hm77 Privacy Policy

hm77 ("we", "us", "our") is the data controller responsible for the personal data collected and processed through the hm77 platform, accessible at hm77.net. As the data controller, hm77 determines the purposes and means of processing your personal data in connection with providing online gaming services to players in Pakistan and internationally.

This Privacy Policy applies to all personal data collected through the hm77 website, any associated mobile applications, customer support channels, and all gaming services offered under the hm77 brand. It should be read alongside hm77's Terms & Conditions and Responsible Gaming Policy, both of which form part of the contractual framework governing your use of the platform.

hm77 collects personal data that is necessary, proportionate, and relevant to providing you with a secure and compliant online gaming experience. The categories of personal data we collect include:

Identity Data: Your full legal name as it appears on your Pakistani CNIC, CNIC number, date of birth, gender, nationality, and — where required for enhanced KYC — a selfie photograph alongside your identity document.

Contact Data: Your Pakistani mobile phone number, email address, city of residence (e.g., Karachi, Lahore, Islamabad, Faisalabad), and any other contact details you provide to hm77 during registration or in the course of using our services.

Financial Data: Payment account numbers associated with JazzCash, EasyPaisa, SadaPay, HBL, UBL, Meezan Bank, or other accepted payment methods; deposit and withdrawal transaction history; account balance history; and, where required by our AML framework, source of funds information.

Technical & Device Data: IP address, device identifiers, browser type and version, operating system, time zone, and connection data collected automatically when you access the hm77 platform.

Usage & Gaming Data: Details of games you have played, bet amounts and outcomes, session start and end times, bonus activity, and your interaction history with hm77 platform features.

KYC Documentation: Scanned or photographed copies of identity and address verification documents submitted during the KYC process.

Support & Communications Data: Records of live chat conversations, emails, and any other communications exchanged between you and hm77 support staff.

hm77 collects personal data through the following channels and methods:

• Direct Collection: Data you provide voluntarily when you register for an hm77 account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automated Collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you browse or use the hm77 platform.
• Third-Party Sources: Identity verification data received from licensed KYC and AML service providers; payment verification data from payment processors including JazzCash and EasyPaisa; fraud risk signals from security data partners.
• Public Sources: Publicly available information used where necessary for enhanced due diligence in compliance with AML obligations — for example, politically exposed person (PEP) screening databases.

hm77 uses the personal data we collect for the following specific purposes:

• Account Management: Creating and maintaining your hm77 player account, verifying your identity at registration and at subsequent KYC checkpoints, and communicating account-related information to you.
• Service Delivery: Processing your deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and other accepted payment methods; facilitating access to slots, cricket betting, and live casino games on the hm77 platform.
• Legal & Regulatory Compliance: Fulfilling our obligations under applicable AML, KYC, and responsible gaming regulations, including age verification, sanctions screening, and transaction monitoring.
• Fraud Prevention & Security: Detecting and preventing fraudulent account activity, unauthorised access, multi-accounting, bonus abuse, and other security threats to the hm77 platform and its player community.
• Responsible Gaming: Monitoring gaming patterns to identify players who may be showing signs of problem gambling; enabling responsible gaming tools including deposit limits, loss limits, and self-exclusion; and directing players to appropriate support resources where warranted.
• Customer Support: Responding to your queries, resolving disputes, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Platform Improvement: Analysing aggregated usage data to improve the performance, design, and feature set of the hm77 platform for Pakistani players.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent to receive such communications, and always subject to your right to opt out at any time.

hm77 processes your personal data only where a valid legal basis exists under applicable data protection law. The legal bases we rely on are:

• Contract Performance: Processing necessary to perform the contract between you and hm77 — including account registration, payment processing, and game access.
• Legal Obligation: Processing required to comply with applicable laws and regulations — including KYC identity verification, AML transaction monitoring, age verification, and data retention obligations.
• Legitimate Interests: Processing carried out for hm77's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and service improvement — where those interests are not overridden by your privacy rights.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent — including marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

hm77 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share your personal data only in the following limited circumstances:

