Privacy Policy – com777 Pakistan Online Gaming Platform

Who We Are & Scope of This Policy

This Privacy Policy is issued by com777, the operator of the online gaming platform at https://com777.click ("the Platform"). When we say "com777", "we", "us", or "our", we mean the entity responsible for operating the Platform and for determining how your personal data is collected and used. When we say "you", "your", or "Player", we mean any individual who visits, registers with, or uses the Platform in any capacity.

This Policy applies to all personal data collected through the com777 Platform — whether you registered an account, visited without registering, participated in a promotion, or contacted our support team. It covers data collected via the website, any associated web app interface, and communications made through our live chat and email channels.

com777 is designed for and directed at players located in Pakistan. This Policy is written in English (en-PK) and is intended to be understood in the context of Pakistani players and applicable data protection obligations. If you access the Platform from outside Pakistan, this Policy still applies to the data we collect about you.

What Personal Data com777 Collects

2.1 Registration Data

When you create a com777 account, we collect your full legal name as it appears on your CNIC, your Pakistani mobile phone number, your email address, your date of birth, and the password you create. This is the minimum information required to open and manage an account on the Platform.

2.2 Identity Verification Data (KYC)

Before processing withdrawals above Rs 10,000 or where additional identity verification is required, com777 collects a copy of your CNIC (front and back), a selfie photograph in which you are holding your CNIC, and in some cases proof of your payment method such as a screenshot of your Easypaisa or JazzCash account screen showing your registered number and name. KYC documents are collected to comply with anti-money laundering requirements and to protect both com777 and its players from fraud.

2.3 Financial Transaction Data

We collect records of every deposit and withdrawal transaction on your account, including the amount in PKR, the payment method used (Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, or card), the timestamp, and the transaction reference number provided by the payment processor. We do not store full card numbers, PINs, or mobile wallet passwords — these remain with your payment provider.

2.4 Gaming Activity Data

com777 records all gaming activity on your account, including every wager placed, the game title and type, the stake amount, the outcome, the timestamp, any bonus credit used, and the resulting balance movement. This data is used to calculate bonus wagering progress, resolve disputes, detect unusual patterns, and compile your account history.

2.5 Device and Technical Data

When you visit or use the com777 Platform, we automatically collect your IP address, device type and model, operating system, browser type and version, screen resolution, and session duration. This technical data helps us optimise the Platform for Pakistani mobile devices and identify security threats.

2.6 Communications Data

If you contact com777 via live chat, email, or any other channel, we retain a record of that communication including the content, the date and time, and your account reference. This allows us to maintain a consistent support history and resolve recurring issues effectively.

How com777 Collects Your Data

com777 collects personal data through three main channels:

3.1 Directly from You

The majority of data we hold is provided directly by you when you register an account, complete KYC verification, make deposits or withdrawal requests, contact our support team, participate in promotions, or update your account profile. You are always in control of what you share through these direct interactions.

3.2 Automatically Through Platform Use

Technical data such as your IP address, device information, and session behaviour is collected automatically whenever you visit or interact with the com777 Platform. This happens through standard web server logging and the use of cookies and similar technologies — explained in Section 7.

3.3 From Payment Processors

When you deposit or withdraw via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT, or card, the relevant payment processor shares transaction confirmation data with com777 so we can update your account balance and maintain a complete transaction record. We receive confirmation of the transaction, the amount, and a reference ID — we do not receive your full payment credentials.

Why com777 Uses Your Personal Data

com777 uses your personal data only for the purposes set out below. We do not use your data for any purpose that is not described in this Policy, and we do not sell your personal data to any third party under any circumstances.

• Account operation: To create, verify, and maintain your com777 account, process logins, and enable you to access games and features.
• Payment processing: To process PKR deposits and withdrawals via your chosen payment method and maintain a complete financial record of your account activity.
• Identity verification: To comply with anti-money laundering (AML) requirements by confirming that account holders are who they say they are and that funds have a legitimate source.
• Fraud and security: To detect and prevent fraudulent account activity, multiple account creation, bonus abuse, money laundering, and other prohibited conduct described in the com777 Terms and Conditions.
• Bonus and VIP management: To calculate wagering progress on bonus funds, manage VIP tier status and loyalty points, and deliver weekly cashback and monthly bonus credits to your account.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behaviour and to enforce deposit limits, loss limits, and self-exclusion settings applied by you or by our responsible gaming team.
• Customer support: To respond to your enquiries, resolve disputes, and maintain a history of your support interactions so you do not have to repeat context with every contact.
• Platform improvement: To analyse aggregated, anonymised usage patterns and identify ways to improve the game library, payment experience, and overall platform performance for Pakistani players.
• Marketing communications: To send you information about promotions, new games, and VIP benefits — but only if you have opted in to receive marketing communications. You can opt out at any time.

Legal Basis for Processing Your Data

com777 processes your personal data on the following legal grounds:

5.1 Contractual Necessity

Processing your registration data, payment records, and gaming activity is necessary for com777 to fulfil the contract between us — the account agreement established when you registered. Without this processing, we cannot operate your account, process your transactions, or provide the gaming services you signed up for.

5.2 Legal Obligation

Processing your KYC documents and maintaining transaction records is required by applicable anti-money laundering and know-your-customer regulations. com777 is legally required to verify the identity of players and to maintain financial records for regulatory inspection purposes. This processing cannot be opted out of while your account remains active.

