Privacy Policy – How ad77 Collects, Uses & Protects Your Personal Data

1 Definitions

In this Privacy Policy, the following terms shall carry the meanings assigned to them below:

• "ad77" / "Platform" / "We" / "Us" / "Our" — the online gaming and sports betting platform operated at ad77.bio and all associated sub-services, mobile interfaces, and support channels.
• "Player" / "You" / "User" — any individual who visits, registers on, or interacts with any feature of the ad77 platform.
• "Personal Data" — any information relating to an identified or identifiable natural person, including but not limited to name, CNIC number, mobile number, email address, postal address, payment method details, IP address, and gaming activity records.
• "Processing" — any operation performed on Personal Data, including collection, storage, use, disclosure, transfer, or deletion.
• "KYC" — Know Your Customer, the identity and age verification process conducted by ad77 using government-issued documents including the Pakistani Computerised National Identity Card (CNIC).
• "Licence" — the international gaming licence under which ad77 operates, which imposes specific obligations regarding the collection, processing, and protection of player data.
• "Third Party" — any entity other than ad77 or the Player, including payment processors, game software providers, analytics services, and regulatory authorities.

2 Data Controller Identity

2.1 For the purposes of this Privacy Policy, ad77 is the data controller responsible for the Personal Data collected through the ad77.bio platform. As data controller, ad77 determines the purposes and means of processing your Personal Data in accordance with our licensing obligations and this Policy.

2.2 All data protection queries, access requests, and complaints relating to the handling of your Personal Data by ad77 may be directed to our support team via the contact channels described in Section 16 of this Policy.

2.3 Where ad77 engages third-party service providers who process Personal Data on our behalf (for example, payment processors and KYC verification services), those providers act as data processors under written agreements that bind them to appropriate data protection standards consistent with our Licence requirements.

3 Categories of Personal Data We Collect

ad77 collects Personal Data through several channels: information you provide directly during registration and ongoing account use; data generated automatically as you use the platform; and information obtained from third parties for identity verification and fraud prevention purposes. The categories of data collected are set out in the table below.

4 How ad77 Uses Your Personal Data

4.1 Account Management: We use your Identity and Contact Data to create and maintain your ad77 account, verify your identity, send important account notifications, and enable you to access all platform features including the casino game lobby, sports betting, cashier, and responsible gaming tools.

4.2 Payment Processing: Your Financial Data is used to process deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, Visa/Mastercard, and USDT TRC20; to process withdrawal requests; to investigate transaction disputes; and to comply with anti-money laundering (AML) obligations imposed under our Licence.

4.3 Identity & Age Verification (KYC): Your Identity Data and KYC documents are used to confirm that you are who you claim to be, that you are 21 years of age or older, and that you are not a politically exposed person (PEP) or subject to international sanctions screening. This processing is a mandatory regulatory requirement.

4.4 Platform Improvement & Analytics: Technical Data and Gaming Activity Data are used in aggregate and anonymised form to monitor platform performance, identify technical issues, improve the user experience, and develop new features. Individual player profiles are not shared externally for analytics purposes.

4.5 Responsible Gaming: Gaming Activity Data and preference settings are used to monitor play patterns for indicators of problem gambling. Where patterns suggest a player may be at risk, ad77's responsible gaming team may proactively reach out. This processing is conducted in the player's legitimate interest and is a Licence requirement.

4.6 Fraud Prevention & Security: Technical Data and Financial Data are used to detect and prevent fraud, money laundering, account takeover attempts, bonus abuse, and prohibited conduct as defined in the ad77 Terms and Conditions.

4.7 Customer Support: Communications Data is used to resolve support queries, respond to complaints, and improve the quality of our support team's performance through quality assurance review of live chat transcripts (conducted by ad77 staff only).

4.8 Legal Compliance: We process Personal Data as necessary to comply with applicable laws, our Licence conditions, requests from regulatory authorities, and court orders. In some cases we are legally required to share certain data with authorities and cannot decline such requests.

5 Legal Basis for Processing

ad77 relies on the following lawful bases when processing your Personal Data:

• Contractual Necessity: Processing required to fulfil our obligations under the player account agreement — including account creation, payment processing, game delivery, and withdrawal processing.
• Legal Obligation: Processing required to comply with our gaming licence conditions, anti-money laundering laws, age verification requirements, and any lawful demand by regulatory or law enforcement authorities.
• Legitimate Interests: Processing for the purposes of fraud prevention, platform security, responsible gaming monitoring, and analytics — where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Where consent is required for specific processing activities (such as sending optional marketing communications), ad77 will request your explicit consent separately and provide a clear and easy mechanism to withdraw that consent at any time.

