Privacy Policy

01 Introduction

XP777 ("Platform", "we", "us", "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the XP777 platform at xp777.cam, including all associated mobile applications and sub-domains (collectively, the "Platform"). This Privacy Policy ("Policy") describes our data handling practices in clear, accessible English.

This Policy applies to all users of XP777, including registered account holders and visitors who browse the Platform without registering. By using XP777, you acknowledge that you have read and understood this Policy and that you consent to the data practices described herein, to the extent that consent is the applicable legal basis for a particular processing activity.

XP777 is an English-language online gaming platform targeting users in the Pakistan market — including players in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. While this Policy is written with Pakistani users in mind, it applies globally to all Platform users.

02 Definitions

03 Personal Data We Collect

3.1 Registration & Account Data

When you create a XP777 account, we collect:

• Full legal name
• Date of birth (for age verification)
• Residential address (including city — e.g., Karachi, Lahore, Islamabad)
• Email address
• Mobile telephone number
• Chosen username and encrypted password
• Preferred currency (e.g., PKR)

3.2 Identity Verification (KYC) Data

To comply with our KYC and AML obligations, we may collect:

• Government-issued photo identification — for Pakistani users, this typically means a copy of your Computerized National Identity Card (CNIC)
• Proof of residential address (e.g., a utility bill or bank statement dated within three months)
• Proof of payment method ownership (e.g., a screenshot or statement confirming the payment account is in your name)
• Source of funds documentation where required by platform policy or AML procedure

3.3 Financial Transaction Data

We collect data related to deposits and withdrawals, including:

• Transaction amounts in PKR or other supported currencies
• Payment method type (e.g., bank transfer, mobile wallet — including contextual references to services such as Easypaisa, JazzCash or Raast where relevant to the transaction)
• Transaction timestamps and reference numbers
• Account balance history for fraud prevention and AML purposes

3.4 Technical & Usage Data

We automatically collect the following technical information when you access the Platform:

• IP address and approximate geographic location
• Device type, operating system and browser version
• Session timestamps, pages visited and features used
• Game play history and betting activity
• Referring URL and exit page
• Cookie identifiers and similar tracking data (see Section 8)

3.5 Support & Communications Data

When you contact XP777 via Live Chat, email or the Help Centre, we collect the content of your communications and any attachments you send. This data is used to resolve your enquiry, improve support quality and, where relevant, for dispute resolution.

04 How We Collect Your Data

XP777 collects Personal Data through the following channels:

• Direct provision: Data you actively provide during registration, KYC submission, payment initiation or when contacting support;
• Automated collection: Technical and usage data collected automatically through cookies, server logs and similar technologies when you access the Platform;
• Third-party sources: Data received from KYC verification partners, fraud prevention services and payment processors in connection with transaction processing and identity verification;
• Public sources: In limited circumstances related to AML compliance, we may reference publicly available information to verify identity or assess risk.

05 How We Use Your Data (Data Processing)

XP777 processes your Personal Data for the following purposes:

06 Legal Basis for Processing

Where applicable data protection law requires a legal basis for processing Personal Data, XP777 relies on the following bases:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing and service delivery;
• Legal obligation: Processing required to comply with applicable law, including KYC/AML obligations and regulatory data retention requirements;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gambling monitoring and service improvement, where these interests do not override your rights;
• Consent: Where consent is the applicable basis — for example, for optional marketing communications — we will obtain your explicit opt-in consent and provide a clear mechanism to withdraw it at any time.

07 Data Sharing & Disclosure

7.1 Service Providers

XP777 shares Personal Data with third-party service providers that assist in delivering the Platform — including payment processors, KYC verification partners, fraud prevention providers, game studios, technical infrastructure providers and customer support platforms. All such providers are contractually bound to process data only on XP777's instruction and in accordance with data protection standards consistent with this Policy.

7.2 No Sale of Personal Data

XP777 does not sell, rent, trade or otherwise commercially transfer your Personal Data to third-party marketers or data brokers. Data sharing is limited to what is functionally necessary to operate the Platform and deliver the services you use.

7.3 Legal Requirements

XP777 may disclose Personal Data to law enforcement agencies, regulatory authorities or other government bodies where required by applicable law, court order or legally binding regulatory direction. We will endeavor to notify you of such disclosure where we are legally permitted to do so.

7.4 Business Transfers

In the event of a merger, acquisition, sale of assets or other corporate restructuring involving XP777, Personal Data held by the Platform may be transferred to the relevant successor entity as part of that transaction. You will be notified of any such transfer and any material change to this Policy that results from it.

