ss77 Privacy Policy — Your Data, Handled with Respect

1. Introduction & Scope

This Privacy Policy ("Policy") is issued by ss77, the operator of the online gaming platform accessible at ss77.today ("the Platform," "we," "us," "our"). It describes how ss77 collects, processes, stores, shares, and protects personal data relating to individuals ("you," "your," "User," "Player") who access, register on, or otherwise interact with the ss77 platform.

This Policy applies to all personal data collected through the ss77 website, mobile interface, customer support channels, and any other touchpoint through which you interact with ss77. It covers all players on the ss77 platform regardless of their location within Pakistan — including players in Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, Peshawar, Multan, and all other cities and regions.

ss77 acts as the data controller in respect of all personal data processed under this Policy. As data controller, ss77 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is conducted in accordance with applicable data protection standards and ss77's obligations under its international gaming licence.

This Policy should be read alongside the ss77 Terms & Conditions, which govern the overall relationship between you and ss77. By registering on the ss77 platform, you acknowledge that you have read and understood this Privacy Policy.

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2. Data We Collect

ss77 collects only the personal data that is necessary and proportionate for the specific purposes described in this Policy. The categories of personal data we collect are as follows:

2.1 Identity & Contact Data

• Full legal name as it appears on your CNIC, passport, or other government-issued ID;
• Date of birth (collected for mandatory 21+ age verification);
• Pakistani mobile number (used for account security, OTP authentication, and communications);
• Email address (used for account communications and notifications);
• Residential address (collected during KYC verification processes);
• CNIC number or passport number (collected during identity verification, stored securely and not shared except as required by our licence).

2.2 Financial Data

• JazzCash account number or EasyPaisa account number linked to your ss77 wallet;
• HBL, UBL, or Meezan Bank account details where bank transfer is used;
• Debit card details (card number, expiry, billing name — stored in tokenised form only, never in plain text);
• Transaction history including deposits, withdrawals, bonuses received, and wager records;
• Source of funds documentation where required by licensing obligations.

2.3 Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system version, browser type and version;
• Session timestamps, login history, and session duration data;
• Pages visited within the ss77 platform, game titles played, and betting activity logs;
• Clickstream data and interaction events within the platform interface.

2.4 Communications Data

• Content of live chat support conversations;
• Email correspondence with the ss77 support team;
• Records of any complaints, disputes, or escalated queries you raise with ss77.

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3. How We Collect Your Data

ss77 collects your personal data through the following means:

• Direct registration: Information you provide when creating your ss77 account, completing KYC verification, or updating your account profile;
• Transaction processing: Data generated when you make deposits, request withdrawals, or receive bonus payments via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or debit card;
• Platform interaction: Technical and usage data collected automatically as you navigate and use the ss77 platform, including through cookies and similar technologies (see Section 7);
• Support communications: Information you provide when you contact the ss77 customer support team via live chat, email, or any other supported channel;
• Third-party verification services: Identity and document verification data received from licensed KYC verification providers engaged by ss77 to fulfil licence obligations — ss77 only engages reputable, licensed verification providers;
• Payment processors: Transaction confirmation and fraud-screening data received from payment processors handling JazzCash, EasyPaisa, and bank transfer transactions.

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4. How We Use Your Data

ss77 uses the personal data described in Section 2 for the following specific purposes:

Purpose	Data Used	Basis
Account creation & management	Identity, contact, financial data	Contract performance
Age & identity verification (21+)	DOB, CNIC, ID documents	Legal obligation / licence
Processing PKR deposits & withdrawals	Financial, identity data	Contract performance
Fraud prevention & security	Technical, financial, identity data	Legitimate interest / legal
Anti-money laundering (AML) compliance	Financial, identity, transaction data	Legal obligation / licence
Responsible gaming monitoring	Usage, transaction, session data	Legal obligation / licence
Customer support provision	Identity, communications data	Contract performance
Platform improvement & analytics	Technical, usage data (anonymised)	Legitimate interest
Promotional communications (opt-in only)	Contact data, game preferences	Consent

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5. Legal Basis for Processing

ss77 processes personal data only where a valid legal basis exists for doing so. The legal bases on which ss77 relies are:

