Privacy Policy

1Introduction

This Privacy Policy ("Policy") describes how 4777sz ("we", "us", "our" or "Platform"), accessible at https://4777sz.cam, collects, uses, stores, shares and protects personal data relating to users of the Platform ("you", "your", "User"). This Policy applies to all personal data processed in connection with your use of the Platform, including data provided during account registration, KYC verification, payment processing and ongoing platform use.

4777sz is committed to handling personal data responsibly and in accordance with the data protection obligations applicable under the laws of the jurisdiction in which it holds its operating licence. Where you access the Platform from Pakistan, we note that the Personal Data Protection Bill and applicable data governance frameworks in Pakistan are subject to ongoing legislative development. We monitor applicable legal requirements and update our practices accordingly.

This Policy should be read alongside our Terms & Conditions and Responsible Gambling Policy. By accessing or using the Platform, you acknowledge that you have read, understood and agree to the data practices described in this Policy.

2Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, IP addresses, identity documents and financial data.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 4777sz.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller, under documented instructions.
• "KYC" means Know Your Customer — the identity and age verification process required before certain account actions can be completed.
• "AML" means Anti-Money Laundering — the regulatory and compliance framework governing the monitoring and reporting of suspicious financial transactions.
• "Cookie" means a small text file placed on your device by the Platform to enable functionality, remember preferences and support analytics.
• "Sensitive Personal Data" means a subset of Personal Data warranting additional protection, including identity document numbers, financial account details and biometric data submitted for KYC purposes.

3Data We Collect

3.1 Data You Provide Directly

We collect Personal Data that you provide to us in the course of registering for an account, completing KYC verification, using the Platform's services or communicating with our support team. This includes:

• Full legal name and date of birth;
• Residential address, including city (e.g. Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar) and country;
• Email address and contact telephone number;
• Government-issued identity documentation such as a CNIC, passport or other accepted identity document;
• Financial data including deposit and withdrawal method details — for example, account references associated with payment methods familiar to Pakistani users such as Easypaisa, JazzCash or Raast, or bank account details for HBL, UBL, Meezan Bank or Bank Alfalah. We note that these references are used solely for the purpose of processing transactions on your behalf; we do not represent that these providers endorse or facilitate gambling transactions;
• Support communications and correspondence submitted to our team.

3.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically, including:

• IP address and approximate geographic location derived from IP data;
• Device type, operating system and browser information;
• Session data including pages visited, time spent, click patterns and game play history;
• Cookie identifiers and similar tracking technologies (see Section 9);
• Referral source data indicating how you arrived at the Platform.

3.3 Data from Third Parties

We may receive Personal Data about you from third parties including:

• KYC and identity verification service providers who verify the documents you submit;
• Fraud prevention and AML screening services;
• Payment processors who confirm the outcome of deposit and withdrawal transactions.

4Legal Basis for Processing

We process your Personal Data on the following legal bases, as applicable to each processing activity:

5How We Use Your Data

4777sz uses Personal Data collected through the Platform for the following purposes:

5.1 Account Operations

To create and manage your user account, authenticate your identity at login, process deposits and withdrawals, apply bonus credits and maintain accurate account records.

5.2 Identity Verification and Compliance

To conduct KYC verification as required under our licensing obligations, screen accounts against AML watchlists, and comply with applicable regulatory requirements including reporting obligations to licensing authorities.

5.3 Responsible Gambling

To monitor account activity for indicators of problem gambling behaviour, enforce responsible gambling limits set by Users (including deposit limits, loss limits, cooling-off periods and self-exclusion), and to conduct proactive outreach where our systems identify patterns consistent with problematic gambling. Further information is available on our Responsible Gambling page.

5.4 Security and Fraud Prevention

To detect, investigate and prevent fraudulent activity, collusion, bonus abuse, money laundering and other forms of prohibited conduct as defined in our Terms & Conditions.

5.5 Communications

To send transactional communications related to your account — including deposit confirmations, withdrawal updates, KYC status notifications and important policy changes — and, where you have given consent, promotional communications about offers and new features.

5.6 Platform Improvement

To analyse aggregate usage patterns, identify areas for platform improvement, test new features and optimise the user experience across devices and connection types commonly used in Pakistan.

6Data Sharing & Disclosure

4777sz does not sell, rent or trade your Personal Data to third parties for their own commercial purposes. We share Personal Data only in the following circumstances:

6.1 Service Providers (Data Processors)

We engage trusted third-party service providers who process Personal Data on our behalf and under our documented instructions, subject to appropriate data processing agreements. These include:

• Payment gateway and transaction processing providers;
• Identity verification and KYC technology providers;
• Fraud screening and AML monitoring services;
• Cloud hosting and data storage providers;
• Customer support platform providers;
• Analytics and platform performance monitoring services.

6.2 Regulatory and Legal Disclosure

We may disclose Personal Data to licensing authorities, law enforcement agencies or other competent regulatory bodies where required to do so by applicable law, court order or regulatory direction. Such disclosures are made strictly to the extent required and are not subject to User consent.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of assets involving 4777sz, Personal Data held by the Platform may be transferred to the relevant successor entity. Users will be notified of any such transfer and the applicable privacy terms governing their data going forward.

