no77 Privacy Policy
— How We Collect, Use & Protect Your Personal Data

01Who We Are

This Privacy Policy is issued by the entity operating the no77 online gaming platform, accessible at no77.bio ("no77", "we", "us", "our"). no77 operates as an internationally licensed online gaming platform, offering sports betting, cricket markets, live dealer casino, slot games, crash games, and a structured Loyalty Program to registered players, with a primary focus on Pakistani players accessing the platform using PKR-denominated accounts and local payment methods including JazzCash and EasyPaisa.

For the purposes of this Privacy Policy, no77 acts as the data controller in respect of all personal data submitted by players during registration, account operation, KYC verification, payment processing, and general use of the platform. As data controller, no77 is responsible for determining the purposes and means by which your personal data is processed.

By creating a no77 account or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data in the manner described herein, in conjunction with the Terms & Conditions which govern your overall use of the platform.

02Data We Collect

no77 collects personal data across several categories depending on how you interact with the platform. The following table outlines the categories of data collected, the specific data points within each category, and the context in which they are collected:

Data You Do Not Provide Directly

In addition to data you actively submit, no77 automatically collects certain technical and behavioural data through your use of the platform. This includes server logs recording your IP address, time of access, pages visited, and bet activity. This data is collected to ensure platform integrity, detect fraud, and comply with no77's licensing obligations — it is not used to build commercial marketing profiles.

03How We Use Your Data

no77 processes personal data for the following purposes, each governed by an appropriate legal basis as described in Section 4:

3.1 Account Creation and Management
Your identity, contact, and preference data are used to create and maintain your no77 account, verify your login credentials, manage your PKR wallet, and enable personalisation of the platform experience within your account dashboard.

3.2 Payment Processing
Financial data including JazzCash and EasyPaisa account references, deposit amounts, and withdrawal requests are processed solely for the purpose of facilitating your financial transactions on the platform. No77 does not store complete payment credentials; transaction references and histories are retained for audit and dispute resolution purposes.

3.3 KYC and Identity Verification
Identity and KYC document data is processed to verify your age (21+ requirement), confirm your identity in connection with withdrawal requests above applicable thresholds, and comply with anti-money laundering obligations under no77's international licensing framework.

3.4 Fraud Prevention and Security
Technical and gaming activity data is analysed to detect and prevent multi-accounting, bonus abuse, money laundering, match-fixing participation, automated betting (bot activity), and other prohibited conduct as defined in the Terms & Conditions. Fraud prevention is a legitimate interest of no77 and a condition of our operating licence.

3.5 Responsible Gaming Monitoring
Gaming activity and pattern data is monitored to identify indicators of problem gambling behaviour. Where such indicators are detected, no77 may proactively contact you with responsible gaming resources or, in cases of significant concern, may implement protective account restrictions. See Section 12 for further detail.

3.6 Customer Support
Communications data including live chat transcripts and email correspondence is retained to provide effective support, maintain a record of dispute interactions, and ensure consistency of service across your support history with no77.

3.7 Marketing Communications
Where you have opted in to receive marketing communications from no77, your contact data and preference data will be used to send you relevant promotional communications including bonus offers, new game announcements, and PSL-related betting promotions. You may withdraw marketing consent at any time by contacting support or adjusting account preferences. Withdrawal of marketing consent does not affect your account functionality.

3.8 Legal and Regulatory Compliance
no77 processes personal data as required to comply with its obligations under the terms of its international online gaming licence, anti-money laundering regulations, and any lawful requests from regulatory authorities or law enforcement bodies with jurisdiction over no77's operations.