08 Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by the XP777 Platform. They allow the Platform to recognise your browser across sessions, remember your preferences, and gather usage analytics. Similar technologies — such as web beacons, pixel tags and local storage — may also be used for comparable purposes.

8.2 Types of Cookies Used

8.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Most major browsers allow you to block or delete cookies via their privacy or security settings. Please note that disabling certain cookies may affect Platform functionality, including session persistence and preference recall. Instructions for managing cookies vary by browser — refer to your browser's help documentation for specific guidance.

09 Data Security

XP777 implements appropriate technical and organizational measures to protect your Personal Data against unauthorized access, alteration, disclosure or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the Platform;
• Secure password hashing — passwords are not stored in plain text;
• Role-based access controls limiting staff access to Personal Data on a need-to-know basis;
• Regular security assessments and monitoring for suspicious access patterns;
• Encrypted storage for Sensitive Data including KYC identity documents;
• Two-factor authentication (2FA) options for user account login where supported.

No system is completely impenetrable. While XP777 takes reasonable and proportionate steps to secure your data, we cannot guarantee absolute security against all threats. In the event of a data breach that is likely to result in a risk to your rights and freedoms, XP777 will notify affected users in accordance with applicable law.

10 Data Retention

XP777 retains Personal Data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active account data: Retained for the duration of your account's active status plus any mandatory retention period required by applicable law after account closure;
• KYC documentation: Retained for the minimum period required by the AML regulations applicable to the jurisdiction in which XP777 operates — typically five years from the date of the last transaction or account closure, whichever is later;
• Financial transaction records: Retained for the period required by applicable financial record-keeping and AML law;
• Support and communications records: Retained for a reasonable period sufficient to resolve disputes and improve service quality — generally up to three years from the date of the communication;
• Marketing opt-in data: Retained until you withdraw your consent or the Platform determines the data is no longer required.

When data is no longer required, XP777 will securely delete or anonymize it in accordance with its data lifecycle procedures.

11 Your Data Rights

Subject to the laws applicable to the jurisdiction in which XP777 operates and, where relevant, applicable data protection frameworks, you have the following rights in relation to your Personal Data:

12 Minors & Age Policy

The XP777 Platform is strictly intended for adults. You must be at least 18 years of age — or the higher minimum age required by the operator's license jurisdiction — to register an account or use any real money gaming services.

XP777 does not knowingly collect Personal Data from individuals under the applicable minimum age. If we become aware that a registered user is below the minimum age, we will immediately suspend the account, conduct an age verification review, withhold any associated funds pending investigation and, if confirmed, permanently close the account.

If you are a parent or guardian and believe that a minor has registered an account on XP777, please contact our support team immediately via Live Chat or email so that we can investigate and take appropriate action.

13 International Data Transfers

XP777 operates as an international platform and may transfer Personal Data to servers or service providers located outside Pakistan. Where such transfers occur, XP777 ensures that appropriate safeguards are in place to protect your data — including contractual protections with service providers and, where applicable, transfer mechanisms consistent with the data protection standards of the jurisdiction in which XP777 operates.

By using the XP777 Platform, you acknowledge that your Personal Data may be transferred to, stored and processed in jurisdictions outside Pakistan that may not apply the same data protection standards as those in your home country. We apply consistent data protection practices regardless of where data is processed.

14 Policy Updates & Amendments

XP777 reserves the right to update or amend this Privacy Policy at any time. Where material changes are made — such as changes to the categories of data collected, the purposes for which it is used, or the third parties with whom it is shared — XP777 will provide reasonable notice to registered users through the Platform or via email to your registered address.

The effective date at the top of this document will be updated to reflect the date of the most recent revision. Your continued use of the Platform following publication of an amended Policy constitutes your acceptance of the revised terms.

We encourage you to review this Policy periodically. If you disagree with any updated provisions, please discontinue use of the Platform and contact support to close your account.

15 Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact the XP777 team through the following channels:

• Live Chat: Available 24/7 directly on the XP777 Platform — fastest response channel
• Help Centre: Self-service guides covering account, payment, privacy and security topics
• Email: [email protected] — displayed as plain text only; this is not a clickable link

Support is provided in English as the primary language. Urdu-language assistance may be available during select hours for Pakistani users. For data rights requests, please include your registered email address and account details (do not include your password) so we can verify your identity and process your request promptly.