• Contract performance: Processing that is necessary to create and manage your ss77 account, process deposits and withdrawals, and deliver the gaming services you have contracted for when registering on the platform;
• Legal obligation: Processing required to comply with ss77's obligations under its international gaming licence, including age verification, KYC/AML requirements, responsible gaming monitoring, and record-keeping obligations imposed by the licencing authority;
• Legitimate interests: Processing carried out for ss77's legitimate business interests, including fraud detection, platform security, network abuse prevention, and aggregated analytics for platform improvement — always subject to your interests and rights not overriding ss77's legitimate interest;
• Consent: Processing for optional purposes such as marketing communications and optional cookie categories, where ss77 obtains your prior explicit consent. You may withdraw such consent at any time without affecting other processing.

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6. Data Sharing & Disclosure

ss77 may share your personal data with the following categories of recipients, and only to the extent strictly necessary:

6.1 Payment Processors

ss77 shares relevant financial and identity data with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and debit card processors solely for the purpose of processing your deposits, withdrawals, and related transaction verification. All payment processors engaged by ss77 are contractually bound to handle your data securely and in accordance with applicable data protection standards.

6.2 Identity Verification Providers

ss77 engages licensed KYC verification service providers to assist with identity verification and AML screening as required by ss77's international gaming licence. These providers receive only the minimum data required to perform verification functions and are strictly prohibited from using your data for any other purpose.

6.3 Game and Technology Providers

Third-party game providers whose titles are available on the ss77 platform may receive technical identifiers (such as anonymised player session tokens) necessary to deliver the game. These providers do not receive your real name, CNIC, financial details, or contact information. All technology providers operating within the ss77 ecosystem are contractually bound to data protection standards consistent with ss77's licensing obligations.

6.4 Regulatory & Law Enforcement Authorities

ss77 may disclose personal data to its licensing authority, financial intelligence units, law enforcement agencies, or courts where required to do so by applicable law, court order, or the conditions of ss77's international gaming licence. ss77 will notify affected users of such disclosures where legally permitted to do so.

6.5 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving ss77, personal data held by ss77 may be transferred to a successor entity. In such cases, ss77 will take reasonable steps to ensure that the receiving entity provides privacy protections at least equivalent to those described in this Policy, and will notify registered players of any such transfer.

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7. Cookies & Tracking Technologies

The ss77 platform uses cookies and similar tracking technologies to operate the platform correctly, maintain your session, protect account security, and — where you have consented — improve your experience and deliver relevant content. The categories of cookies used on the ss77 platform are:

• Strictly Necessary Cookies: These cookies are essential for the ss77 platform to function. They maintain your login session, remember your language preferences, and enable secure communications between your browser and the ss77 servers. These cookies cannot be disabled as the platform will not function without them;
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred payment method, interface language, and notification preferences — so you do not have to re-enter them on each visit. They do not track you across other websites;
• Analytics Cookies: With your consent, ss77 uses analytics cookies to collect aggregated, anonymised data about how players navigate the platform. This data helps ss77 identify areas for improvement and optimise the user experience. No individual player is identified in analytics reports;
• Security Cookies: These cookies support ss77's fraud detection and account security systems by flagging unusual access patterns and confirming that login attempts originate from recognised devices.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the ss77 platform. ss77 does not use advertising or third-party behavioural tracking cookies.

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8. Data Security

ss77 implements technical and organisational security measures that are appropriate to the nature of the data held and the risks involved in its processing. The key security measures in place include:

• 256-bit SSL/TLS 1.3 encryption for all data transmitted between your device and the ss77 platform — the same standard used by major international banks;
• Encrypted storage for all sensitive personal and financial data at rest, using industry-standard encryption algorithms;
• Zero plain-text password storage — your ss77 account password is never stored in readable form. Passwords are hashed using modern cryptographic algorithms before storage;
• SMS two-factor authentication available for all accounts to prevent unauthorised access even where login credentials have been compromised;
• Payment card tokenisation — debit card details are stored only as tokens provided by PCI-DSS compliant payment processors. ss77 never stores raw card numbers;
• Access controls limiting internal access to personal data on a strict need-to-know basis — only ss77 staff whose roles require access to specific categories of data are permitted to access those categories;
• Regular security audits conducted by independent third-party security professionals to identify and remediate vulnerabilities;
• Intrusion detection and monitoring systems operating continuously to detect and respond to security incidents in real time.