6 Disclosure & Sharing of Personal Data

6.1 ad77 does not sell, rent, or otherwise disclose your Personal Data to third parties for their own commercial purposes. Data sharing is limited to the following categories of recipients, and only to the extent strictly necessary for the stated purpose:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, Visa/Mastercard payment networks, and USDT TRC20 processing services receive the transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are bound by financial sector data protection standards.
• KYC & Identity Verification Services: Where ad77 engages a third-party KYC provider to assist with identity and age verification, your identity documents are shared with that provider under a data processing agreement that restricts their use of your data to the verification purpose only.
• Game Software Providers: Game session data (bet amounts, game outcomes, session identifiers) is shared with the game software providers (e.g., PG Soft, Pragmatic Play, Hacksaw Gaming) to the extent necessary for game operation, RNG auditing, and jackpot pool management. Your personally identifiable information is not shared with game providers beyond what is technically required for game delivery.
• Regulatory & Licensing Authorities: ad77 is required under its Licence to submit certain player data to its licensing regulator, particularly in relation to AML reporting, player complaint escalations, and regulatory audits. Such disclosures are made under legal obligation.
• Law Enforcement & Courts: ad77 will disclose Personal Data to law enforcement agencies, courts, or other governmental bodies where required by law, court order, or lawful regulatory request. We will notify you of such disclosures where legally permitted to do so.
• Professional Advisers: Legal counsel, auditors, and other professional advisers engaged by ad77 may have access to Personal Data on a need-to-know basis, subject to professional confidentiality obligations.

6.2 In all cases where ad77 shares Personal Data with third-party processors, we ensure that appropriate contractual safeguards are in place to protect your data and restrict its use to the specified purpose.

7 International Data Transfers

7.1 As an internationally licensed gaming platform, ad77 and some of its service providers (including game software developers and KYC providers) may operate servers or processing infrastructure in jurisdictions outside Pakistan. Your Personal Data may therefore be transferred to and processed in countries outside your country of residence.

7.2 Where such international transfers occur, ad77 takes appropriate measures to ensure that your Personal Data receives a level of protection that is equivalent to the protections applicable under our Licence. These measures may include contractual clauses, data processing agreements, and technical safeguards such as encryption in transit and at rest.

7.3 By using the ad77 platform and accepting this Privacy Policy, you acknowledge and consent to the transfer of your Personal Data to the servers and processors used by ad77 in the course of delivering the platform's services.

8 Data Retention Periods

8.1 ad77 retains Personal Data for no longer than is necessary for the purposes for which it was collected, subject to mandatory minimum retention periods imposed by our Licence and applicable law.

• Active Account Data: Retained for the duration of your active account with ad77, plus a minimum of five (5) years following account closure — in accordance with AML record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years following the date of verification or account closure, whichever is later, as required by anti-money laundering obligations under our Licence.
• Transaction Records: All deposit and withdrawal records are retained for a minimum of five (5) years for AML compliance and audit purposes.
• Gaming Activity Logs: Retained for a minimum of three (3) years following the date of the relevant session, for responsible gaming monitoring, dispute resolution, and regulatory reporting purposes.
• Customer Support Communications: Live chat transcripts and email correspondence are retained for a minimum of two (2) years for quality assurance and dispute resolution purposes.
• Technical Logs: Server logs and IP address data are retained for up to twelve (12) months for security, fraud detection, and platform stability purposes.

8.2 Following the applicable retention period, Personal Data is securely deleted or anonymised such that it can no longer be linked to any identified individual.

9 Cookies & Tracking Technologies

9.1 ad77 uses cookies and similar tracking technologies on the ad77.bio platform to provide core functionality, maintain session state, improve performance, and understand how Players use the platform. The categories of cookies used are:

• Strictly Necessary Cookies: Essential for the operation of the platform — including session authentication, maintaining your login state, and security functions. These cookies cannot be disabled without rendering core platform features non-functional.
• Functional Cookies: Remember your preferences such as display settings, language selections, and responsible gaming limits. These improve your experience but are not essential to basic platform operation.
• Analytics Cookies: Collect anonymised and aggregated information about how Players interact with ad77 — such as which pages are most visited and how long sessions last. This data helps us improve the platform. No individually identifiable data is collected via analytics cookies.
• Security Cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats. These may track device fingerprints and behavioural signals.

9.2 You may configure your browser to refuse cookies or to alert you when cookies are being set. However, disabling strictly necessary cookies will impair your ability to log in to and use the ad77 platform.

9.3 ad77 does not use cookies to serve third-party advertising or to track your behaviour across unaffiliated websites beyond the ad77.bio domain.

10 Your Data Rights

Subject to applicable law and the limitations imposed by our Licence obligations, you have the following rights in relation to your Personal Data held by ad77:

To exercise any of the above rights, contact the ad77 support team via live chat or at [email protected] (plain text — not a clickable link). We will acknowledge your request within 5 business days and provide a substantive response within 30 days. Complex or multiple requests may require up to an additional 60 days, in which case we will notify you of the extension.

