he77 Privacy Policy

1. Who We Are

This Privacy Policy is issued by he77 ("he77", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at he77.club. he77 is the data controller responsible for the personal information of all registered players and site visitors.

For any data-related enquiries, including requests to exercise your rights under applicable data protection law, you may contact our dedicated privacy team via the contact details provided in Section 16 of this policy. Our support team is available 24 hours a day, 7 days a week, and is familiar with the needs of Pakistani players across Karachi, Lahore, Islamabad, and Faisalabad.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected, processed, stored, or shared by he77 in connection with:

• The he77.club website and all pages, features, and content accessible through that domain.
• The registration and management of Player Accounts on he77.
• All deposits, withdrawals, and financial transactions processed through the he77 cashier.
• All gameplay activity, betting, and use of gaming features on the Platform.
• Customer support interactions via live chat, email, or any other communication channel.
• Marketing communications, promotional campaigns, and loyalty programme activity.
• KYC (Know Your Customer) identity and age verification procedures.
• Responsible gaming tool usage, including self-exclusion requests, deposit limits, and cooling-off periods.

This policy does not apply to third-party websites, services, or applications that may be linked to from he77.club. he77 is not responsible for the privacy practices of any third party and encourages you to review the privacy policies of any external services you access.

3. Data We Collect

he77 collects personal data through several channels. The categories of data we collect, and the circumstances in which each category is gathered, are set out below.

3.1 Registration Data

When you create a Player Account on he77, we collect the following information:

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Residential address (including city, province, and postal code in Pakistan)
• Email address
• Pakistani mobile phone number
• Username and encrypted password
• Preferred currency (PKR)

3.2 KYC Verification Data

To comply with our licensing obligations and anti-money-laundering requirements, we collect:

• Government-issued photo ID (CNIC, passport, or driving licence)
• Proof of residential address (utility bill, bank statement)
• Proof of payment method ownership (JazzCash or EasyPaisa account screenshot, bank statement header)
• Source of funds documentation for high-value transactions
• Selfie or biometric photo for identity confirmation where required

3.3 Financial Transaction Data

All deposits and withdrawal transactions on he77 generate the following data records:

• Payment method type (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, bank transfer)
• Transaction amounts in PKR
• Transaction timestamps and reference numbers
• Account identifiers associated with the payment method (masked for security)

3.4 Gameplay & Activity Data

• Game sessions played, including game type, duration, wager amounts, and outcomes
• Sports betting activity, including markets selected, stake amounts, and results
• Bonus and promotional offer uptake and wagering history
• Responsible gaming tool settings and usage history

3.5 Technical & Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Session login timestamps and durations
• Referring URL and on-site navigation path
• Cookie identifiers and similar tracking data (see Section 7)

3.6 Communications Data

• The content of live chat and email support conversations
• Feedback, complaints, and dispute correspondence
• Responses to surveys or promotional communications

4. How We Use Your Data

he77 uses the personal data it collects for the following specific purposes. We do not use your data for any purpose incompatible with those listed here without first obtaining your explicit consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

he77 processes personal data only where a valid legal basis exists under applicable data protection law. The four legal bases on which he77 relies are:

• Contract Performance: Processing that is necessary to fulfil our contractual obligations to you as a Player — including account management, payment processing, and the provision of gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC and anti-money-laundering obligations imposed by our international gaming licence.
• Legitimate Interest: Processing undertaken for he77's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and analytical improvements — where those interests are not overridden by your privacy rights.
• Consent: Processing for which you have given explicit, freely given, and withdrawable consent — primarily marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

he77 does not sell, rent, or otherwise commercially exploit your personal data. Data is shared with third parties only in the limited circumstances described below, and only to the extent necessary for the specified purpose.

6.1 KYC and Identity Verification Partners

he77 works with licensed third-party KYC verification providers to confirm the identity and age of Players. These partners receive only the data necessary to complete identity checks and are bound by strict data processing agreements that prohibit secondary use of your data.

6.2 Payment Processors

Transaction data is shared with payment processing partners — including the operators of JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and bank transfer infrastructure — solely for the purpose of processing deposits and withdrawals. Payment processors are required to handle your data in accordance with applicable financial regulations and data protection standards.

6.3 Regulatory and Law Enforcement Authorities

he77 will disclose personal data to regulatory bodies, law enforcement agencies, tax authorities, or courts where required to do so by law, by court order, or in connection with the supervision of our gaming licence. We will notify affected Players of such disclosures where legally permissible to do so.

