Privacy Policy

This Privacy Policy ("Policy") is published by at77hh ("we", "us", "our", "the Platform") and applies to all personal data collected, processed and stored in connection with your use of the at77hh website at https://at77hh.cam and all related services and content.

at77hh is an English-language online gaming information and entertainment platform primarily serving users in Pakistan, including cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. We are committed to handling your personal data with transparency, care and in accordance with applicable data protection principles.

This Policy describes in plain, accessible English: what personal data we collect and how; the purposes for which we process it; who we may share it with; how long we keep it; the technical and organisational security measures we use to protect it; and the rights you have as a data subject to access, correct, delete or restrict processing of your personal information.

The following definitions apply throughout this Privacy Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person ("data subject"), including but not limited to name, email address, phone number, device identifiers, IP address and financial transaction data.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, alteration or deletion.
• "Controller" means at77hh, as the entity that determines the purposes and means of processing your Personal Data.
• "Processor" means any third party that processes Personal Data on behalf of at77hh under a data processing agreement.
• "Consent" means a freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data.
• "Cookies" means small data files stored on your device by the Platform's web server for the purposes of session management, analytics and personalisation.
• "KYC Data" means identity verification documentation collected in compliance with Know Your Customer obligations, including government-issued identification, proof of address and payment method documentation.
• "Platform" refers to the at77hh website at https://at77hh.cam and all associated features, services and content.

at77hh collects only the Personal Data that is necessary for legitimate Platform operations and the purposes described in this Policy. The categories of data we collect include:

3.1 Registration & Account Data

• Full legal name
• Date of birth (for age verification)
• Email address
• Username and hashed password
• Country of residence and city (e.g., Karachi, Lahore, Islamabad)
• Mobile phone number (where provided)
• Currency preference (including PKR where applicable)

3.2 KYC & Verification Data

• Government-issued photo identification (e.g., CNIC, passport, driving licence)
• Proof of residential address (e.g., utility bill, bank statement)
• Proof of payment method ownership (where required)
• Selfie or biometric verification data (where applicable)

3.3 Financial Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method references (e.g., last four digits of card, account reference for familiar Pakistan channels such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — referenced as context only, not implying their endorsement of gambling)
• Transaction identifiers and status records
• Account balance history

3.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system and browser version
• Session data including login timestamps and session duration
• Pages visited, features accessed and click-path data
• Error logs and performance diagnostics

3.5 Communications Data

• Support chat transcripts and email correspondence
• Complaint and dispute records
• Marketing preference records (opt-in / opt-out status)

We use the Personal Data we collect for the following specified, explicit and legitimate purposes:

We do not use your Personal Data for automated decision-making that produces significant legal effects without human oversight, except where required by applicable regulatory obligations.

at77hh processes your Personal Data only where a valid legal basis exists under applicable data protection law. The legal bases we rely on are as follows:

• Contract Performance: Processing necessary to register your account, process transactions and deliver the services you have signed up for.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC, AML and responsible gambling obligations.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, abuse detection and internal analytics — where our legitimate interests are not overridden by your rights and interests.
• Consent: For optional activities such as marketing email communications, where we have obtained your explicit prior consent. You may withdraw consent at any time.

at77hh does not sell, rent or trade your Personal Data to third parties for their own commercial purposes. We may share Personal Data with the following categories of third parties strictly for the purposes described in this Policy:

• Payment Processing Partners: To facilitate deposit and withdrawal transactions. These partners process financial data under their own applicable data protection obligations and our contractual requirements.
• KYC & Identity Verification Providers: Third-party services that assist with document verification, age verification and identity authentication as part of our KYC process.
• Fraud Detection & Security Providers: Services that help us identify and prevent fraudulent activity, account misuse and security threats.
• Analytics Providers: Aggregated, anonymised usage data may be processed by analytics tools to help us understand Platform performance and user experience.
• Legal & Regulatory Authorities: We may disclose Personal Data to law enforcement, regulatory authorities, courts or government agencies where required to do so by applicable law, court order or to protect our legal rights.
• Professional Advisors: Legal counsel, accountants and auditors who are bound by professional confidentiality obligations.

at77hh uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device by our web server. They serve several important functions:

You can control and manage cookies through your browser settings at any time. Please note that disabling essential cookies may impair the functionality of certain Platform features. For detailed guidance on managing cookies in your specific browser, refer to your browser's official help documentation.

