td77 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by td77 ("td77," "we," "us," "our") and applies to all personal information collected from individuals ("Player," "User," "You") who register an account, access, or otherwise interact with the td77 Platform at td77.bio.

td77 takes the privacy of its players seriously. This Policy is intended to provide a clear and honest account of how we handle your personal information — what we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have in relation to it.

By registering a td77 account and using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, you should not create or continue to use a td77 account.

2. Data We Collect

td77 collects personal data in the following categories:

2.1 Registration & Account Data

• Full legal name (as it appears on your CNIC)
• Date of birth
• Email address
• Pakistani mobile phone number
• Username and encrypted account password
• City and province of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad)

2.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents (CNIC — front and back)
• Selfie photographs taken with the CNIC document
• Proof of payment method documents (e.g., JazzCash wallet screenshots, Easypaisa statements, HBL or UBL bank statements)

2.3 Financial & Transaction Data

• Deposit and withdrawal amounts and timestamps
• Payment method identifiers (e.g., JazzCash mobile number, Easypaisa wallet ID, bank account name and number)
• Transaction reference numbers
• PKR balance history

2.4 Gaming Activity Data

• Game session logs including titles played, bet amounts, outcomes, and timestamps
• Sportsbook bet history including markets, odds, and settlement outcomes
• Bonus claims, wagering progress, and promotional history

2.5 Technical & Device Data

• IP address at the time of login and transaction
• Device type, operating system, and browser information
• Session duration and Platform navigation patterns
• Cookie identifiers (see Section 7)

2.6 Communications Data

• Content of support tickets, live chat transcripts, and email correspondence with the td77 support team
• Complaint and dispute records

3. How We Use Your Data

td77 uses the personal data we collect for the following purposes:

• Account Administration: Creating, managing, and maintaining your td77 account; processing login and authentication requests.
• Transaction Processing: Receiving PKR deposits via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and USDT; processing withdrawal requests to verified payment methods.
• Identity Verification (KYC): Verifying that account holders are who they claim to be, that they are of legal age (18+), and that payment methods belong to the registered account holder.
• Fraud Prevention & Security: Detecting and investigating suspicious account activity, duplicate accounts, attempted account takeovers, money laundering patterns, and other fraudulent behaviour.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviours; applying deposit limits, cooling-off periods, and self-exclusion measures where requested or required.
• Customer Support: Responding to Player enquiries, complaints, and disputes; maintaining correspondence records for accountability purposes.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform performance, game selection, and user experience for Pakistani players.
• Legal & Regulatory Compliance: Meeting obligations under applicable laws and regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) requirements.

4. Legal Basis for Processing

td77 processes personal data on the following legal grounds:

• Contractual Necessity: Processing required to provide the services described in the td77 Terms & Conditions — account management, transaction processing, KYC verification, and customer support.
• Legal Obligation: Processing required to comply with applicable AML, CTF, and data protection laws.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by the Player's rights.
• Consent: Where td77 relies on consent (e.g., for optional marketing communications), this consent is sought separately and may be withdrawn at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Third Parties

td77 does not sell personal data. We share personal data only in the following limited circumstances:

5.1 Game Providers

td77 integrates game content from third-party providers. These providers may receive limited technical session data (e.g., session tokens, bet outcomes) necessary to deliver their games. They do not receive your full personal profile, CNIC data, or payment account details.

5.2 Payment Processors

Transaction data is shared with payment processors (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah) to the extent necessary to process deposits and withdrawals. These processors are bound by their own data protection obligations.

5.3 KYC Verification Services

td77 may use third-party identity verification services to assist with CNIC document verification and facial matching. These services process KYC data under strict contractual data processing agreements with td77.

5.4 Legal & Regulatory Authorities

td77 may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required by applicable law or valid legal process. Such disclosures are made only to the extent required and not beyond.

6. KYC & Identity Data

KYC documents — including CNIC images and selfie photographs — are particularly sensitive categories of personal data. td77 handles KYC data with heightened care:

• KYC documents are stored in encrypted form on secure servers with restricted access.
• Access to KYC documents is limited to td77 compliance staff and authorised verification partners operating under data processing agreements.
• KYC documents are not shared with game providers, marketing partners, or any other third party except as required by law or as described in Section 5.3.
• KYC documents are retained for a minimum period required by applicable AML regulations following account closure.

7. Cookies & Tracking Technologies

td77 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that help the Platform function correctly and help td77 understand how Players use the Platform.

7.1 Essential Cookies

Essential cookies are required for the Platform to function. They manage your login session, maintain your account state, and ensure security. These cookies cannot be disabled without preventing you from using the Platform.

7.2 Analytical Cookies

td77 uses first-party analytical cookies to understand how Players navigate the Platform — which pages are visited most frequently, where errors occur, and how performance can be improved. This data is aggregated and anonymised where possible.

7.3 Managing Cookies

You can manage cookie preferences through your browser settings. Note that disabling essential cookies will impair your ability to log in to and use the td77 Platform. Analytical cookies can be disabled without affecting core Platform functionality.

8. Data Retention

td77 retains personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure.
• Transaction Records: Retained for a minimum of seven (7) years from the date of the relevant transaction, in compliance with AML record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the most recent transaction, whichever is later.
• Support & Communications Records: Retained for a minimum of three (3) years from the date of the most recent communication.

After the applicable retention period, personal data is securely deleted or anonymised in accordance with td77's data disposal procedures.

9. Data Security

td77 implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption of all data transmitted between your browser and the td77 Platform.
• Encryption of sensitive stored data including passwords (hashed), KYC documents, and payment account identifiers.
• Role-based access controls ensuring that personal data is accessible only to td77 staff who require it for legitimate operational purposes.
• Regular security assessments and monitoring of Platform infrastructure for vulnerabilities and intrusion attempts.
• Two-factor authentication available for Player accounts to reduce the risk of unauthorised account access.

While td77 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to Player rights, td77 will notify affected Players without undue delay.

10. Your Rights

As a td77 Player, you have the following rights in relation to your personal data:

• Right of Access: You may request a copy of the personal data td77 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Some data (such as CNIC-verified name and date of birth) cannot be amended without re-verification.
• Right to Erasure: You may request deletion of your personal data in certain circumstances. Note that erasure requests may be declined where td77 is required to retain data by law (e.g., AML record-keeping obligations).
• Right to Restriction: You may request that td77 restrict processing of your personal data in certain circumstances.
• Right to Object: You may object to processing based on legitimate interests where you have grounds relating to your particular situation.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting prior lawful processing.

To exercise any of these rights, contact td77 support at the email address provided on this website. We will respond to all requests within 30 days. In some cases, we may require proof of identity before processing your request.

11. Children's Privacy

The td77 Platform is strictly intended for adults aged 18 years and over. td77 does not knowingly collect personal data from individuals under the age of 18. If td77 becomes aware that personal data has been collected from an individual under 18, we will delete that data promptly and close the associated account. Parents or guardians who believe that a minor has registered a td77 account should contact us immediately at the support email provided on this website.

12. Changes to This Privacy Policy

td77 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, td77 will notify registered Players via email or a prominent notice on the Platform, and the "Last updated" date at the top of this Policy will be revised accordingly.

Your continued use of the td77 Platform following notification of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree with any change, you should cease using the Platform and may request account closure by contacting support.