6.4 Fraud Prevention Services

To detect and prevent financial crime, he77 may share relevant data with fraud prevention databases and agencies. Information shared in this context may be used to assess risk and may, in some cases, affect a Player's ability to access financial services provided by other organisations.

6.5 Professional Advisors

he77 may share data with its legal counsel, auditors, and professional advisors in connection with the conduct of legal proceedings, audit reviews, or regulatory submissions. All such advisors are bound by confidentiality obligations.

7. Cookies & Tracking Technologies

he77 uses cookies, web beacons, pixel tags, and similar tracking technologies on the Platform. A cookie is a small text file placed on your device by the he77.club server when you visit the site. Cookies help he77 recognise returning users, maintain session security, and understand how the Platform is used.

7.1 Categories of Cookies Used by he77

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies maintain your login session, keep your account secure, and enable core gaming and cashier functionality. They cannot be disabled without disrupting Platform operation.
• Functional Cookies: Remember your preferences, such as language settings and display configurations, to personalise your experience on return visits.
• Analytics Cookies: Collect anonymised data about how players interact with the Platform — pages visited, time spent, and navigation paths — to help he77 improve site performance and user experience.
• Marketing Cookies (Consent Required): Used to deliver relevant promotional content within the he77 Platform based on your activity and preferences. These cookies are only activated where you have provided explicit consent.

7.2 Managing Your Cookie Preferences

You can manage non-essential cookie preferences through the Cookie Preference Centre accessible via the consent banner displayed on your first visit to he77.club. You can also control cookies through your browser settings, though disabling certain cookies may affect the functionality of the Platform. Withdrawing cookie consent does not affect the lawfulness of processing that occurred prior to withdrawal.

8. Data Retention

he77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Active Account Data: Retained for the full duration of your Player Account, plus a mandatory retention period of five years following account closure, in accordance with anti-money-laundering record-keeping obligations.
• KYC Verification Documents: Retained for a minimum of five years from the date of verification or from the date of the last transaction, whichever is later, as required by our licensing authority.
• Financial Transaction Records: Retained for five years from the date of each transaction in accordance with financial crime prevention requirements.
• Customer Support Communications: Retained for two years from the date of the last interaction, unless the communication forms part of an ongoing dispute or legal proceeding, in which case it is retained until the matter is fully resolved.
• Marketing Consent Records: Retained for the duration of your consent plus three years to evidence compliance in the event of a regulatory inquiry.
• Technical and Device Logs: Retained for 12 months from the date of collection for security monitoring and fraud detection purposes.

When the applicable retention period expires, he77 securely deletes or anonymises personal data in accordance with its data disposal procedures. Anonymised data — which can no longer identify you — may be retained indefinitely for statistical and analytical purposes.

9. International Data Transfers

he77 operates internationally and may process or store your personal data on servers located outside Pakistan. Where personal data is transferred to a country that does not provide a level of data protection equivalent to international standards, he77 will implement appropriate safeguards to protect your data, which may include:

• Standard contractual clauses approved by recognised data protection authorities
• Data processing agreements with receiving parties that impose equivalent data protection obligations
• Transfers to jurisdictions that have been assessed as providing adequate data protection

By registering an Account on he77 and accepting our Terms and Conditions, you acknowledge that your personal data may be transferred, stored, and processed in countries outside Pakistan as described in this section. he77 takes all reasonably practicable steps to ensure such transfers are carried out securely and lawfully.

10. Your Privacy Rights

As an he77 Player, you hold the following rights in relation to your personal data. To exercise any of these rights, contact our privacy team at [email protected] with your Account username and a description of your request. he77 will respond within 30 days of receipt.

• Right of Access: You may request a copy of all personal data he77 holds about you, along with information about how it is used, where it is stored, and with whom it has been shared.
• Right to Rectification: If any personal data he77 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or supplemented without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where processing was unlawful. This right is subject to overriding legal retention obligations.
• Right to Restriction of Processing: You may request that he77 suspend processing of your data in certain circumstances — for example, while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you have the right to receive your personal data in a structured, machine-readable format for transfer to another controller.
• Right to Object: You may object to processing of your data based on legitimate interest grounds, including profiling for direct marketing purposes. he77 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

11. Children & Minors

If he77 discovers or is notified that an Account belongs to a person under the age of 21, the Account will be closed immediately, all associated personal data will be flagged for deletion in accordance with our data retention policy and applicable law, and any funds will be returned to the source payment method net of amounts already wagered.

If you believe that a minor may have registered an Account on he77 using false information, please contact our support team immediately at [email protected]. he77 takes underage gambling extremely seriously and will act on all credible reports without delay.

