ef77 Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") applies to all personal data collected by ef77 in connection with the ef77 online casino and sportsbook platform, accessible at ef77.app. It applies to all users regardless of their location, including players based in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, and across Pakistan.

By registering an ef77 account or using the ef77 platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, you must not use the ef77 platform.

This Policy should be read in conjunction with ef77's Terms & Conditions and Responsible Gaming Policy. In the event of any conflict, this Policy governs ef77's data practices.

2. Personal Data We Collect

ef77 collects personal data across several categories depending on the nature of your interaction with the platform. The categories of data collected are described below.

2.1 Registration Data

When you create an ef77 account, we collect:

• Full name
• Date of birth (for age verification purposes)
• Pakistani mobile number (for OTP verification and account security)
• Email address
• Password (stored in hashed, non-recoverable form — ef77 cannot access your plaintext password)
• Country and city of residence

2.2 Identity Verification Data

ef77 may request the following documents as part of Know Your Customer (KYC) verification, particularly before processing withdrawals above a threshold amount:

• Copy of Pakistani CNIC (Computerised National Identity Card) or other government-issued photo ID
• Proof of address (utility bill, bank statement) dated within 90 days
• Selfie or live photo for identity matching

2.3 Financial & Payment Data

When you make a deposit or withdrawal on ef77, we collect:

• Payment method type (e.g., JazzCash, Easypaisa, bank transfer, card)
• JazzCash or Easypaisa account number associated with the transaction
• Bank account details (account title, IBAN) for bank transfer transactions
• Transaction amounts, timestamps, and reference numbers

ef77 does not store full card numbers. Card transactions are processed through regulated payment processors, and only the last four digits and card type are retained by ef77 for reference.

2.4 Usage & Technical Data

ef77 automatically collects technical data during your use of the platform, including:

• IP address and approximate geolocation (country/city level)
• Device type, operating system, and browser
• Session timestamps, pages visited, and navigation patterns
• Games played, bets placed, amounts wagered, and outcomes
• Login history and security events (e.g., failed login attempts)

2.5 Communication Data

If you contact ef77 support — via live chat, email, or any other channel — ef77 retains records of that communication, including your message content, timestamps, and the resolution reached. This data is used to resolve disputes, improve support quality, and maintain account security records.

3. How ef77 Uses Your Data

ef77 does not use your personal data for any purpose not listed above without your prior consent, except where required by law.

4. Legal Basis for Processing

ef77 processes personal data on the following legal bases:

• Contractual necessity: Processing required to register your account, operate your PKR wallet, process deposits and withdrawals, and deliver the gaming services you have contracted with ef77 to receive.
• Legal obligation: Processing required to comply with applicable anti-money laundering (AML), Know Your Customer (KYC), and age verification obligations imposed on gaming operators.
• Legitimate interests: Processing for fraud detection, platform security, responsible gaming monitoring, and service improvement where ef77's legitimate interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit, informed consent. Consent may be withdrawn at any time by contacting ef77 support or adjusting your account communication preferences.

5. Data Sharing & Third Parties

ef77 does not sell your personal data to third parties. ef77 may share your personal data with the following categories of recipients only where necessary and appropriate:

• Payment processors: JazzCash, Easypaisa, Pakistani banking partners (HBL, UBL, Meezan Bank, Bank Alfalah), card networks (Visa, Mastercard), and cryptocurrency processing services — solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC/AML service providers engaged to verify your identity and comply with regulatory obligations.
• Game software providers: Licensed gaming studios (including PG Soft, Pragmatic Play, and others) may receive anonymised session data as part of game delivery. These providers do not receive personally identifiable information.
• Technology service providers: Cloud hosting, security, and infrastructure providers operating under confidentiality obligations who support ef77's platform operations.
• Law enforcement and regulatory authorities: Where ef77 is legally required to disclose personal data in response to a lawful order, court order, or regulatory enquiry, ef77 will comply.

All third-party service providers engaged by ef77 are contractually required to maintain the confidentiality and security of any personal data shared with them and are prohibited from using it for any purpose other than the specific service they provide to ef77.

6. Data Retention

ef77 retains personal data for as long as is necessary to fulfil the purposes described in this Policy or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your ef77 account and for a minimum of 5 years following account closure, in compliance with AML record-keeping requirements.
• Transaction records: Retained for a minimum of 5 years from the date of the transaction.
• Identity verification documents: Retained for the duration of the account and for a minimum of 5 years following account closure.
• Support communications: Retained for 3 years from the date of the communication unless there is an ongoing dispute requiring longer retention.
• Technical and usage logs: Retained for up to 24 months for security and fraud detection purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ef77's data deletion procedures.

7. Data Security

ef77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ef77's servers
• Bcrypt or equivalent hashing for all stored passwords — ef77 cannot retrieve your password in plaintext
• OTP-based mobile verification for account registration, password resets, and high-risk actions
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing of ef77's platform infrastructure
• Encrypted storage of identity documents and sensitive KYC materials

8. Cookies & Tracking Technologies

ef77 uses cookies and similar tracking technologies to operate the platform, maintain your session, and improve the user experience. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function, including session management, login authentication, and security tokens. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language, preferred payment method, and last-used game categories. These improve your experience but are not essential.
• Analytics cookies: Collect anonymised data about how users navigate ef77, which pages are visited most frequently, and where technical errors occur. This data is used to improve the platform.
• Marketing cookies: Used only where you have consented to receive personalised promotional content from ef77. These can be disabled via your account preferences or by contacting support.

You may control cookie settings through your browser settings. Disabling strictly necessary cookies may prevent you from logging in or using core ef77 features.

9. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data held by ef77:

• Right of access: Request a copy of the personal data ef77 holds about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ef77's legal retention obligations.
• Right to restrict processing: Request that ef77 limit its processing of your data in certain circumstances.
• Right to data portability: Request a structured, machine-readable copy of the personal data you have provided to ef77.
• Right to withdraw consent: Where ef77 processes your data on the basis of consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: Object to ef77's processing of your data for legitimate interests purposes, including direct marketing.

To exercise any of these rights, contact ef77 at [email protected]. ef77 will respond to valid requests within 30 days. ef77 may request identity verification before processing certain data requests to prevent unauthorised access to your personal information.

10. Minors & Age Restrictions

ef77 is strictly an 18+ platform. ef77 does not knowingly collect personal data from persons under the age of 18. If ef77 discovers that it holds personal data belonging to a person under 18, that data will be deleted immediately and the associated account closed.

If you are a parent or guardian and believe a minor has created an ef77 account or otherwise submitted personal data to ef77, please contact [email protected] immediately with details of the account so that ef77 can investigate and take appropriate action.

11. Changes to This Policy

ef77 may update this Privacy Policy from time to time to reflect changes in its data practices, applicable law, or platform features. When ef77 makes material changes to this Policy, it will:

• Update the "Last Updated" date at the top of this page
• Display a notice to logged-in users on their next session following the update
• Where required, seek fresh consent for new processing activities

Continued use of the ef77 platform following publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. ef77 recommends reviewing this page periodically to stay informed of any updates.

12. Contact & Data Requests

For all privacy-related enquiries, data access requests, consent withdrawals, or concerns about ef77's data practices, please contact the ef77 data team:

ef77 takes all privacy concerns seriously. If you are unsatisfied with ef77's handling of your data request, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.