04Legal Basis for Processing

no77 processes your personal data on the following legal grounds, in accordance with internationally recognised data protection principles:

• Contractual Necessity: Processing required to fulfil the contract established when you accept these Terms — including account management, payment processing, and delivery of gaming services.
• Legal Obligation: Processing required to comply with no77's international licensing conditions, anti-money laundering obligations, and lawful requests from authorised regulatory or law enforcement bodies — including KYC verification and transaction record-keeping.
• Legitimate Interests: Processing that serves no77's legitimate operational interests where those interests are not overridden by your fundamental rights — including fraud detection, security monitoring, responsible gaming analysis, and platform improvement analytics.
• Consent: Processing based on your freely given, specific, and informed consent — applicable to marketing communications and any data processing not covered by the bases above. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

05Data Sharing & Disclosure

no77 does not sell, rent, or commercially trade personal data. Data is shared only in the following limited circumstances:

• Payment Processors: Financial data necessary to process JazzCash, EasyPaisa, HBL, UBL, SadaPay, and other payment transactions is shared with the relevant payment processing partners. These processors are engaged under contractual data processing agreements and are not permitted to use your data beyond the scope of transaction processing.
• Identity Verification Providers: KYC document data may be processed by authorised third-party identity verification service providers acting as data processors under contract with no77. These providers verify document authenticity and identity matching only.
• Game Software Providers: Certain technical and gaming session data may be shared with licensed game providers (e.g., live casino studio operators) to the extent necessary to deliver and audit game outcomes. Game providers are subject to their own certification body requirements regarding data handling.
• Regulatory Authorities and Law Enforcement: no77 will disclose personal data to its licensing authority, relevant regulatory bodies, or law enforcement agencies where required to do so by law, court order, or under the terms of its operating licence. No77 will not disclose data to law enforcement on a voluntary basis beyond what is legally required.
• Fraud Prevention Networks: Where fraud or money laundering is confirmed or strongly suspected, limited identifying data may be shared within industry fraud prevention networks to protect the broader gaming ecosystem and other platforms' players.
• Corporate Transactions: In the event of a merger, acquisition, or sale of substantially all of no77's assets, personal data may be transferred to the acquiring entity, provided the receiving entity commits to maintaining data protection standards equivalent to those set out in this Policy.

06Cookies & Tracking Technologies

The no77 platform uses cookies and similar tracking technologies to ensure the platform operates correctly, remember your session, and gather aggregate usage analytics. The following categories of cookies are used:

Essential cookies are required for the no77 platform to function and cannot be disabled without preventing core platform functionality. Functional and analytics cookies may be declined, though doing so may affect your platform experience. Most modern browsers allow you to manage cookie preferences through browser settings — refer to your browser's help documentation for instructions specific to your device.

No77 does not use third-party advertising cookies or tracking pixels that build cross-site commercial profiles of your browsing behaviour.

07Data Security

no77 implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Specific security measures in place include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and no77's servers is encrypted in transit using TLS. This applies to login credentials, payment data, KYC document uploads, and all other communications across the platform.
• Password Hashing: Account passwords are never stored in plain text. No77 uses industry-standard cryptographic hashing algorithms — even no77 personnel cannot view or retrieve your password in its original form.
• Access Controls: Access to personal data held by no77 is restricted to personnel with a documented operational need. Access is role-based and audited. KYC documents are accessible only by authorised compliance team members.
• Intrusion Detection: no77's infrastructure is monitored for unusual access patterns, automated attack signatures, and anomalous data access requests. Detected threats trigger automated isolation and human review protocols.
• Session Security: Player sessions are automatically terminated after periods of inactivity. Multiple failed login attempts trigger temporary account lockout as a brute-force protection measure.

In the event of a personal data breach that is likely to result in a risk to your rights or interests, no77 will notify affected players in accordance with the notification requirements under its applicable licensing framework, without undue delay and where feasible within 72 hours of becoming aware of the breach.

08Data Retention

no77 retains personal data for no longer than is necessary for the purposes described in this Policy or required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised aggregate data from which individual identification is no longer possible may be retained beyond these periods for statistical and product improvement purposes.

09Your Rights Over Your Personal Data

As a player registered on no77, you hold a number of rights in relation to your personal data. These rights are genuine and exercisable — not procedural obstacles. To exercise any right listed below, contact no77 support via live chat or email at [email protected]. No77 will respond within 30 days of receiving a verifiable request.

10Children & Minors

The no77 platform is strictly for adults aged 21 years and older. No77 does not knowingly collect personal data from any individual under the age of 21. Age verification is performed during the registration process and may be supplemented by KYC document checks at any point.

If no77 becomes aware that personal data has been collected from a person under 21, that account will be immediately closed, all associated data will be deleted to the extent not required for regulatory record-keeping purposes, and any deposits will be returned at no77's discretion after deducting any winnings generated.

11International Data Transfers

As an internationally operated platform, no77 may process or store certain personal data on servers located outside Pakistan. Where personal data is transferred to jurisdictions that may have different data protection standards, no77 implements appropriate safeguards to ensure that the level of protection afforded to your data is not reduced as a result of such transfer.

Applicable safeguards may include contractual data processing agreements with relevant service providers, and adherence to the data protection requirements imposed by no77's international operating licence. By using the no77 platform, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan as part of the platform's normal operation.

12Responsible Gaming & Your Data

no77 uses gaming activity data — including bet frequency, session duration, deposit patterns, and wagering amounts — as part of its responsible gaming monitoring programme. This processing is carried out on the basis of no77's legitimate interest in protecting players from harm and fulfilling the responsible gaming obligations of its operating licence.

Specifically, no77 may:

• Analyse your gaming activity against established problem gambling indicators;
• Send you responsible gaming messages or cooling-off suggestions where concerning patterns are observed;
• Implement temporary deposit or session restrictions where significant risk indicators are identified;
• Retain responsible gaming interaction records (self-exclusion requests, limit changes) for the duration of the account and for a minimum of 5 years post-closure, to prevent re-registration during an active exclusion period.

You may set or adjust your own deposit limits, session timers, and self-exclusion preferences through your account settings or via the live chat support team. Full detail on available tools is published on our Responsible Gaming page.

13Third-Party Services

The no77 platform may integrate with or link to third-party service providers including game software studios, payment gateways, and identity verification services. These third parties operate under their own privacy policies and data protection frameworks. No77 exercises due diligence in selecting third-party partners with appropriate data protection commitments, but is not responsible for the privacy practices of third parties beyond the scope of data processing agreements in place.

No77 does not integrate third-party social media tracking pixels, cross-site advertising networks, or commercial data enrichment services that would allow external parties to build profiles of no77 players based on their platform activity.

14Policy Updates

No77 reserves the right to update this Privacy Policy at any time. Where material changes are made — particularly changes that affect the purposes for which your data is processed or the rights available to you — no77 will provide advance notice to registered players via email or in-platform notification before the revised policy takes effect.

The effective date displayed at the top of this page will be updated to reflect the date on which the most recent version of this Privacy Policy came into force. Your continued use of the no77 platform following notification of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not accept the revised Policy, you should cease using the platform and contact support to initiate account closure and data deletion requests.

15Contact & Complaints

For any questions, requests, or complaints relating to this Privacy Policy or the handling of your personal data by no77, please contact us through the following channels:

• Live Chat: The fastest method of reaching the no77 data protection team for routine enquiries — available 24/7 from within the platform. Mention "Privacy" or "Data Request" at the start of your chat to be routed to the relevant team.
• Email: [email protected] — for formal data subject access requests, erasure requests, or written privacy complaints. Include your registered username and a description of your request in the email subject line for faster routing. No77 aims to respond substantively to all privacy requests within 30 days.

No77 treats privacy complaints with the same seriousness as regulatory compliance matters. All complaints are logged, reviewed, and responded to by a responsible team member. Where a complaint cannot be resolved to your satisfaction through no77's internal process, you retain the right to escalate to the relevant supervisory authority or to the dispute resolution mechanism provided under no77's international operating licence.