Privacy Policy

Introduction

This Privacy Policy ("Policy") describes how RS77 ("RS77", "we", "us", "our"), the operator of the website accessible at rs77.cam and all associated mobile-optimised interfaces (collectively, the "Platform"), collects, uses, stores, shares and protects the personal data of individuals who register, access or otherwise interact with the Platform ("Users", "you").

By creating an account on the Platform or continuing to use our services, you confirm that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform and request account closure.

Definitions

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information that relates to an identified or identifiable natural person, including name, email address, national identity number, financial details and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, erasure or destruction.
• "Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, RS77.
• "Processor" means any third party that processes Personal Data on behalf of RS77 under a contractual arrangement.
• "Consent" means any freely given, specific, informed and unambiguous indication of your agreement to the processing of your Personal Data for a stated purpose.
• "KYC" (Know Your Customer) means the identity verification process conducted to confirm a User's identity, age and payment method ownership.
• "Cookie" means a small text file placed on your device by the Platform for functional, analytical or similar purposes as described in Section 7.

Data We Collect

RS77 collects Personal Data through several means. The categories of data collected are set out below:

3.1 Data You Provide Directly

• Registration information: name, email address, date of birth, username, password;
• Identity verification documents submitted during KYC: government-issued CNIC, passport or equivalent;
• Proof of address documentation: utility bills or bank statements;
• Payment information: account or wallet details used for deposits and withdrawals — note that full payment credentials are handled by our payment processing partners and are not stored on RS77 servers;
• Communications: messages sent to our support team via live chat or email.

3.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version;
• Usage data: pages viewed, features used, betting activity, session duration and navigation paths;
• Location data: approximate geographic location derived from IP address;
• Cookie and tracking data: as described in Section 7.

How We Use Your Data

RS77 processes your Personal Data for the following purposes:

• Account Management: creating and maintaining your account, verifying your identity through KYC, and enabling access to Platform features;
• Transaction Processing: processing deposits, withdrawals and related payment administration;
• Legal and Regulatory Compliance: fulfilling obligations under applicable law, including anti-money laundering (AML) checks, fraud prevention and responsible gambling requirements;
• Security: detecting and preventing unauthorised access, fraud, exploitation of bonuses, collusion and other prohibited conduct;
• Customer Support: responding to enquiries, complaints and account-related requests submitted through live chat or email;
• Service Improvement: analysing aggregated usage data to improve Platform functionality, content and user experience;
• Communications: sending service-related notifications such as transaction confirmations, security alerts and policy updates — these are not optional as they are necessary to operate the account;
• Marketing (where separately consented): sending promotional communications about RS77 offers, if you have opted in. You may opt out of marketing communications at any time by contacting support.

Legal Basis for Processing

RS77 processes your Personal Data on the following legal bases, consistent with applicable data protection principles:

• Contractual Necessity: Processing required to fulfil the agreement between you and RS77 — account creation, transaction processing and KYC verification;
• Legal Obligation: Processing required to comply with applicable law, including AML obligations and responsible gambling regulations;
• Legitimate Interests: Processing for fraud prevention, security, platform integrity, and service improvement, where those interests are not overridden by your rights;
• Consent: Marketing communications and any non-essential cookie usage, where your explicit consent has been obtained.

Data Sharing & Disclosure

RS77 does not sell your Personal Data. We may share your data with the following categories of recipients only where strictly necessary:

• Payment Processors: Third-party providers who handle transaction processing on behalf of RS77. These processors operate under contractual data protection obligations. References to payment services familiar to Pakistani users — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are contextual only and do not imply these providers receive your data through RS77;
• Identity Verification Providers: Third-party KYC and AML service providers engaged to verify user identities in compliance with applicable obligations;
• Technology and Infrastructure Providers: Cloud hosting, platform software, and security service providers who process data on RS77's behalf under data processing agreements;
• Regulatory and Law Enforcement Authorities: Where required by applicable law, court order or regulatory demand, RS77 may be required to disclose Personal Data to competent authorities;
• Fraud Prevention and AML Bodies: Where fraud, money laundering or other prohibited conduct is suspected, relevant information may be shared with appropriate prevention and detection organisations.