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9. Data Retention

ss77 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by ss77's obligations under its international gaming licence and applicable law. The general retention principles ss77 applies are:

• Active account data: Personal data associated with an active ss77 account is retained for the duration of the account's existence on the platform;
• Closed account data: Following account closure, ss77 retains identity, financial, and transaction data for a minimum period as required by AML regulations and our gaming licence — typically five (5) years from the date of account closure. This retention is mandatory and cannot be waived;
• Transaction records: Detailed records of all deposits, withdrawals, and wagering transactions are retained for the period required by our licensing authority's record-keeping requirements;
• KYC documentation: Identity verification documents are retained for the period required under AML obligations applicable to licensed gaming operators;
• Marketing consent records: Records of marketing consent opt-ins and opt-outs are retained for as long as necessary to demonstrate compliance with consent obligations;
• Support communications: Customer support chat logs and email records are retained for a reasonable period after the resolution of the relevant query to assist with any related follow-up.

When personal data is no longer required for any lawful purpose, ss77 securely destroys or irreversibly anonymises it in accordance with our data disposal procedures.

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10. Your Privacy Rights

As a user of the ss77 platform, you have the following rights in relation to your personal data. These rights can be exercised by contacting the ss77 support team via live chat, which is available 24/7 from any page on the platform:

• Right of Access: You have the right to request confirmation of whether ss77 holds personal data about you and, if so, to receive a copy of that data together with information about how it is processed;
• Right to Rectification: You have the right to request correction of inaccurate personal data ss77 holds about you. You can update basic account information directly through your account settings without needing to contact support;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Please note that ss77 is required to retain certain data for the mandatory periods described in Section 9 and cannot erase data subject to those retention requirements. Data deletion requests will be fulfilled to the maximum extent permitted by our licensing obligations;
• Right to Restrict Processing: You may request that ss77 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of ss77's legitimate grounds;
• Right to Data Portability: You have the right to receive personal data you have provided to ss77 in a structured, commonly used, machine-readable format where processing is based on your consent or a contract with you;
• Right to Object: You have the right to object to processing of your personal data where it is based on ss77's legitimate interests. You also have an absolute right to object to processing for direct marketing purposes, which ss77 will action immediately upon receipt;
• Right to Withdraw Consent: Where processing is based on your consent (such as for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

ss77 will respond to all valid data rights requests within thirty (30) calendar days. In complex cases, this period may be extended by a further two months, and you will be informed of any such extension within the initial thirty-day period. ss77 does not charge a fee for handling data rights requests unless a request is manifestly unfounded or excessive.

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11. Children's Privacy

If ss77 becomes aware that personal data has been collected from an individual under the age of 21 — whether due to misrepresentation of age at registration or any other reason — ss77 will immediately suspend the relevant account, delete all associated personal data to the extent not required for regulatory compliance, and return any funds deposited to the source account. Appropriate reporting to relevant authorities will be made where required.

Parents and guardians who believe that a minor under their care may have registered or attempted to register on the ss77 platform are encouraged to contact the ss77 support team immediately. ss77 takes the protection of minors from online gambling extremely seriously and will act promptly on any such notification.

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12. Policy Updates

ss77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or updates required by ss77's international gaming licencing authority. The "Effective" date at the top of this Policy will be updated each time a revision is made.

When material changes are made to this Policy, ss77 will notify registered players via the email address or mobile number registered on their account, and will publish the updated Policy on this page. For minor, non-material changes — such as clarifications of existing language that do not change the substance of what ss77 does with your data — ss77 may update the Policy without individual notification.

Your continued use of the ss77 platform following notification of a revised Privacy Policy constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed of how ss77 handles your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ss77 handles your personal data, please contact the ss77 support team via live chat, accessible at any time from any page on the ss77 platform. Our support team is available around the clock and privacy-related queries are escalated to the appropriate person within ss77 without delay.