Section 01
Introduction
This Privacy Policy ("Policy") is issued by ef77 ("ef77", "we", "us", "our") and applies to all personal data collected from individuals ("you", "your", "Player") who register for, access, or use the ef77 online gaming platform, including the website, mobile-optimised interface, all casino games, sports betting markets, card game sections, and any related customer support services.
ef77 is Pakistan's premier online casino and sports betting platform, serving players across Karachi, Lahore, Faisalabad, Islamabad, Rawalpindi, and throughout Pakistan. Given the nature of ef77's services — which involve real-money transactions processed through JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT — the collection and responsible handling of certain personal data is a necessary operational requirement.
By registering an ef77 account or using any ef77 service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read alongside ef77's Terms and Conditions, which govern your use of the platform generally.
Note for Pakistani Players: ef77 recognises that data privacy is a genuine concern for Pakistani users. This Policy is written to be as clear and specific as possible about exactly what data is collected and why — not as a legal shield but as a genuine commitment to transparency with our players.
Section 02
Data Controller
For the purposes of applicable data protection law, ef77 is the data controller in respect of personal data collected from Pakistani players through the ef77 platform. ef77 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is conducted lawfully, fairly, and transparently in accordance with this Policy.
ef77 operates under an internationally recognised gaming licence and is subject to the data protection and anti-money laundering requirements of its licensing jurisdiction. These regulatory obligations directly inform several of ef77's data collection and retention practices, particularly in relation to identity verification (KYC) and financial transaction records.
Where ef77 engages third-party data processors — such as payment service providers, game software suppliers, or fraud detection services — those processors act on ef77's instructions and are bound by contractual obligations to process personal data only as directed by ef77 and to maintain appropriate security standards.
Section 03
Personal Data We Collect
3.1 Data You Provide Directly
When you register an ef77 account, use the platform, or contact ef77 support, you provide data directly to ef77. This includes:
- Registration information: Your full legal name, date of birth, Pakistani mobile number, and chosen password;
- KYC documents: Where requested, copies of your Pakistani National Identity Card (CNIC or NICOP), passport, or other identity documents, together with proof of address documents such as recent utility bills or bank statements from recognised Pakistani financial institutions;
- Payment information: Details necessary to process deposits and withdrawals, including your JazzCash or EasyPaisa mobile wallet identifier, HBL, UBL, or Meezan Bank account details, or USDT wallet address;
- Support communications: Content of your communications with ef77's customer support team, including live chat transcripts and email correspondence;
- Responsible gaming declarations: Any self-exclusion requests, deposit limit instructions, or other responsible gaming tool activations.
3.2 Data Collected Automatically
When you access and use ef77, certain technical and usage data is collected automatically through standard web technologies:
- Technical data: Your IP address, device type (mobile, desktop, tablet), operating system, browser type and version, and connection type;
- Session data: Login timestamps, session duration, pages visited within ef77, and features accessed;
- Gameplay data: Games played, bet amounts placed, game outcomes, and in-game interactions;
- Cookie data: Information collected through cookies and similar tracking technologies as described in Section 9 of this Policy.
3.3 Data from Third Parties
ef77 may receive personal data about you from third parties in limited circumstances, including from payment service providers confirming transaction completion or failure, from fraud detection and identity verification services used to verify your KYC documents, and from regulatory bodies where we are legally required to obtain or cross-reference information as part of our anti-money laundering compliance obligations.
Section 04
Legal Basis for Processing Your Personal Data
ef77 processes your personal data on the following legal bases as recognised under applicable data protection law:
- Contractual necessity: Processing required to enter into and perform our contract with you — including account registration, payment processing, and the provision of gaming services;
- Legal obligation: Processing required to comply with legal and regulatory obligations applicable to ef77 as a licensed gaming operator, including Know Your Customer (KYC) verification, anti-money laundering (AML) record-keeping, and regulatory reporting;
- Legitimate interests: Processing conducted to pursue ef77's legitimate business interests, where those interests are not overridden by your rights — including fraud detection, platform security, responsible gaming monitoring, and service improvement analytics;
- Consent: Where ef77 seeks your specific consent for particular processing activities — such as sending you personalised promotional communications — such processing is conducted only upon obtaining your explicit consent, which you may withdraw at any time.
Section 05
How ef77 Uses Your Personal Data
ef77 uses the personal data collected from Pakistani players for the following purposes:
- Account management: Creating and maintaining your ef77 account, verifying your identity, and managing your account settings and preferences;
- Service delivery: Providing access to all ef77 gaming services — casino games, live dealer tables, sports betting markets including PSL and cricket, slot games, Slide, Callbreak, and all other platform features;
- Payment processing: Processing deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and USDT, and processing withdrawal requests back to your verified payment method;
- Regulatory compliance: Fulfilling ef77's obligations under the regulations of its licensing jurisdiction, including age verification, KYC, AML screening, and regulatory reporting;
- Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, bonus abuse, and other prohibited activities on the ef77 platform;
- Responsible gaming: Monitoring gameplay patterns that may indicate problem gambling behaviour, administering self-exclusion requests, enforcing deposit and session limits, and ensuring compliance with ef77's responsible gaming obligations;
- Customer support: Responding to your queries, complaints, and disputes through ef77's live chat and email support channels;
- Platform improvement: Analysing aggregated usage data to understand how Pakistani players interact with ef77 and to improve the platform's features, performance, and game selection;
- Marketing communications: Where you have provided consent or where permitted under applicable law, sending you information about ef77 promotions, bonuses, and new games. You may opt out of marketing communications at any time.
