication: td77 offers and strongly recommends two-factor authentication (2FA) via OTP for all player accounts, adding an additional layer of protection against unauthorised login.
• Penetration Testing: td77's systems are subject to regular security assessments, including vulnerability scanning and penetration testing, conducted by qualified security professionals.
• Incident Response: td77 maintains a documented data breach response procedure. In the event of a breach affecting your personal data, you will be notified in accordance with applicable regulatory requirements.

td77 uses cookies and similar technologies on the Platform to support essential functionality, improve user experience, and fulfil security obligations. The following types of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function — including session management, login authentication, and security token handling. These cookies cannot be disabled without affecting core functionality. No consent is required for this category.
• Functional Cookies: Store your preferences — including language settings, displayed currency (PKR), and responsible gaming notification configurations — so these are maintained across sessions.
• Analytics Cookies: Used to collect aggregated data about Platform usage — including pages visited, game categories browsed, and session durations — to help td77 improve performance for Pakistani users. These cookies are deployed only where you have provided consent.
• Security Cookies: Used to detect and prevent fraudulent access attempts, manage rate limiting, and support our bot-detection systems. These cookies are strictly necessary and cannot be disabled.

td77 does not deploy third-party advertising cookies or allow external advertising networks to place tracking pixels on the Platform. You can manage your cookie preferences through the cookie settings interface accessible from the Platform footer, or via your browser settings. Please note that disabling certain cookies may affect the functionality of some Platform features.

td77 respects your rights over your personal data. As a user of the Platform, you hold the following rights, all of which can be exercised by contacting td77 via the channels in Section 15:

td77 will respond to all rights requests within 30 calendar days of receipt. Where the complexity or volume of requests requires additional time, we will notify you within the initial 30-day period and provide a revised completion timeline, which will not exceed 90 days in total.

td77's services are strictly restricted to individuals who are 21 years of age or older. We do not knowingly collect personal data from any individual under the age of 21. This minimum age requirement is strictly enforced through CNIC verification during the KYC process and through our ongoing responsible gaming monitoring programme.

If td77 becomes aware that personal data has been collected from an individual below the minimum age requirement, the Account will be immediately suspended, all associated data will be reviewed under our regulatory obligations, and appropriate steps will be taken to delete personal data where no legal retention obligation applies.

If you believe that td77 has inadvertently collected data relating to a person under 21, please contact us immediately using the details in Section 15. We take such reports extremely seriously and will investigate and respond promptly.

td77 processes gaming activity data as part of our responsible gaming obligations. This includes monitoring session patterns, betting frequency, deposit behaviours, and win/loss volatility indicators that may suggest a player is experiencing gambling-related difficulties.

Where such monitoring identifies a potential concern, td77 may proactively reach out to the player concerned via their registered contact details — mobile number or email — to offer information about responsible gaming resources and available self-management tools. This processing is conducted on the basis of both legal obligation (responsible gaming requirements under our gaming licence) and td77's legitimate interest in player welfare.

Responsible gaming records — including self-exclusion elections, cooling-off periods, deposit limit configurations, and any welfare-related communications — are retained permanently as required by our regulatory obligations and to prevent circumvention of player protection measures through Account re-registration. This means that even if you close your td77 Account, a self-exclusion record will be maintained.

For more information about td77's responsible gaming programme and the tools available to you, please visit our Responsible Gaming page.

td77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable regulatory requirements, or operational context. When material changes are made, td77 will notify registered users via email to their registered address and/or via a prominent notice on the Platform prior to the changes taking effect.

The revised Policy will be published at this URL (td77.site/privacy-policy) with an updated Effective Date and Version number. Your continued use of td77 following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

We recommend reviewing this Privacy Policy at least every six months. If you have concerns about any changes made to this Policy, please contact our data privacy team before continuing to use the Platform.

For all privacy-related enquiries, data subject rights requests, or concerns regarding this Privacy Policy, please contact td77 using the following channels:

• Email: [email protected] — please include "Privacy Request" in the subject line to ensure prompt routing to the data privacy team.
• Live Chat: 24/7 live chat is available from the td77 Platform once logged in. For data subject rights matters, live chat agents can initiate the formal request process on your behalf.
• Response Commitment: td77 commits to acknowledging all privacy-related contacts within 3 business days and providing a substantive response or resolution within 30 calendar days.

When submitting a data subject rights request, please provide your registered td77 username and mobile number to allow our team to locate your Account record promptly. We may request additional identity verification before processing certain requests to protect against unauthorised access to another person's data.