11 Security Measures

11.1 ad77 implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• Encryption in Transit: All data transmitted between your browser/device and ad77 servers is encrypted using TLS 1.3 (256-bit SSL). The padlock icon in your browser's address bar confirms this encryption is active.
• Encryption at Rest: Sensitive data — including CNIC numbers, KYC documents, and payment credentials — is stored in encrypted form on ad77's servers. Encryption keys are managed separately from the encrypted data.
• Password Security: Player passwords are never stored in plain text. They are processed using industry-standard one-way cryptographic hashing algorithms. Even ad77's technical staff cannot retrieve your actual password.
• Two-Factor Authentication: ad77 supports optional 2FA for player accounts, providing an additional layer of login security beyond the password alone.
• Access Controls: Access to player Personal Data within ad77's systems is restricted on a strict need-to-know basis. Employee access logs are maintained and reviewed regularly.
• Penetration Testing: ad77's platform undergoes periodic security assessments to identify and remediate vulnerabilities before they can be exploited.

11.2 While ad77 implements robust security measures, no system is entirely immune to breach. In the event of a data security incident that is likely to result in a risk to your rights, ad77 will notify affected players as required by our Licence obligations and applicable law, and will take immediate remedial action.

12 Protection of Minors

12.1 The ad77 platform is strictly restricted to individuals aged 21 years and above. ad77 does not knowingly collect, store, or process Personal Data from persons under the age of 21.

12.2 Age verification is a mandatory step in the ad77 registration and KYC process. Any account found to belong to a person under 21 years of age will be immediately and permanently closed, all balances forfeited, and the matter reported to our licensing regulator as required.

12.3 If you believe that a person under 21 has registered on ad77 or that ad77 has inadvertently collected data from a minor, please contact us immediately at [email protected] (plain text — not a clickable link) so that we may investigate and take appropriate action, including deletion of the minor's data.

12.4 Parents and guardians of minors who are concerned about access to online gambling platforms are encouraged to use parental control software and to implement device-level access restrictions to prevent access to platforms such as ad77.

13 Third-Party Services & Links

13.1 The ad77 platform integrates third-party services for purposes including payment processing, game software delivery, KYC verification, and platform analytics. These third parties operate as data processors under contractual arrangements with ad77, and their processing of your data on our behalf is governed by the data protection terms of those arrangements.

13.2 ad77 is not responsible for the privacy practices of third parties acting as independent data controllers — for example, your mobile banking app (JazzCash, EasyPaisa) when you initiate a deposit. Your interactions with those services are governed by their own privacy policies, which we encourage you to review.

13.3 The ad77 platform does not contain links to external websites for commercial or navigational purposes beyond those necessary for platform operation. However, if any such links are present, clicking them will take you away from the ad77 platform and your activity on those external sites is not governed by this Privacy Policy.

14 Personal Data & Responsible Gaming

14.1 ad77 uses your Gaming Activity Data — including session lengths, bet frequency, deposit patterns, and loss progression — to proactively monitor for indicators of problem gambling as required by our Licence. This processing is in your legitimate interest and is a condition of our regulatory authorisation to operate.

14.2 Where ad77's monitoring identifies patterns consistent with problem gambling risk, our responsible gaming team may reach out to you via your registered contact (mobile number or email) to offer information about responsible gaming tools and support resources available on the platform.

14.3 Self-exclusion requests and responsible gaming limits you set within your account are stored and enforced as part of our regulatory obligations. Once a self-exclusion is active, your data is flagged to prevent re-registration attempts during the exclusion period. This processing is mandatory under our Licence and cannot be reversed at your request during the minimum exclusion period.

14.4 For more information about the responsible gaming tools available at ad77, please visit our Responsible Gaming page.

15 Changes to This Privacy Policy

15.1 ad77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, Licence requirements, applicable law, or platform functionality.

15.2 Material changes to this Policy will be communicated to registered Players via the email address on file or via an in-platform notification at least 14 days before the changes take effect. The "Last Reviewed" date at the top of this document will be updated to reflect the most recent version.

15.3 The current version of this Privacy Policy, as published at ad77.bio/privacy-policy, supersedes all previous versions. Continued use of the ad77 platform following the effective date of any amendment constitutes your acknowledgement of and consent to the updated Policy.

15.4 We encourage you to review this Privacy Policy periodically to stay informed about how ad77 protects your Personal Data.

16 Contact & Data Protection Queries

16.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your Personal Data by ad77, please contact us through the following channels:

• Live Chat: Available 24/7 on the ad77 platform — fastest response channel for general data queries and access requests.
• Email: [email protected] — for formal data subject access requests, erasure requests, and data protection complaints. Please mark your email subject line "Privacy Request" for priority routing.

16.2 ad77 aims to acknowledge all privacy-related communications within 5 business days and to provide a full substantive response within 30 days. For complex requests, we may require up to an additional 60 days, in which case we will notify you of the extension in writing.

16.3 If you are not satisfied with ad77's response to your data protection query or complaint, you may escalate the matter to the data protection supervisory authority relevant to ad77's licensing jurisdiction. Details of the applicable supervisory authority are available on request from our support team.