Privacy Policy

1. Introduction

This Privacy Policy (hereinafter the "Policy") is published by ef77 (hereinafter "ef77", "we", "us" or "our"), operator of the online gambling platform accessible at https://ef77.cam (the "Platform").

ef77 is an English-language platform targeted at users in Pakistan and internationally. We collect and process personal data in order to operate your account, verify your identity, process financial transactions, prevent fraud, comply with applicable legal and regulatory obligations, and continuously improve the quality of our service.

This Policy applies to all individuals who visit the ef77 website, register an account, or interact with ef77 in any other capacity. It should be read in conjunction with our Terms & Conditions and our Responsible Gambling page.

2. Definitions

For the purposes of this Policy, the following terms carry the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including name, email address, CNIC/passport number, IP address and financial account details.
• "Processing" means any operation performed on personal data, including collection, storage, use, disclosure and deletion.
• "Data Controller" means ef77, which determines the purposes and means of processing your personal data.
• "Data Processor" means a third-party entity that processes personal data on behalf of ef77, pursuant to a written data processing agreement.
• "KYC Data" means identity verification documents and related information submitted by you as part of the Know Your Customer process, including CNIC, passport copy and selfie/liveness check imagery.
• "Cookies" means small text files placed on your device by the Platform to store session and preference data.
• "User" or "you" means any natural person who accesses the Platform, registers an account or submits personal data to ef77.

3. Categories of Data We Collect

ef77 collects the following categories of personal data from users. We collect only the data that is necessary for the purposes described in this Policy:

4. How We Collect Your Data

ef77 collects personal data through the following channels:

• Direct submission: Information you provide when registering an account, completing KYC, making deposits or withdrawals, contacting our support team or participating in promotions.
• Automated technical collection: Data collected automatically when you access the Platform, including IP address, device identifiers, session metadata and browser information via cookies and server logs.
• Third-party verification providers: Identity and document verification services that process your KYC documents to confirm your identity and age on our behalf.
• Payment processors: Transaction reference data returned by payment processors (such as references to payment methods familiar to Pakistani users like bank transfers) when deposits or withdrawals are processed. Payment processor names referenced on this Platform are for contextual familiarity only and do not imply that specific processors are active or that they endorse ef77.
• Fraud and risk systems: Risk scoring and fraud detection systems that analyse account and transaction patterns against known fraud indicators.

5. Data Processing — Purposes & Activities

ef77 processes your personal data for the following specific purposes. We do not process your data for any purpose not listed below without first obtaining your explicit consent or unless required by applicable law.

5.1 Account Operation

To create, maintain and administer your ef77 account, including processing your registrations, login sessions, balance management, betting activity and account settings. This processing is essential to performing our contractual obligations to you.

5.2 Identity Verification (KYC)

To verify your identity, age and address in accordance with our KYC obligations. For Pakistani users, this typically involves processing your CNIC or passport details and, where required, a selfie or liveness verification image. KYC processing is required before withdrawal requests are approved.

5.3 Financial Transactions

To process deposits and withdrawals in PKR and other accepted currencies, maintain accurate transaction records, and fulfil anti-money laundering (AML) monitoring obligations.

5.4 Responsible Gambling

To operate and enforce the responsible gambling tools available to users — including deposit limits, loss limits, session timers, cooling-off periods and self-exclusion. We monitor account activity patterns to identify indicators of problem gambling behaviour and may contact you proactively if patterns warrant concern.

5.5 Customer Support

To handle your support enquiries, complaints and feedback through our Live Chat, Help Centre and email channels. Support communications are retained for quality assurance and compliance purposes.

5.6 Security & Fraud Prevention

To detect, investigate and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering and other prohibited conduct as set out in our Terms & Conditions.

5.7 Marketing Communications (Consent-Based)

To send you promotional offers, bonus notifications and platform updates via email or in-platform messaging, but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time through your account settings or by contacting our support team.

5.8 Platform Improvement

To analyse anonymised or aggregated usage data in order to improve platform performance, user experience and service quality. Individual user data is not used for profiling beyond the functional purposes described in this section.

6. Legal Basis for Processing

ef77 processes your personal data on the following legal bases, which apply in the jurisdiction of our operating licence:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you accepted at registration (e.g., account operation, transaction processing, KYC).
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML requirements, age verification obligations and regulatory reporting.
• Legitimate interests: Processing for fraud prevention, security monitoring and platform improvement, where our interests do not override your fundamental rights and freedoms.
• Consent: Processing for optional purposes, primarily marketing communications, where you have given freely given, specific and informed consent.

7. Data Sharing & Third-Party Disclosure

ef77 does not sell, rent or trade your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Identity verification providers: Third-party KYC service providers who process your identity documents on our behalf to confirm age and identity.
• Payment processors: Financial intermediaries who facilitate deposit and withdrawal transactions. These processors receive only the data necessary to process the specific transaction.
• Game and technology providers: Third-party studios and technology partners who supply casino games, sports data feeds and platform infrastructure. These providers may receive anonymised session data but not personally identifiable information beyond what is technically required.
• Fraud and AML systems: Risk management and anti-money laundering screening services that analyse transaction patterns.
• Regulatory and law enforcement authorities: Where required by applicable law, court order or regulatory instruction to disclose personal data.
• Professional advisers: Legal, accounting and auditing firms engaged by ef77, bound by professional confidentiality obligations.