6.4 Consent-Based Sharing

Where we wish to share Personal Data with third parties for purposes not described in this Policy, we will seek your explicit consent before doing so.

7International Data Transfers

Given that 4777sz operates under an international licensing framework and uses service providers located in various jurisdictions, your Personal Data may be transferred to and processed in countries outside Pakistan. Such countries may have data protection laws that differ from those applicable in Pakistan.

Where we transfer Personal Data internationally, we take steps to ensure that appropriate safeguards are in place to protect your data, including entering into data transfer agreements with recipient entities that incorporate equivalent data protection standards. Where relevant, we rely on the adequacy decisions, standard contractual clauses or equivalent mechanisms recognised under the data protection framework applicable to our licensing jurisdiction.

8Data Retention

We retain Personal Data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory and licensing obligations. The following general retention principles apply:

• Active account data: Retained for the duration of the account relationship and for a period thereafter as required by applicable licensing and AML regulations.
• KYC documentation: Retained in accordance with the minimum period required by our licensing authority, which is typically five years from the date of account closure or the date of the most recent transaction.
• Transaction records: Retained for the minimum period required by applicable financial regulation — generally five to seven years.
• Support communications: Retained for three years from the date of correspondence, or longer where related to an active dispute or regulatory matter.
• Marketing data: Retained until consent is withdrawn or the User opts out of marketing communications.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in accordance with our data disposal procedures.

9Cookies & Tracking Technologies

4777sz uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

9.1 Essential Cookies

These cookies are strictly necessary for the Platform to function. They enable core features such as session authentication, security controls and navigation. Essential cookies cannot be disabled without materially affecting your ability to use the Platform.

9.2 Functional Cookies

These cookies remember your preferences — such as language settings, display options and responsible gambling limit configurations — to provide a personalised experience across sessions.

9.3 Analytical Cookies

These cookies collect anonymised or aggregated information about how Users interact with the Platform, including pages visited, session duration and feature usage. This data is used to identify usability improvements and optimise the Platform for devices and network conditions common in Pakistan.

9.4 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling functional or analytical cookies may affect your experience of the Platform. Detailed instructions for managing cookies are available in the help documentation of most major browsers.

10User Rights

Subject to applicable law and the data protection framework governing our licensing jurisdiction, you have the following rights in relation to your Personal Data:

• Right of Access: You may request a copy of the Personal Data we hold about you, along with information about how it is processed.
• Right to Rectification: You may request correction of inaccurate or incomplete Personal Data held in your account.
• Right to Erasure: You may request deletion of your Personal Data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected and no overriding legal obligation requires its retention.
• Right to Restrict Processing: You may request that we restrict the processing of your Personal Data in certain circumstances, such as while the accuracy of data is contested.
• Right to Data Portability: Where processing is based on consent or contract performance and carried out by automated means, you may request a machine-readable copy of your Personal Data.
• Right to Object: You may object to processing carried out on the basis of legitimate interests, including direct marketing. Where you object to marketing, we will cease such communications immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

11Children's Privacy

The Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's licensing jurisdiction. We do not knowingly collect Personal Data from individuals under the applicable minimum age. If we become aware that Personal Data has been submitted by a minor, we will immediately suspend the associated account, delete the data and, where appropriate, report the matter to relevant authorities.

Parents and guardians who believe that a minor may have accessed the Platform or submitted Personal Data are encouraged to contact our support team at [email protected] immediately.

12Third-Party Links

The Platform does not include links to third-party websites for commercial or advertising purposes. Where informational references are made to payment methods or services familiar to Pakistani users — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — these are contextual references only. 4777sz does not control the privacy practices of these third-party providers and is not responsible for their data handling. Users should review the privacy policies of any third-party payment provider they use independently.

13Security Measures

4777sz implements technical and organisational security measures designed to protect your Personal Data against unauthorised access, disclosure, alteration or destruction. These measures include:

• HTTPS (TLS) encryption across all pages of the Platform, including the cashier, KYC portal and account management sections;
• Access controls limiting staff access to Personal Data on a need-to-know basis;
• Encrypted storage of sensitive data including identity document images;
• Regular penetration testing and security audits of Platform infrastructure;
• Incident response procedures for detecting, reporting and managing data security events.

While we take data security seriously and invest in appropriate protections, no transmission of data over the internet can be guaranteed to be completely secure. You use the Platform and transmit data to us at your own risk in so far as factors outside our direct control are concerned. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you in accordance with our obligations under applicable law.

14Amendments to This Policy

4777sz reserves the right to update or amend this Privacy Policy at any time. Where material changes are made, we will provide reasonable advance notice to registered Users via the email address associated with their account or through a prominent notice on the Platform. The "Last Updated" date at the top of this page will always reflect the most recent revision.

Where changes are required by new legal or regulatory obligations, they may take effect immediately upon publication. Continued use of the Platform following the effective date of any amendment constitutes acceptance of the updated Policy. If you do not agree to the amended Policy, you should cease using the Platform and may close your account in accordance with the account termination provisions in our Terms & Conditions.

15Contact Us

If you have questions about this Privacy Policy, wish to exercise a data right, or have a concern about how your Personal Data is being handled, please contact our support team:

For queries specifically related to responsible gambling tools or self-exclusion, please also see our dedicated Responsible Gambling page.