ct77 Privacy Policy — How We Protect and Handle Your Personal Data

ct77 ("we", "us", "our") operates the online gaming platform accessible at ct77.lat, including all associated casino, sports betting, live dealer, and slot game services. We are committed to protecting the personal data of every individual who uses, registers with, or interacts with our platform.

This Privacy Policy describes how ct77 collects, processes, stores, discloses, and protects personal data in connection with the provision of our services. It applies to all users of ct77, regardless of their location or the device from which they access the platform. It is intended to be read in conjunction with ct77's Terms & Conditions, which govern the overall contractual relationship between ct77 and its users.

This Policy applies to personal data collected and processed by ct77 in the operation of its online gaming services. It does not govern the data practices of third-party payment providers, game studios, or other external services that may be accessible through or integrated with the ct77 platform, each of which maintains its own independent privacy practices.

ct77 collects personal data that is necessary and proportionate to the purpose for which it is collected. We do not collect personal data beyond what is required to operate the platform, verify user identity, process transactions, prevent fraud, and comply with applicable regulatory obligations. The categories of personal data we collect are as follows:

ct77 collects personal data through the following channels and methods:

• Direct Provision: Data you provide directly when registering a ct77 account, completing KYC verification, initiating deposits or withdrawals, contacting ct77 support, or submitting feedback or complaints.
• Automated Collection: Technical data automatically collected by ct77's systems when you access the platform — including IP address, device identifiers, browser characteristics, and session activity — through cookies, log files, and similar tracking technologies described further in Section 9.
• Payment Providers: Transaction confirmation data received from ct77's integrated payment providers, including JazzCash, EasyPaisa, and other accepted payment methods, sufficient to verify and reconcile deposit and withdrawal transactions.
• Game Studios and Platform Providers: Game session data generated through ct77's integrated game studio APIs during gameplay, including bet and outcome logs that are recorded in ct77's system for account management and dispute resolution purposes.
• Third-Party Verification Services: Where ct77 uses third-party KYC or fraud-screening services to validate identity documents or screen users against regulatory watchlists, such services may return data points that are recorded in your ct77 account record.

ct77 processes personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between ct77 and the user — including account management, payment processing, bet settlement, and support delivery — is conducted on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with applicable legal and regulatory obligations — including anti-money-laundering requirements, age verification mandates, and data retention obligations — is conducted on the basis of legal compliance.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring is conducted on the basis of ct77's legitimate interests in operating a secure, compliant, and sustainable gaming service, provided such interests are not outweighed by the data subject's rights.
• Consent: Processing for marketing communications and non-essential cookies is conducted on the basis of the user's freely given, specific, and informed consent, which may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

ct77 uses the personal data it collects for the following specific and documented purposes:

ct77 does not sell your personal data to third parties. We do not share your personal information for third-party marketing purposes without your explicit consent. We may, however, share your personal data with the following categories of recipients in the following circumstances:

• Payment Service Providers: We share transaction-relevant data with ct77's integrated payment providers — including JazzCash, EasyPaisa, and associated banking partners — solely to the extent necessary to process your deposits and withdrawals.
• Identity and KYC Verification Providers: Where ct77 uses third-party services to verify identity documents or conduct fraud screening, we share the minimum data necessary to complete the verification process. These providers are contractually bound to use your data only for the specified verification purpose.
• Game Studio Providers: Certain game activity data is shared with ct77's integrated game studio providers for the purpose of game delivery, outcome verification, and dispute resolution. Game studios receive only the data necessary to deliver their specific game services.
• Legal and Regulatory Authorities: We may disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where we are legally required to do so, or where we have a good-faith belief that such disclosure is necessary to prevent or investigate suspected criminal activity or protect the rights, property, or safety of ct77 or its users.
• Corporate Transactions: In the event of a merger, acquisition, or sale of ct77's business assets, personal data held by ct77 may be transferred to the acquiring entity, subject to equivalent data protection commitments being maintained. Users would be notified of any such transfer.

ct77 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to mandatory retention periods imposed by applicable laws and regulations. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. In cases where deletion is not immediately technically feasible, data is quarantined and access-restricted pending scheduled deletion.

ct77 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security programme includes, but is not limited to, the following measures:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and ct77's servers is encrypted using 256-bit SSL/TLS encryption — the same standard used by major global financial institutions. This prevents interception of data in transit on any network, including public Wi-Fi and mobile data connections.
• Encrypted Data Storage: Personal data stored in ct77's databases — including financial records, identity documents, and account credentials — is encrypted at rest using industry-standard encryption algorithms.
• Password Security: User passwords are stored using one-way cryptographic hashing. ct77 does not store passwords in readable form. Even in the event of an unprecedented database access incident, your password could not be retrieved by any party.
• Access Controls: Access to personal data within ct77's organisation is restricted on a strict need-to-know basis. Staff who can access personal data are subject to confidentiality obligations and regular security training.
• Anomaly Detection: ct77's security systems continuously monitor for unusual access patterns, suspicious login activity, and technical indicators of compromise or fraud, triggering automated and manual review where thresholds are met.
• Data Breach Response: In the event of a confirmed personal data breach that presents a material risk to users' rights, ct77 will notify affected users and relevant regulatory authorities within the timeframes required by applicable law, and will take immediate steps to contain and remediate the breach.

ct77 uses cookies and similar tracking technologies to deliver and improve the platform experience. Cookies are small text files stored on your device that allow ct77's systems to recognise your browser, maintain your session state, remember your preferences, and gather analytics data about how the platform is used.

You may configure your browser to block or delete cookies from ct77. Please note that disabling strictly necessary cookies will impair your ability to log in and use the platform. Most browsers provide cookie management settings in the Privacy or Security section of their preferences. Specific instructions vary by browser and device type.

Subject to applicable law and ct77's legitimate operational and regulatory obligations, you have the following rights with respect to your personal data held by ct77. To exercise any of these rights, submit a written request to [email protected] with sufficient information to verify your identity. ct77 will respond within a reasonable timeframe and no later than the period required by applicable law.

• Right of Access: You have the right to request a copy of the personal data ct77 holds about you, along with information about how it is used, the categories of recipients with whom it has been shared, and the applicable retention periods.
• Right to Rectification: You have the right to request correction of inaccurate or incomplete personal data. Where possible, account details can be updated directly within your ct77 account settings or by contacting support.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and where no overriding legal obligation requires its retention. Please note that regulatory and legal data retention obligations (see Section 7) may prevent immediate deletion of certain data categories.
• Right to Restriction of Processing: You have the right to request that ct77 restrict the processing of your personal data in certain circumstances — for example, while a dispute regarding data accuracy is pending investigation.
• Right to Data Portability: Where processing is based on your consent or on contract performance, and is carried out by automated means, you have the right to receive your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You have the right to object to processing of your personal data based on ct77's legitimate interests. We will review such objections and cease the specific processing activity unless we can demonstrate compelling legitimate grounds that override your interests or the processing is necessary for legal claims.
• Right to Withdraw Consent: Where processing is based on your consent — such as marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal. Withdrawal of consent does not affect processing conducted on other legal bases.

ct77 employs age verification measures during account registration and KYC processes to prevent underage access. If ct77 becomes aware — through any means — that personal data has been collected from or that an account has been operated by an individual under the age of 21, the Account will be immediately suspended, all associated data will be quarantined, and the data will be deleted to the extent not required to be retained for fraud investigation or regulatory reporting purposes.

Parents and guardians who believe that a minor under their care may have accessed or registered with ct77 should contact us immediately at [email protected]. ct77 will investigate all such reports promptly and take immediate protective action.

As an internationally operating platform, ct77 may process and store personal data on servers located outside Pakistan. This may include transfers to jurisdictions where ct77's hosting infrastructure, payment processing partners, or KYC verification providers are based. Where such transfers occur, ct77 ensures that appropriate safeguards are in place to protect the security and integrity of your personal data to a standard equivalent to that described in this Privacy Policy.

Such safeguards may include contractual data protection clauses between ct77 and recipient entities, transfers to jurisdictions that maintain adequate data protection frameworks, or other legally recognised transfer mechanisms. By using the ct77 platform, you acknowledge that your data may be transferred internationally in accordance with these safeguards.

The ct77 platform integrates third-party game studio content and payment provider interfaces to deliver its services. These third-party services operate under their own independent privacy policies and data practices. ct77 is not responsible for the privacy practices or content of any third-party service provider accessed through or integrated with the ct77 platform.

ct77 recommends that users review the privacy policies of any third-party service they interact with — including JazzCash, EasyPaisa, and other payment providers — to understand how those entities handle personal data independently of ct77. ct77's Privacy Policy governs only data that ct77 itself collects, controls, and processes in connection with the delivery of ct77's services.

ct77 reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, applicable laws, regulatory requirements, or the services we provide. The "Effective Date" at the top of this Policy reflects the date of the most recent revision.

Where amendments are material — meaning they meaningfully affect how we collect, use, or share your personal data — ct77 will provide advance notice via account notification or email to your registered contact address, where applicable. Your continued use of the ct77 platform following the effective date of an amended Privacy Policy constitutes your acceptance of the revised terms.

For any questions, requests, or concerns relating to this Privacy Policy, your personal data held by ct77, or any data subject rights exercise, please contact ct77 through the following channels:

• Email: [email protected] — for data access requests, erasure requests, rectification requests, consent withdrawal, and privacy complaints. Please include your registered account details and a clear description of your request to enable prompt processing.
• Live Chat: Available 24/7 via the ct77 website — for urgent privacy concerns, suspected unauthorised account access, and initial triage of data requests.

ct77 is committed to resolving all privacy queries and data subject rights requests promptly, transparently, and in accordance with applicable law. We will acknowledge receipt of all written data requests within 5 business days and provide a substantive response within the timeframe required by applicable law, and no later than 30 days from the date of a verified request.