8. Data Retention

ef77 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal obligations. The following general retention guidelines apply:

• Account data: Retained for the duration of your account plus a minimum of five (5) years following account closure, in compliance with AML and regulatory record-keeping requirements.
• KYC documents: Retained for a minimum period as required by the applicable regulatory framework governing our operating licence. After this period, KYC data is securely deleted or anonymised.
• Transaction records: PKR deposit and withdrawal transaction records are retained for a minimum of five (5) years to support AML monitoring and financial audit requirements.
• Support communications: Support chat logs and email records are retained for up to two (2) years for quality assurance and dispute resolution purposes.
• Marketing data: Consent records and associated communication history are retained until consent is withdrawn, plus a reasonable period thereafter for compliance purposes.
• Technical logs: Server logs and session metadata are retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data is securely deleted, anonymised or archived in accordance with our internal data lifecycle management procedures.

9. Security Measures

ef77 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction or alteration:

• SSL/TLS encryption: All data transmitted between your device and the ef77 Platform is encrypted using 256-bit SSL/TLS protocols.
• Access controls: Personal data is accessible only to authorised ef77 personnel and approved third-party processors on a strict need-to-know basis.
• Two-factor authentication (2FA): Available to all registered users as an additional layer of account protection.
• Secure KYC portal: Identity documents must be submitted through the Platform's dedicated HTTPS KYC portal. ef77 will never request sensitive documents via public chat, social media or unsecured email.
• Fraud monitoring systems: Automated systems continuously monitor for anomalous account and transaction behaviour.
• Regular security assessments: ef77 conducts periodic reviews of its data security infrastructure and practices.

10. Cookies & Tracking Technologies

ef77 uses cookies and similar tracking technologies to operate the Platform and enhance your user experience. The following categories of cookies may be in use:

• Strictly necessary cookies: Required for the Platform to function, including session management, login state and security tokens. These cookies cannot be disabled without impairing core functionality.
• Functional cookies: Store your preferences (e.g., language settings, PKR display format) to personalise your experience.
• Analytical cookies: Collect anonymised data about how users interact with the Platform (e.g., pages visited, session duration) to help us improve performance. No personally identifiable information is included in analytical data sets.
• Security cookies: Assist in detecting and preventing fraudulent activity, including unusual login patterns and bot traffic.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent you from using core Platform features. ef77 does not currently use third-party advertising cookies or behavioural tracking cookies for cross-site advertising purposes.

11. Your Data Rights

Subject to applicable law and certain operational limitations, you have the following rights with respect to your personal data held by ef77:

• Right of Access: You may request a copy of the personal data we hold about you. We will respond to access requests within a reasonable timeframe, subject to identity verification.
• Right to Rectification: You may request that inaccurate or incomplete personal data be corrected. Some data fields can be updated directly within your account settings.
• 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, subject to our overriding legal retention obligations (e.g., AML record-keeping).
• Right to Restriction of Processing: You may request that we restrict processing of your data in certain circumstances, such as while a disputed accuracy claim is being resolved.
• Right to Data Portability: Where technically feasible and legally applicable, you may request a machine-readable copy of the personal data you have provided to us.
• Right to Object: You may object to processing based on legitimate interests. Where objections are upheld, we will cease processing for that purpose.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw consent at any time without affecting prior processing.

12. Minors & Age Gating

The ef77 Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the applicable operator licence jurisdiction. ef77 does not knowingly collect or process personal data from persons below the applicable minimum age.

Where ef77 has reasonable grounds to suspect that a registered user is below the minimum age, the account will be suspended immediately pending age verification. If age verification is not satisfactorily completed, the account will be closed and any deposited funds returned via the original payment method, subject to AML checks.

13. Cross-Border Data Transfers

ef77 operates internationally and your personal data may be transferred to and processed in jurisdictions other than Pakistan. Such transfers may include the transmission of data to third-party service providers (e.g., KYC verification platforms, payment processors, game studios) located in other countries.

Where personal data is transferred across borders, ef77 takes steps to ensure that adequate safeguards are in place, including contractual data protection provisions with receiving parties. ef77 does not transfer data to jurisdictions that lack adequate data protection frameworks without implementing appropriate supplementary protective measures.

Note that Pakistan does not currently have a comprehensive data protection law equivalent to the EU GDPR or similar frameworks. ef77's data protection practices reflect the standards of the jurisdiction in which it holds its operating licence, supplemented by the commitments set out in this Policy.

14. Policy Amendments

ef77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law or platform functionality. The "Last Updated" date at the top of this page will be revised to reflect the date of the most recent amendment.

Where material changes are made to this Policy, ef77 will provide reasonable advance notice to registered users via the Platform or by email to your registered address. Your continued use of the Platform following such notice constitutes acceptance of the updated Policy.

If you do not agree to a material change in this Policy, you should contact us to exercise your data rights or to request account closure before the updated Policy takes effect.

15. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by ef77, please contact us through the following channel:

For responsible gambling support or account self-exclusion requests, please visit our Responsible Gambling page. For the full terms governing your use of the Platform, please refer to our Terms & Conditions.