• KYC & Identity Verification Providers: Licensed third-party providers who assist hm77 in verifying player identities and documents as part of our regulatory compliance obligations.
• Payment Processors: JazzCash, EasyPaisa, SadaPay, HBL, UBL, Meezan Bank, and other payment service providers — solely to process your financial transactions on hm77.
• Game Content Providers: Licensed third-party game studios that supply slot, live casino, and sports betting content to the hm77 platform may receive limited technical data necessary to deliver their games to your device.
• Fraud & Security Partners: Specialist security service providers engaged to assist hm77 in detecting and preventing fraud, multi-accounting, and other platform security threats.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order, or the instruction of a competent regulatory or law enforcement authority — including Pakistani financial intelligence authorities where relevant.
• Business Transfers: In the event of a merger, acquisition, or sale of hm77's business or assets, your personal data may be transferred to the acquiring entity — subject to the same privacy protections described in this Policy.

All third-party service providers engaged by hm77 are contractually required to process your personal data only for the specific purposes for which it was shared, and to maintain appropriate security and confidentiality standards.

hm77 operates as an internationally licensed gaming platform. In the course of delivering our services, your personal data may be transferred to and processed in countries outside Pakistan. Such transfers occur only where hm77 has implemented appropriate safeguards to protect your personal data during the transfer and in the destination jurisdiction.

Appropriate safeguards for international transfers may include standard contractual clauses approved by relevant data protection authorities, adequacy decisions, or binding corporate rules — depending on the jurisdiction of the data recipient. Where transfers involve our KYC or payment processing partners, those partners are themselves bound by applicable data protection and financial services regulations in their own jurisdictions.

hm77 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention principles apply:

• Active Accounts: Personal data associated with an active hm77 account is retained for the duration of the account's existence, plus any legally required post-closure retention period.
• Closed Accounts: Following account closure, hm77 retains identity data, KYC documentation, and transaction records for a minimum of five (5) years in compliance with AML and financial services regulations. Responsible gaming records — including self-exclusion history — are retained for a minimum of seven (7) years.
• Support Records: Customer support interaction records are retained for three (3) years following the resolution of the interaction, for dispute resolution and quality assurance purposes.
• Marketing Data: Where consent has been withdrawn, marketing preference data is retained for a suppression period to ensure you are not contacted again — typically up to two (2) years.
• Cookie & Analytics Data: Non-essential cookie and analytics data is retained in accordance with the specific retention periods disclosed in the hm77 cookie consent tool — generally ranging from 30 days to 24 months depending on the cookie type.

When personal data is no longer required for any legitimate purpose, hm77 securely deletes or anonymises it in accordance with our internal data disposal procedures.

hm77 uses cookies and similar tracking technologies — including web beacons, pixel tags, and local storage objects — on the hm77 website and platform. These technologies help us deliver a secure, functional, and personalised experience for Pakistani players.

Types of cookies used by hm77:

• Strictly Necessary Cookies: Essential for the platform to function — including session management, login authentication, and security tokens. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences — such as language, currency display (PKR), and responsible gaming tool settings — to personalise your hm77 experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players navigate and use the hm77 platform, helping us identify performance issues and improve the user experience.
• Security Cookies: Support hm77's fraud detection and account security systems by helping identify unusual login patterns, multi-accounting attempts, and other suspicious activity.

You can manage your cookie preferences through your browser settings or via the hm77 cookie consent management tool available on the platform. Disabling non-essential cookies will not prevent you from using hm77, but may affect the personalisation of certain features.

hm77 operates a strict minimum age policy. No person under the age of 21 is permitted to register for, access, or use the hm77 platform in any capacity. hm77 does not knowingly collect or process personal data belonging to individuals under 21 years of age.