5.3 Legitimate Interests

Processing technical and device data for fraud detection, security monitoring, and Platform optimisation is carried out under our legitimate interest in operating a safe and reliable gaming platform. We have assessed that this interest is not overridden by player privacy interests, given the nature of the data and the security benefit it provides to all players.

5.4 Consent

Where we send marketing communications to your mobile number or email address, this is done on the basis of your consent, given at registration or updated in your account settings. You can withdraw consent for marketing at any time via your account settings or by contacting support@com777.click. Withdrawing marketing consent does not affect the processing of data necessary to operate your account.

Data Sharing & Third Parties

com777 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share data only in the following limited and controlled circumstances:

6.1 Payment Processors

To process your PKR transactions, com777 shares necessary financial data (transaction amount, account reference, payment method) with our payment processing partners — Easypaisa, JazzCash, NayaPay, SadaPay, and our banking partners for IBFT and card transactions. These processors are bound by their own privacy obligations and receive only the data required to complete the transaction.

6.2 Identity Verification Services

KYC documents may be processed by third-party identity verification services used by com777 to automate and secure the verification process. These services process data only for verification purposes and do not retain data beyond the verification workflow or use it for any other purpose.

6.3 Fraud Prevention and Security

com777 may share account data with fraud prevention agencies and security service providers where we have a legitimate interest in preventing financial crime. This sharing is limited to the data necessary to investigate or prevent the specific fraud concern identified.

6.4 Legal and Regulatory Requirements

If com777 receives a lawful request from a government authority, law enforcement body, or court with jurisdiction over our operations, we will comply with that request and disclose only the data specifically required by the legal order. We will notify you of such a request where we are legally permitted to do so.

Cookies & Similar Tracking Technologies

com777 uses cookies and similar browser storage technologies to make the Platform work correctly and to improve your experience. Below is a plain explanation of what each type of cookie does:

7.1 Essential Cookies

These cookies are required for the Platform to function. They maintain your login session so you do not have to log in again every time you switch pages, store your preferred language and currency display settings, and enable game sessions to run correctly. You cannot opt out of essential cookies while using the Platform — without them, basic functions such as logging in and placing wagers will not work.

7.2 Security Cookies

Security cookies help com777 detect and prevent fraudulent login attempts, multiple account activity, and automated bot access. They store a session token that verifies you are the legitimate account holder during your active session. These are also essential to Platform operation and cannot be disabled.

7.3 Performance and Analytics Cookies

com777 uses anonymised analytics cookies to understand how Pakistani players navigate and use the Platform — which pages are most visited, how long sessions typically last, and where players encounter problems. This data is aggregated and cannot be used to identify individual players. You can opt out of analytics cookies via your browser settings or by contacting our support team.

7.4 Marketing Cookies

If you have opted in to marketing communications, com777 may set cookies that help personalise the promotions shown to you on the Platform. You can opt out of marketing cookies at any time via your browser settings or by withdrawing your marketing consent in your account settings.

How com777 Protects Your Data

Protecting the personal and financial data of Pakistani players is taken seriously at com777. The following technical and organisational measures are in place to keep your data secure:

• 256-bit SSL encryption: All data transmitted between your device and the com777 Platform is encrypted using industry-standard 256-bit SSL (TLS 1.3). This protects your login credentials, payment data, and personal information from interception during transmission.
• Encrypted data storage: Sensitive stored data — including CNIC scans and verification documents — is encrypted at rest using strong encryption keys. Raw payment credentials such as card numbers and mobile wallet PINs are never stored on com777 servers.
• Access controls: Internal access to player data is restricted on a strict need-to-know basis. Employees who do not require access to player data to perform their role do not have it. Access logs are maintained and reviewed regularly.
• Intrusion detection: com777's infrastructure is monitored 24/7 for intrusion attempts, unusual access patterns, and data exfiltration indicators. Security incidents are investigated within 24 hours of detection.
• Regular security audits: The Platform undergoes periodic security testing including penetration testing and vulnerability assessments conducted by independent third-party security specialists.

How Long com777 Keeps Your Data

com777 retains personal data for only as long as necessary for the purposes described in this Policy or as required by applicable legal obligations. The following retention periods apply:

• Account and registration data: Retained for the duration of the account plus 5 years following account closure. This period accounts for potential regulatory investigations and legal disputes that may arise after closure.
• KYC and identity documents: Retained for 5 years following account closure in compliance with anti-money laundering record-keeping requirements. You may request deletion of KYC documents after this retention period has elapsed.
• Financial transaction records: Retained for 7 years following each transaction in compliance with financial record-keeping obligations. This period is set by regulatory requirements and cannot be shortened on request.
• Gaming activity records: Retained for 5 years following account closure. These records support dispute resolution and regulatory compliance obligations.
• Support communications: Retained for 3 years following the last communication in a given thread. Communications relevant to an ongoing dispute or investigation are retained until the matter is resolved.
• Technical and device data: Retained for 12 months following collection. Aggregated, anonymised analytics data derived from this information may be retained indefinitely.
• Marketing consent records: Retained for the duration of your account to allow us to demonstrate that marketing was sent with valid consent.

After the applicable retention period expires, data is securely deleted or irreversibly anonymised so that it cannot be linked back to any individual player.

Your Rights Over Your Personal Data

As a com777 player, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at support@com777.click with your account registered mobile number and a description of your request. We will respond within 14 days.