Cookies & Tracking Technologies

RS77 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management, authentication tokens and security cookies. These cannot be disabled without affecting core functionality;
• Functional Cookies: Used to remember your preferences such as language settings and session-related user interface choices;
• Analytical Cookies: Used to collect anonymised data about how users navigate the Platform, helping us identify areas for improvement. Where non-essential, these are activated only with your consent;
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic and abuse.

7.2 Managing Cookies

You may configure your browser to refuse all or some cookies. Disabling strictly necessary cookies may impair your ability to use the Platform. Instructions for managing cookies are available in your browser's help documentation.

Data Retention

RS77 retains Personal Data for as long as is required to fulfil the purposes described in this Policy, including compliance with legal and regulatory obligations. The following general retention principles apply:

• Account data and transaction records are retained for a minimum period required by applicable AML, tax and gambling regulations in the operator's licensing jurisdiction — typically a minimum of five years from account closure;
• KYC documentation is retained in accordance with applicable identity verification and AML requirements;
• Support communications are retained for a period sufficient to manage ongoing disputes and regulatory requirements;
• Marketing consent records are retained for as long as the relevant consent is relied upon, plus a reasonable period thereafter for compliance evidence.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised so that it can no longer be associated with an identified individual.

Data Security

RS77 implements appropriate technical and organisational measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• Encrypted storage for sensitive personal and financial data at rest;
• Access controls restricting internal access to Personal Data on a need-to-know basis;
• Regular security assessments and monitoring of Platform systems;
• Employee training on data protection obligations.

No system can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, RS77 will take steps to notify affected users and, where legally required, the relevant supervisory authority, within applicable timeframes.

Your Rights

Subject to applicable data protection law, you hold the following rights regarding your Personal Data held by RS77. Requests to exercise these rights should be submitted via live chat support or to the email address listed in Section 15.

RS77 will aim to respond to all rights requests within 30 days. In complex cases this period may be extended by a further two months, in which case you will be notified. We will not charge a fee for handling rights requests unless they are manifestly unfounded or excessive.

Minors

The Platform is strictly intended for adults aged 18 and over, or the higher minimum age required by the applicable operator or license jurisdiction. RS77 does not knowingly collect Personal Data from individuals under the age of 18. If RS77 discovers or reasonably suspects that a registered user is under 18, the account will be suspended immediately, all activity will be reviewed and any funds will be returned in accordance with our Terms and applicable law, pending investigation.

If you are a parent or guardian and believe your child has registered an account with RS77, please contact us immediately via live chat so that appropriate action can be taken without delay.

International Data Transfers

RS77 operates internationally and your Personal Data may be processed in countries outside your country of residence, including countries that may not have data protection laws equivalent to those in your jurisdiction. Where such transfers occur, RS77 will take appropriate steps to ensure that your Personal Data is protected to a standard consistent with this Policy, including through contractual safeguards with data processors.

By using the Platform, you acknowledge that your Personal Data may be transferred, stored and processed in other jurisdictions.

Third-Party Services

The Platform may reference third-party services in a contextual capacity — for example, payment methods familiar to Pakistani users such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah. These references are informational only. RS77 is not responsible for the privacy practices of third-party providers. If you use any third-party service in connection with your RS77 account, you should review that provider's privacy policy independently.

RS77 does not embed social media sharing buttons, third-party advertising networks or unrelated third-party scripts on the Platform that would enable those parties to collect your data through their own mechanisms without your knowledge.

Policy Amendments

RS77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, our data processing activities or Platform features. Where changes are material, registered users will be notified by email or via an in-platform notification prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following any update constitutes your acceptance of the revised Policy. We recommend reviewing this page periodically.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to make a complaint about RS77's data practices, please contact us through the following channel: