cx77 Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") is issued by cx77 ("cx77", "we", "us", "our") and governs the collection, use, storage, disclosure and protection of personal data relating to registered users ("User", "you", "your") and visitors to the cx77 online platform accessible at https://cx77.cam (the "Platform").

cx77 is committed to protecting your privacy and handling your personal data with transparency, integrity and care. This Policy is designed to clearly inform you of your rights and our obligations with respect to your personal information.

By registering an account, accessing the Platform or using any of our services, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy.

2. Definitions

In this Policy, the following terms carry the meanings set out below:

Term	Meaning
"Personal Data"	Any information relating to an identified or identifiable natural person, including name, email address, date of birth, device identifiers and transactional data.
"Processing"	Any operation performed on personal data, including collection, recording, storage, use, disclosure, erasure or destruction.
"Data Controller"	cx77, which determines the purposes and means of processing personal data collected through the Platform.
"Data Processor"	A third party that processes personal data on behalf of cx77 under a data processing agreement.
"Consent"	A freely given, specific, informed and unambiguous indication of agreement to processing of personal data for a stated purpose.
"KYC Data"	Identity and address verification documents submitted as part of the Know Your Customer process, including CNIC, passport and proof-of-address documents.
"Special Category Data"	Sensitive personal data such as health information or financial vulnerability indicators, which attracts additional processing safeguards.

3. Data We Collect

cx77 collects the following categories of personal data:

3.1 Identity & Registration Data

• Full legal name, date of birth and gender.
• Username and encrypted account password.
• Nationality and country of residence, including city (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Peshawar, Faisalabad or Multan).

3.2 Contact Data

• Email address (primary account identifier and communications channel).
• Mobile phone number (used for account verification and security alerts).
• Residential address (where required for KYC or enhanced due diligence purposes).

3.3 KYC & Verification Data

• Copies of government-issued identity documents — for Pakistani users, this is primarily a valid CNIC or current passport.
• Proof of address documents where required by the KYC process.
• Selfie or liveness-check images captured during identity verification.
• Payment method verification screenshots (e.g., wallet account name for Easypaisa or JazzCash — provided for verification only; cx77 does not store full payment credentials).

3.4 Financial & Transaction Data

• Deposit and withdrawal amounts, methods and timestamps.
• Betting and gaming transaction history, including stakes, outcomes and running balance.
• Bonus and promotion activity records.

3.5 Technical & Usage Data

• IP address, device type, operating system and browser information.
• Session duration, pages visited, features used and interaction logs.
• Geolocation data (country/region level, derived from IP address).
• Cookie identifiers and tracking pixel data where applicable.

3.6 Communication Data

• Records of support tickets, live chat transcripts and email correspondence.
• Complaint records and dispute documentation.
• Marketing communication preferences and opt-in/opt-out records.

4. How We Collect Your Data

We collect personal data through the following means:

• Direct submission: Information you provide when registering, completing KYC, making deposits or withdrawals, or contacting support.
• Automated collection: Technical data collected automatically as you use the Platform, including via cookies, server logs and analytics tools.
• Third-party verification services: Identity verification results returned by KYC and anti-fraud service providers engaged by cx77.
• Payment processors: Transaction confirmation and status data returned by payment processing partners (not full payment credentials).
• Publicly available sources: Sanctions lists, politically exposed persons (PEP) databases and fraud-prevention registries where AML obligations apply.

5. Lawful Basis for Processing

cx77 processes personal data only where a lawful basis exists. The primary lawful bases applied to our processing activities are:

Lawful Basis	Processing Activities
Contract Performance	Registering and operating your account; processing deposits, withdrawals and bets; providing customer support.
Legal Obligation	KYC and AML compliance; age verification; fraud prevention; regulatory reporting obligations.
Legitimate Interest	Platform security; fraud detection; abuse prevention; service improvement analytics; responsible gambling monitoring.
Consent	Marketing communications by email or push notification; optional analytics beyond core service operation; placement of non-essential cookies.

6. How We Use Your Data

cx77 uses collected personal data for the following purposes:

• Creating, verifying and managing your account, including identity and age verification.
• Processing financial transactions — deposits and withdrawals — and maintaining accurate account ledgers.
• Complying with anti-money laundering (AML), counter-terrorism financing (CTF), and fraud prevention obligations.
• Operating responsible gambling tools including deposit limit enforcement, session monitoring, loss-limit controls and self-exclusion.
• Providing customer support and resolving complaints or disputes.
• Sending service communications such as deposit confirmations, withdrawal notices, security alerts and account status updates — these cannot be opted out of while an account is active.
• Sending marketing communications where you have provided explicit consent — you may withdraw this consent at any time.
• Analysing Platform usage to improve user experience, identify technical issues and develop new features.
• Detecting and preventing fraudulent, abusive or illegal activity on the Platform.

7. Data Sharing & Disclosure

cx77 does not sell, rent or trade your personal data. We share data only in the following circumstances and only to the minimum extent necessary:

7.1 Service Providers & Data Processors

We engage third-party data processors under contractual data processing agreements. These processors include KYC and identity verification providers, payment processing partners, cloud hosting and infrastructure providers, fraud detection and analytics services, and customer support platform operators. Each processor is bound to process data only on our documented instructions and to maintain appropriate technical and organisational security measures.

7.2 Legal & Regulatory Disclosure

We may disclose personal data to competent authorities, law enforcement bodies, licensing regulators or financial intelligence units where required by applicable law, court order or regulatory obligation. We will, where legally permitted, notify affected users of such disclosures.