at77hh retains Personal Data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory or contractual obligations. General retention periods are as follows:

• Account & Registration Data: Retained for the duration of your active account relationship with at77hh, plus a minimum of five (5) years following account closure to satisfy regulatory and audit obligations.
• KYC Documentation: Retained for a minimum of five (5) years following account closure or the completion of the transaction to which the KYC relates, in compliance with applicable anti-money laundering requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years following the transaction date for regulatory compliance and audit trail purposes.
• Communications & Support Records: Retained for up to three (3) years following the final interaction, or longer where the communication relates to an ongoing dispute or legal matter.
• Technical & Usage Data: Generally retained in aggregated or anonymised form indefinitely for Platform improvement purposes. Identifiable session logs retained for up to twelve (12) months.
• Marketing Preference Records: Retained until you withdraw consent or close your account, plus a reasonable period thereafter to evidence consent history.

Where retention beyond the stated periods is required by law or for the establishment, exercise or defence of legal claims, data will be retained for the duration of that requirement.

at77hh implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. Our security measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including passwords (stored as salted hashes) and KYC documentation.
• Role-based access controls limiting staff access to Personal Data to those with a legitimate operational need.
• Regular security assessments and penetration testing of Platform infrastructure.
• Two-factor authentication (2FA) options for user accounts to reduce unauthorised access risk.
• Monitoring and intrusion detection systems to identify and respond to suspicious activity.
• Staff training on data protection obligations and security awareness.

Subject to applicable data protection law and any overriding legal obligations (such as AML record-keeping requirements), you have the following rights with respect to your Personal Data held by at77hh:

To exercise any of the above rights, please submit your request in writing to [email protected] with the subject line "Data Rights Request". We will verify your identity before processing any request and respond within the applicable statutory timeframe. We will not charge a fee for reasonable requests.

at77hh operates internationally and may transfer your Personal Data to, or process it in, countries or territories outside of Pakistan or your country of residence. This may include transfers to countries where data protection laws differ from those in your jurisdiction.

Where such transfers occur, at77hh takes steps to ensure that your data is adequately protected through appropriate safeguards, including:

• Contractual clauses requiring the recipient to apply equivalent data protection standards to your Personal Data.
• Transfers only to jurisdictions recognised as providing an adequate level of data protection under applicable international standards.
• Specific data processing agreements with third-party processors that impose binding data protection obligations.

The at77hh Platform is strictly intended for adults. We do not knowingly collect, process or retain Personal Data from individuals under the age of 18 years, or the higher minimum age required by the relevant operator or licence jurisdiction.

During the registration process, users are required to confirm that they meet the applicable minimum age requirement. We conduct age verification as part of our KYC process and reserve the right to request documentation confirming date of birth at any point.

The at77hh Platform does not contain external links to third-party websites as a matter of policy. However, certain integrated services — such as game content providers, payment processors and analytics tools — operate under their own privacy policies and data protection practices.

at77hh is not responsible for the privacy practices of third-party processors beyond the contractual obligations we impose on them as described in Section 6 of this Policy. If you have concerns about how a specific third-party service processes your data, please contact them directly or review their published privacy policy.

Payment channel references on this Platform (including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are cited as familiar Pakistan-market payment references for user context only. at77hh is not responsible for the data practices of these institutions, and their mention does not imply endorsement of gambling or any affiliation with at77hh.

at77hh reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, our data processing practices or the services we offer. We will notify registered users of material changes through a prominent notice on the Platform or via email to the address registered on your account.

• The "Last Updated" date at the top of this page reflects the date of the most recent revision.
• Continued use of the Platform following publication of an updated Privacy Policy constitutes your acknowledgement of and agreement to the revised terms.
• If you do not accept the revised Policy, you must immediately cease using the Platform and may contact us to request account closure.
• Minor clarifications or formatting corrections that do not materially affect your rights may be made without specific notification.

We encourage you to review this Privacy Policy periodically, particularly before making any deposit or submitting personal documentation, to ensure you remain fully informed of our current data handling practices.

If you have any questions, concerns or requests regarding this Privacy Policy or the processing of your Personal Data by at77hh, please contact our team through the following channels. All data-related enquiries are handled with priority by our support team.