Where hm77 becomes aware that personal data has been collected from an individual who is under 21, that data will be permanently deleted immediately, the associated account will be closed, and any funds held within it will be subject to our underage account handling procedures.

Parents and guardians in Pakistan who believe their minor child may have accessed the hm77 platform are urged to contact hm77 Player Support immediately via live chat or at [email protected] so that the matter can be investigated and resolved promptly.

hm77 implements a multi-layered security framework to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and hm77's servers is encrypted using TLS 1.3 protocols. Sensitive stored data — including CNIC numbers, financial account details, and KYC documentation — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within hm77's systems is restricted on a strict need-to-know basis. Staff members with access to player data are subject to background verification, confidentiality agreements, and regular security training.
• Infrastructure Security: hm77's platform infrastructure is hosted in secure, access-controlled data centres with physical security controls, redundant power systems, and continuous monitoring.
• Intrusion Detection: hm77 operates continuous intrusion detection and security monitoring systems to identify and respond to potential security incidents in real time.
• Two-Factor Authentication: hm77 strongly encourages all players to enable two-factor authentication (2FA) on their accounts. 2FA significantly reduces the risk of unauthorised account access resulting from compromised passwords.

While hm77 takes all reasonable technical and organisational measures to protect your personal data, no internet-based platform can guarantee absolute security against all possible threats. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, hm77 will notify you without undue delay in accordance with applicable data breach notification obligations.

As an hm77 player, you hold the data rights described in the "Your Data Rights" section above. To exercise any of these rights, you may submit a request through any of the following channels:

• Live Chat: Access the 24/7 live chat feature inside your hm77 account dashboard and submit your request to a support agent directly.
• Email: Send your request to [email protected] with the subject line "Data Rights Request — [Your Request Type]" and include your registered email address and a brief description of your request.

hm77 will acknowledge your request within 72 hours and respond substantively within 30 days of receipt of a verified request. In complex cases, hm77 may extend this period by a further 30 days — in which case we will notify you of the extension and the reason for it.

hm77 will not charge a fee for processing data rights requests unless a request is manifestly unfounded, repetitive, or excessive. In such cases, hm77 may charge a reasonable administrative fee or decline to act on the request, and will inform you accordingly.

To protect your privacy and security, hm77 will verify your identity before fulfilling any data rights request. We may ask you to confirm details associated with your registered account before proceeding.

hm77 may send you promotional communications — including bonus offers, free spin notifications, PSL cricket betting promotions, and platform feature updates — where you have consented to receive such communications at the time of registration or through your account marketing preferences.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email sent by hm77;
• Updating your communication preferences inside your hm77 account settings; or
• Contacting hm77 Player Support via live chat or at [email protected] with the subject line "Marketing Opt-Out".

Opting out of marketing communications will not affect the delivery of transactional and account-related communications — such as deposit confirmations, withdrawal notifications, KYC status updates, and responsible gaming alerts — which hm77 may send regardless of your marketing preferences as these form part of our service delivery obligations.

hm77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws and regulations, or the features and services offered on the hm77 platform. The "Last Updated" date at the top of this page will be revised whenever a material change is made.

Where changes to this Privacy Policy are material — meaning they significantly affect how we process your personal data or the rights available to you — hm77 will notify you via email to your registered address and/or through a prominent notice on the hm77 platform prior to the changes taking effect. Your continued use of the hm77 platform following notification of material changes will constitute your acknowledgement of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how hm77 protects and manages your personal data. The current version of this Privacy Policy is always available at hm77.net/privacy-policy.

If you have any questions, concerns, or complaints about this Privacy Policy or hm77's data processing practices, please contact our Player Support and Data Protection team through the following channels:

• Live Chat: 24/7 live chat available inside your hm77 account dashboard — the fastest way to reach us.
• Email: [email protected] — please include "Privacy Policy" in your subject line.
• Support Hours: 24 hours a day, 7 days a week (Pakistan Standard Time).

If you are not satisfied with hm77's response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority or regulatory body in your jurisdiction.