7.3 Business Transfers

In the event of a merger, acquisition, sale of assets or restructuring, personal data held by cx77 may be transferred to the successor entity, subject to equivalent privacy protections being maintained. Affected users will be notified before their data is transferred and becomes subject to a materially different privacy policy.

7.4 Payment References

Payment method references on the cx77 Platform — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are cited for user familiarity only. cx77 does not share your personal data with these providers unless directly required to process an authorised transaction you have initiated. None of these providers endorse cx77 or are data-sharing partners.

8. International Data Transfers

cx77 operates servers and engages service providers that may be located outside Pakistan. When your personal data is transferred internationally, cx77 implements appropriate safeguards including standard contractual clauses or equivalent mechanisms to ensure an adequate level of protection consistent with applicable data protection standards.

Pakistani users should be aware that Pakistan's Personal Data Protection Act (PDPA), to the extent enacted and in force, may govern the handling of personal data of Pakistani residents. cx77 endeavours to process data in a manner consistent with applicable data protection principles. This is not legal advice; please consult a qualified legal professional for advice specific to your situation.

9. Cookies & Tracking Technologies

cx77 uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies we use are as follows:

Cookie Type	Purpose	Consent Required
Strictly Necessary	Session management, authentication, security tokens, load balancing. The Platform cannot function without these.	No — essential
Functional	Remembering your language preference, display settings and responsible gambling tool configurations.	No — core functionality
Analytics	Aggregated, anonymised usage data used to understand navigation patterns and improve Platform performance.	Yes — opt-in
Marketing	Personalised promotional content and conversion tracking. Used only where you have given explicit consent.	Yes — opt-in

You may manage your cookie preferences at any time through your browser settings. Disabling certain cookies may affect Platform functionality. Strictly necessary cookies cannot be disabled without preventing access to core services.

10. Data Retention

cx77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulatory obligation. Indicative retention periods are set out below:

• Account and registration data: Retained for the lifetime of the account and for a minimum of five years following permanent account closure, in line with AML regulatory requirements.
• KYC documents: Retained for the period required by applicable AML/CTF regulations from the date of the last transaction, typically five years.
• Transaction records: Retained for a minimum of five years following the date of each transaction.
• Support and complaint records: Retained for a minimum of three years from the date of resolution.
• Marketing data: Retained until consent is withdrawn; preference records retained for three years following withdrawal.
• Technical and log data: Typically retained for 12 months on a rolling basis, unless retained longer for active security investigations.

Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised in accordance with our internal data lifecycle procedures.

11. Data Security

cx77 implements technical and organisational security measures appropriate to the risk profile of the data processed. These measures include:

• TLS/SSL encryption for all data in transit between the Platform and user devices.
• Encryption of sensitive data at rest, including KYC documents and payment information.
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for staff accessing back-end systems containing personal data.
• Regular penetration testing and vulnerability assessments conducted by qualified third parties.
• Incident response procedures including mandatory breach notification processes where applicable.

12. User Rights

Subject to applicable law, you hold the following rights with respect to your personal data held by cx77:

To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request". We will acknowledge your request within 5 business days and respond substantively within 30 calendar days. Certain rights may be limited where overriding legal obligations require retention or processing to continue.

13. Minors & Age Protection

The cx77 Platform is strictly intended for adults. We do not knowingly collect or process personal data relating to individuals under the age of 18 years, or the higher minimum age required by the operator's license jurisdiction.

Age verification is enforced during the registration process and through our KYC procedures. Where cx77 discovers, following registration, that an account holder is under the applicable minimum age, the account will be immediately suspended, all activity voided, and any deposits will be returned to the depositing payment method following identity verification. The individual's data will be deleted as soon as it is no longer required for the purposes of the investigation and refund.

If you are aware of a minor who has gained access to the cx77 Platform, please notify us immediately at [email protected].

14. Specific Notice for Pakistani Users

Pakistani users should note the following in relation to the processing of their personal data:

• cx77 is not registered with, licenced by, or regulated under any Pakistani authority, including the Pakistan Telecommunication Authority (PTA) or the State Bank of Pakistan.
• Your personal data may be transferred to and processed in jurisdictions outside Pakistan. cx77 applies contractual safeguards to such transfers as described in Section 8.
• Pakistan's data protection framework is evolving. cx77 will endeavour to align its practices with applicable Pakistani data protection requirements as they develop.
• Payment method names referenced for Pakistani users — Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are cited purely as familiar local references. These providers are not data-sharing partners, affiliates or endorsers of cx77.
• This Policy does not constitute legal advice. If you have questions about your rights under Pakistani law, please consult a qualified legal professional.

15. Changes to This Policy

cx77 reserves the right to update this Privacy Policy at any time. Where changes are material — such as a significant new category of data collection or a new disclosure purpose — we will notify registered Users by email and/or by a prominent notice on the Platform at least 14 days before the changes take effect.

Minor changes (such as clarifications that do not alter the substance of how your data is handled) may be made without advance notice. The effective date at the top of this Policy will always reflect the date of the most recent update. Continued use of the Platform after a change becomes effective constitutes acceptance of the updated Policy.

16. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection team:

• Email: [email protected]
• Subject line for data rights requests: "Data Rights Request"
• Support Hours: 24 hours a day, 7 days a week
• Languages: English (primary); Urdu-speaking agents available on request

We aim to acknowledge all privacy-related inquiries within 48 hours and to provide a full substantive response within 30 calendar days of receipt. Where a request is complex or involves multiple rights, we may extend the response period by a further 30 days, in which case we will notify you of the extension and the reason.