Section 06
Sharing Your Personal Data
ef77 does not sell, rent, or trade your personal data. We share your data with third parties only in the following strictly limited circumstances:
6.1 Service Providers and Data Processors
ef77 engages carefully selected third-party service providers who process personal data on ef77's behalf and under ef77's instructions. These include payment processors facilitating JazzCash, EasyPaisa, and bank transfer transactions; game software providers whose technology powers ef77's casino and sports betting services; identity verification and KYC service providers; fraud detection and cybersecurity service providers; and cloud hosting and data storage providers. All such processors are bound by contractual data processing agreements that restrict their use of your data to the specified purpose only.
6.2 Regulatory and Legal Disclosure
ef77 may disclose your personal data to regulatory authorities, law enforcement agencies, courts, or other public bodies where required by applicable law, regulatory obligation, or valid legal process. Such disclosures may include responses to AML regulatory enquiries, court orders, fraud investigation requests, or mandatory regulatory reporting obligations under ef77's gaming licence.
6.3 Business Transfers
In the event that ef77 undergoes a business restructuring, merger, acquisition, or sale of assets, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer that materially affects your privacy rights, and the successor entity will be required to honour the commitments set out in this Policy.
No Advertising Sales: Under no circumstances does ef77 share Pakistani players' personal data with third-party advertisers, data brokers, social media platforms for targeting purposes, or any other party for commercial marketing activities unrelated to ef77's own services.
Section 07
International Data Transfers
Given the international nature of ef77's operations and the use of global third-party service providers — including game software suppliers, cloud infrastructure providers, and fraud detection services — your personal data may be transferred to and processed in countries outside Pakistan. ef77 ensures that any such international transfer is conducted in compliance with applicable data protection requirements, including through the use of appropriate contractual safeguards with receiving parties.
Where your data is transferred to a jurisdiction with a different level of data protection than that applicable in ef77's licensing jurisdiction, ef77 implements appropriate safeguards to ensure your data remains protected to the standards described in this Policy. If you have questions about specific international transfers of your data, you may contact ef77 using the details in Section 15.
Section 08
Data Retention
ef77 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by legal or regulatory obligations. Specific retention considerations include:
- Active account data: Retained for the duration of your ef77 account and for a period of at least five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements applicable to ef77's gaming licence;
- Financial transaction records: Retained for a minimum of five (5) years as required by AML and gaming regulatory obligations, regardless of whether your account is active or closed;
- KYC documents: Retained for the period of your account plus five (5) years post-closure in accordance with regulatory requirements;
- Support communications: Retained for up to three (3) years from the date of the relevant communication unless a longer period is required for an ongoing dispute or investigation;
- Technical and usage logs: Typically retained for twelve (12) to twenty-four (24) months, after which they are deleted or anonymised.
Upon expiry of the applicable retention period, ef77 will securely delete or irreversibly anonymise your personal data. Anonymised data — from which all identifying information has been removed — may be retained indefinitely for statistical and platform improvement purposes.
Section 09
Cookies & Tracking Technologies
ef77 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small data files stored on your device when you access ef77. They serve several important functions:
- Essential cookies: Required for the platform to function — including maintaining your login session, remembering your language preferences, and ensuring platform security. These cannot be disabled without affecting your ability to use ef77;
- Functional cookies: Enable enhanced features such as remembering your game preferences, displaying your recent activity, and personalising certain aspects of your ef77 experience;
- Analytics cookies: Collect anonymised data about how Pakistani players use ef77 — which pages are visited most, where players spend the most time, and which features are most commonly used. This data informs platform improvements;
- Security cookies: Help ef77 identify unusual account activity, prevent session hijacking, and protect against CSRF attacks and other security threats.
Cookie Management: Most web browsers allow you to manage cookie settings, including blocking or deleting cookies. Please note that disabling essential cookies will significantly impair your ability to use ef77, as they are required for session management and platform security. You can typically manage cookie settings through your browser's privacy or settings menu.
ef77 does not use advertising tracking pixels or share cookie-derived data with third-party advertising networks. Analytics data derived from cookies is used exclusively for ef77's own platform improvement purposes.
Section 10
Your Data Rights
Subject to applicable law and the regulatory obligations that ef77 operates under, Pakistani players have the following rights in respect of their personal data held by ef77:
10.1 Right of Access
You have the right to request a copy of the personal data ef77 holds about you. ef77 will provide this information in a clear, structured format within a reasonable timeframe following a valid request. To exercise this right, contact ef77 support via live chat or at [email protected] with "Data Access Request" in your subject line.
