done77 Privacy Policy

Introduction

done77 ("we", "us", "our" or "the Platform"), accessible at https://done77.cam, is an English-language online gaming information and review platform serving users in Pakistan and other regions where access to such informational content is lawful. done77 takes the privacy and security of your personal data seriously.

This Privacy Policy (the "Policy") describes in detail how done77 collects, receives, uses, stores, processes, shares, transfers and otherwise handles personal information in connection with your use of the Platform. It also sets out your rights in relation to that personal information and how you may exercise them.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, which are incorporated by reference into this document. Where any conflict exists between this Policy and those documents on matters of data privacy, this Policy shall prevail.

Definitions

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

• "Controller" means done77, the entity that determines the purposes and means of processing your personal data.
• "Data Subject" means any identified or identifiable natural person whose personal data is processed by done77 — in most cases, this means you, the User.
• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, IP address, device identifiers and financial information.
• "Processing" means any operation or set of operations performed on Personal Data, including collection, recording, storage, adaptation, retrieval, consultation, use, disclosure, transmission, restriction or erasure.
• "Processor" means any third party that processes Personal Data on behalf of done77 under a written data-processing agreement.
• "Sensitive Data" means Personal Data that reveals racial or ethnic origin, political opinions, religious beliefs, health data, biometric data or financial account details, which requires heightened protection.
• "Third Party" means any natural or legal person, public authority, agency or body other than the Data Subject, the Controller and authorised Processors.
• "Cookie" means a small data file placed on your device by the Platform to enable or enhance certain functionality, session management or anonymised analytics.

Personal Data We Collect

done77 collects and processes the following categories of personal data, depending on how you interact with the Platform:

3.1 Registration & Account Data

• Full name as provided during registration
• Date of birth (for age verification purposes)
• Email address (primary means of account communication)
• Username and encrypted password
• Country or region of residence
• Preferred currency (e.g., PKR)

3.2 Identity Verification (KYC) Data

• Scanned copies or photographs of government-issued photo identification (e.g., Pakistani CNIC, passport, driving licence)
• Proof-of-address documentation (e.g., utility bill, bank statement)
• Payment method verification documentation where required
• Selfie or liveness-check image where required by the KYC process

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records (amounts in PKR or other applicable currencies)
• Payment method identifiers (e.g., partial account numbers, wallet references — full card or account numbers are never stored)
• Bonus redemption and wagering activity records

3.4 Technical & Usage Data

• IP address and approximate geolocation derived therefrom
• Device type, operating system and browser information
• Session timestamps, duration and frequency of Platform access
• Pages visited, features used and navigation paths within the Platform
• Error logs and crash reports

3.5 Communications Data

• Content of support tickets, live chat sessions and emails submitted to done77
• Survey responses and feedback submitted voluntarily
• Records of promotional communications sent to you and your opt-in/opt-out preferences

How We Collect Your Data

done77 collects personal data through the following means:

Legal Basis for Processing

done77 processes personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to perform our contractual obligations to you — including providing access to the Platform, processing your account and executing transactions.
• Legal Obligation: Processing required to comply with applicable law, including AML/KYC regulatory requirements, record-keeping obligations and cooperation with law enforcement or regulatory bodies.
• Legitimate Interests: Processing necessary for the legitimate interests of done77 or a third party — such as fraud prevention, network security, improving the Platform and responsible-gambling monitoring — provided these interests are not overridden by your data protection rights.
• Consent: Where you have provided explicit consent to a specific processing activity — such as receiving marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

How We Use Your Data

done77 uses personal data collected from you for the following purposes:

• To create, verify and manage your Platform account and associated profile.
• To process deposits, withdrawals and other financial transactions in PKR or applicable currencies.
• To conduct KYC and AML verification as required under the operator's licensing and regulatory framework.
• To screen against sanctions lists, PEP databases and fraud-prevention registries.
• To personalise your Platform experience and recommend relevant games or betting markets based on your activity history.
• To communicate with you about your account, including transactional emails, security alerts and support responses.
• To send promotional communications where you have opted in — including bonus offers, PSL season promotions and platform updates. You may opt out at any time.
• To monitor gaming activity for responsible-gambling compliance, including enforcing deposit limits, loss limits and self-exclusion requests.
• To detect, prevent and investigate fraud, money laundering, cheating and other prohibited activities.
• To improve Platform functionality, user experience and content through anonymised analytical insights.
• To comply with applicable legal obligations and to respond to lawful requests from regulatory, law enforcement or judicial bodies.

Third-Party Sharing & Disclosure

done77 does not sell, rent or trade your personal data to third parties for their own marketing or commercial purposes. We may, however, share your data with the following categories of third parties where necessary:

7.1 Service Providers (Processors)

Third-party companies that provide services on our behalf and process personal data under our instruction, including:

• Cloud infrastructure and hosting providers
• Payment processing and gateway providers
• Identity verification and KYC technology providers
• Customer support and live chat software vendors
• Email delivery and communication platforms
• Website analytics and performance monitoring services

All Processors are bound by written data-processing agreements requiring them to maintain confidentiality and implement appropriate security measures.

7.2 Legal & Regulatory Disclosure

done77 may disclose personal data where required to do so by applicable law, court order, regulatory instruction or in connection with legal proceedings. Such disclosures will be made only to the extent required and will be recorded in our compliance logs.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of done77's business or assets, personal data may be transferred to the relevant successor entity, subject to equivalent data-protection protections.

7.4 Payment References

When you use payment methods referenced on done77 — such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — your transaction data is processed by the relevant payment provider under their own privacy policies. done77 does not store full financial account credentials. These providers are referenced for contextual familiarity only and do not endorse or support online gambling activity.

Cookies & Tracking Technologies

done77 uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small data files placed on your device when you visit the Platform. They help us recognise returning users, maintain session continuity and gather anonymised usage statistics.

You may manage or disable non-essential cookies through your browser settings. Note that disabling essential cookies may impair certain Platform functionality. done77 does not deploy third-party advertising cookies or cross-site tracking technologies without your express consent.

Data Retention

done77 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, tax or accounting obligations. The following general retention principles apply:

• Account Data: Retained for the duration of your active account relationship with done77, and for a period of up to five (5) years following account closure, to comply with AML record-keeping requirements.
• KYC Documentation: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, as required under applicable AML regulations.
• Transaction Records: Retained for a minimum of five (5) years for financial and regulatory compliance purposes.
• Communications Data: Support tickets and chat logs retained for up to two (2) years from the date of the communication for quality assurance and dispute resolution purposes.
• Technical & Usage Data: Anonymised analytics data may be retained indefinitely in aggregated form. Identifiable technical logs are retained for up to twelve (12) months.
• Self-Exclusion Records: Retained for the duration of the self-exclusion period plus up to five (5) years thereafter, to prevent circumvention of self-exclusion.

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

International Data Transfers

done77 operates internationally and may transfer your personal data to countries outside your country of residence, including countries that may not provide the same level of data-protection legislation as your home jurisdiction.

Where personal data is transferred internationally, done77 takes steps to ensure that appropriate safeguards are in place — such as standard contractual clauses, binding corporate rules, or transfers to countries recognised as providing an adequate level of data protection — before any such transfer takes place.

Pakistani users should note that Pakistan's Personal Data Protection Bill (at various stages of legislative progress) may impose specific obligations on cross-border data transfers. done77 monitors relevant regulatory developments and will update this Policy accordingly.

Your Data Rights

Subject to applicable law and reasonable verification of your identity, you have the following rights with respect to your personal data held by done77. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request".