Parents and guardians in Pakistan who share devices with children are strongly encouraged to use parental control software to restrict access to online gambling platforms, including he77.club.

12. Marketing Preferences

he77 may send you promotional communications — including information about bonuses, PSL cricket betting offers, new slot titles, and platform updates — where you have given explicit consent to receive marketing at the point of registration or subsequently through your Account settings.

12.1 Types of Marketing Communications

• Email newsletters covering new games, promotions, and platform news
• SMS notifications about active bonus offers and deposit match promotions
• Push notifications (where enabled on your device) for time-sensitive offers
• Personalised in-platform promotional banners and pop-ups based on your gaming preferences

12.2 Opting Out

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

• Clicking the unsubscribe link in any marketing email from he77
• Updating your marketing preferences in your Account settings
• Contacting he77 support directly at [email protected]

Opting out of marketing communications will not affect your ability to use the Platform or receive transactional communications related to your Account, such as deposit confirmations, withdrawal notifications, and security alerts.

13. Security Measures

he77 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure.

13.1 Technical Safeguards

• Encryption in Transit: All data transmitted between your browser and he77.club is protected by 256-bit TLS/SSL encryption, preventing interception by third parties.
• Encryption at Rest: Sensitive personal data stored on he77's servers — including KYC documents and financial records — is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within he77's systems is restricted on a strict need-to-know basis. Staff access is governed by role-based access controls and multi-factor authentication.
• Intrusion Detection: he77's infrastructure is monitored 24/7 by automated intrusion detection systems that flag and respond to anomalous access patterns, brute-force attempts, and other security threats in real time.
• Penetration Testing: he77 conducts regular independent penetration tests and security audits of its Platform infrastructure to identify and remediate vulnerabilities before they can be exploited.
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their he77 Accounts as an additional layer of protection against unauthorised access.

13.2 Organisational Safeguards

• All he77 staff with access to personal data undergo mandatory data protection training upon onboarding and annually thereafter.
• Data processing agreements are in place with all third-party partners who handle personal data on he77's behalf.
• A documented incident response plan is maintained and tested regularly, enabling he77 to respond rapidly to any data security incident.
• In the event of a data breach that is likely to result in a risk to your rights and freedoms, he77 will notify you without undue delay in accordance with applicable legal requirements.

14. Third-Party Links

The he77 Platform may contain links to third-party websites, services, or resources for informational or operational purposes. he77 does not control the privacy practices or content of any third-party site and is not responsible for how those sites collect, use, or protect your personal data.

When you click a link that takes you away from he77.club, you are leaving the he77 Platform and your interaction with the destination site is governed by that site's own privacy policy and terms. he77 strongly recommends that you review the privacy policy of any third-party site before providing personal information.

The presence of a link on he77.club does not constitute an endorsement of the linked site or any products or services offered by it.

15. Changes to This Privacy Policy

he77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform functionality. When material changes are made — meaning changes that substantially affect your rights or how your data is processed — he77 will:

• Post the updated Privacy Policy on he77.club with a revised effective date clearly displayed at the top of the document.
• Notify registered Players via email to the address associated with their Account at least seven days before the changes take effect.
• Display a prominent notice upon login to the Platform drawing attention to the update.

Minor amendments — such as corrections of typographical errors, clarifications of existing provisions, or updates to contact information — may be implemented immediately without prior notice. Your continued use of the Platform following notification of a material change constitutes acceptance of the revised Privacy Policy.

If you do not agree with any change to this Privacy Policy, you should stop using the he77 Platform and may close your Account by contacting our support team. Any personal data collected prior to the change will continue to be processed under the terms in effect at the time of collection, unless you consent to the new terms.

16. Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way he77 handles your personal data, please contact our privacy and support team using the details below. Our team is available around the clock and is well-equipped to assist players from across Pakistan — including Karachi, Lahore, Islamabad, Faisalabad, and Peshawar.

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week via the he77.club Platform
• Response Time: Privacy rights requests acknowledged within 72 hours; substantive responses within 30 days

16.1 Escalation and Formal Complaints

If you are not satisfied with he77's response to a privacy concern, you have the right to escalate your complaint to the data protection supervisory authority or regulatory body with jurisdiction over he77's data processing operations. he77 will cooperate fully with any regulatory investigation and will provide affected Players with information about the relevant supervisory authority upon request.

he77 is committed to resolving all privacy concerns fairly, efficiently, and in good faith. We encourage Players to contact us directly in the first instance, as most issues can be resolved quickly through our internal process without the need for formal escalation.