10.2 Right to Rectification
If any personal data ef77 holds about you is inaccurate or incomplete, you have the right to request correction. For simple corrections such as updating a contact number, you can make changes directly in your ef77 account settings. For corrections to identity data, contact ef77 support with supporting documentation.
10.3 Right to Erasure
In certain circumstances, you have the right to request deletion of your personal data held by ef77. However, this right is subject to important limitations — ef77 is legally required to retain certain data (particularly KYC and financial transaction records) for the regulatory retention periods described in Section 8. Erasure requests will be assessed on a case-by-case basis and ef77 will inform you of any data that cannot be deleted due to legal obligations.
10.4 Right to Restrict Processing
In certain circumstances — such as where you contest the accuracy of data or have objected to processing — you may request that ef77 restrict processing of your personal data to storage only while the relevant issue is resolved.
10.5 Right to Object
Where ef77 processes your personal data on the basis of legitimate interests, you have the right to object to that processing. ef77 will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is necessary for legal claims. You have an unconditional right to object to processing of your data for direct marketing purposes.
10.6 How to Exercise Your Rights
To exercise any of the above rights, contact ef77's support team via live chat on the platform or by email at [email protected]. Please include your registered Pakistani mobile number and account username so we can identify your account. ef77 will respond to all data rights requests within a reasonable timeframe as required by applicable law. ef77 does not charge fees for data rights requests made in good faith.
Section 11
Children, Minors & the 21+ Requirement
ef77 is strictly prohibited for use by persons under 21 years of age. ef77 does not knowingly collect personal data from anyone under 21. If ef77 becomes aware that an account has been registered by or is being used by a person under 21, the account will be immediately suspended, all data will be reviewed, and the matter may be referred to relevant authorities.
Mandatory 21+ Enforcement: ef77 employs age verification at registration and through ongoing KYC checks. Providing false information about your age to register on ef77 is a serious breach of ef77's Terms and Conditions and may constitute fraud. If you are a parent or guardian and believe a minor has accessed ef77, contact us immediately at [email protected].
Section 12
Data Security
ef77 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:
- 256-bit SSL/TLS encryption for all data transmitted between your device and ef77's servers — the same encryption standard used by major Pakistani banks such as HBL, UBL, and Meezan Bank;
- Encryption at rest for stored personal data, ensuring that even in the event of a server-level breach, data remains protected;
- Role-based access controls ensuring that ef77 personnel can only access player data required for their specific operational function;
- Regular security audits and penetration testing conducted by independent cybersecurity professionals;
- Two-factor authentication (2FA) available to all Pakistani players to protect their own account access — ef77 strongly recommends enabling 2FA;
- Automated fraud and intrusion detection systems monitoring for unusual account activity, login anomalies, and potential data breaches.
In the unlikely event of a data breach that poses a significant risk to your rights and freedoms, ef77 will notify affected players and the relevant regulatory authority in accordance with applicable legal notification requirements.
Section 13
Third-Party Links
The ef77 platform may contain links to third-party websites or services — for example, links to game providers' information pages or payment method help pages. This Privacy Policy applies only to ef77 and does not govern the privacy practices of any third-party websites or services. ef77 is not responsible for the privacy practices, data collection, or content of any third-party site. You should review the privacy policy of any third-party site you visit independently of ef77.
Section 14
Changes to This Privacy Policy
ef77 may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, platform functionality, or our data processing practices. When we make material changes to this Policy, we will notify registered Pakistani players via a notice displayed on the ef77 platform and, where practicable, via direct communication to your registered contact details.
The "Last Reviewed" date at the top of this Policy indicates when it was most recently updated. We encourage you to review this Policy periodically. Your continued use of ef77 following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you disagree with any changes, you should cease using ef77 and may request account closure.
Section 15
Contact & Complaints
If you have any questions, concerns, or complaints about how ef77 handles your personal data, or if you wish to exercise any of your data rights described in Section 10, please contact ef77 through the following channels:
- Live Chat: Available 24/7 directly through the ef77 platform. This is the fastest way to reach ef77 for any privacy-related query from Pakistani players.
- Email: [email protected] — For data subject access requests, erasure requests, or formal privacy complaints, please include "Privacy Request" or "Data Complaint" in your subject line together with your registered mobile number or account username.
ef77 takes all privacy complaints seriously and will acknowledge your contact within a reasonable period and aim to resolve your complaint fully within thirty (30) days. Where a complaint cannot be resolved within that timeframe, ef77 will inform you of the expected resolution date and the reasons for any delay.
This Privacy Policy was last reviewed and updated on 1 January 2026. It supersedes all previous versions of ef77's Privacy Policy. Pakistani players who registered prior to this date should note that this updated Policy now governs the processing of their personal data by ef77.