BC77 Privacy Policy

This Privacy Policy (the "Policy") describes how BC77 (the "Operator", "we", "us" or "our") collects, uses, stores, discloses and otherwise processes personal data relating to individuals ("you" or the "User") who access and use the BC77 online gambling platform at bc77.cam and any associated services (collectively, the "Platform" or "Services").

BC77 takes the privacy and security of your personal information seriously. This Policy is designed to provide you with a clear and transparent account of how your data is handled throughout your relationship with the Platform — from the moment you register an account through to the closure of that account and the applicable retention period beyond it.

By registering for or using the Services, you acknowledge that you have read this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

This Policy should be read alongside the BC77 Terms & Conditions and Responsible Gambling Policy, both of which are incorporated by reference.

The following terms carry the meanings set out below throughout this Policy, unless context requires otherwise:

• "Personal Data" Any information relating to an identified or identifiable natural person. This includes name, date of birth, email address, postal address, payment details, CNIC number, IP address, device identifiers and any other data that can be used directly or in combination to identify an individual.
• "Processing" Any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, combination, restriction, erasure or destruction, whether by automated or manual means.
• "Data Controller" BC77, as the entity that determines the purposes and means of processing your Personal Data in connection with the Services.
• "Data Processor" Any third party engaged by BC77 to process Personal Data on its behalf and in accordance with its instructions — for example, identity verification providers, payment processors and customer support platforms.
• "KYC" Know Your Customer — the identity verification process conducted to confirm a User's identity, age, source of funds and compliance status in accordance with applicable Anti-Money Laundering (AML) and counter-terrorism financing (CTF) obligations.
• "Consent" Any freely given, specific, informed and unambiguous indication of a User's agreement to the processing of their Personal Data for a stated purpose, whether by a written statement or a clear affirmative action.
• "Cookies" Small text files placed on a User's device by a web server for the purposes of session management, preference storage, analytics or marketing tracking.
• "Third Party" Any natural or legal person other than BC77, the User, or a Data Processor acting under BC77's direct instruction.

BC77 collects Personal Data across several categories. The specific data points collected will depend on how you interact with the Platform. The primary categories are set out in the table below:

BC77 does not intentionally collect sensitive personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health data or biometric data used for unique identification) beyond what is strictly necessary for KYC liveness checks, which are conducted solely for identity verification purposes and are not retained beyond the verification process.

BC77 collects Personal Data through the following primary mechanisms:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, filling in forms or opting into promotional communications;
• Automated Collection: Technical and usage data collected automatically as you interact with the Platform, including through cookies, web beacons, server logs and similar tracking technologies;
• Third-Party Sources: Identity verification data received from KYC service providers; fraud and AML screening results from risk management partners; geolocation data from IP resolution services; payment confirmation data from payment processors;
• Publicly Available Sources: Where relevant for AML and sanctions screening, data drawn from publicly available databases, sanctions lists or adverse media sources.

BC77 processes your Personal Data for the following purposes:

• 5.1 Account Management: To create, maintain and administer your BC77 account, including processing registration details, managing login credentials, updating account information and handling account closure requests;
• 5.2 Identity & Age Verification (KYC): To verify your identity and age in compliance with the Operator's obligations under applicable gambling licensing conditions and AML/CTF requirements. For Pakistani users, this typically involves processing CNIC or passport data and associated verification documents;
• 5.3 Transaction Processing: To process deposits, withdrawals and associated payment instructions. This includes sharing relevant financial data with payment processors and, where applicable, banks and cryptocurrency network providers;
• 5.4 Fraud & AML Screening: To detect, prevent and investigate fraudulent activity, money laundering, terrorist financing and other prohibited conduct. This may involve automated screening and profiling based on transaction patterns, device data and behavioural analytics;
• 5.5 Responsible Gambling Monitoring: To monitor usage patterns for indicators of problem gambling and to administer responsible gambling tools such as deposit limits, self-exclusion and session time controls;
• 5.6 Customer Support: To respond to queries, complaints and support requests and to maintain a record of interactions for quality assurance and regulatory purposes;
• 5.7 Marketing Communications: To send you promotional communications, bonus offers and platform updates — solely where you have provided explicit consent or where such communication is otherwise permitted. You may withdraw marketing consent at any time by contacting the support team;
• 5.8 Legal Compliance: To comply with applicable laws, regulatory obligations, court orders, licensing conditions and requests from competent authorities.

Where applicable data protection legislation requires BC77 to identify a legal basis for each processing activity, the Operator relies on the following grounds:

• Contractual Necessity: Processing required to perform the contract with you — including account setup, KYC, transaction processing and service delivery — is necessary for BC77 to fulfil its obligations to you as a User;
• Legal Obligation: Processing required to comply with applicable laws and regulations — including AML/CTF obligations, licensing conditions and responses to lawful requests from competent authorities;
• Legitimate Interests: Processing conducted for BC77's legitimate business interests where those interests are not overridden by your data protection rights — including fraud prevention, platform security, responsible gambling monitoring and system analytics;
• Consent: Processing for direct marketing purposes and certain non-essential cookies, which is conducted only on the basis of your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

BC77 does not sell your Personal Data to third parties for commercial marketing purposes. However, we may disclose your data in the following circumstances:

• KYC & Identity Verification Providers: Your identity documents and verification data may be shared with contracted third-party KYC platforms for the purpose of identity and age verification. These providers act as Data Processors under BC77's instruction;
• Payment Processors: Financial transaction data is shared with payment processors and, where applicable, with the underlying payment infrastructure providers — including networks associated with bank transfers, mobile wallet systems and cryptocurrency networks — solely to execute your payment instructions;
• Fraud Prevention & AML Partners: BC77 may share limited data with fraud screening, sanctions checking and AML/CTF service providers to fulfil its compliance obligations;
• Regulatory & Legal Authorities: BC77 may disclose Personal Data to competent regulatory authorities, law enforcement agencies or courts where required by applicable law, court order or lawful regulatory request. BC77 will not voluntarily disclose data to authorities beyond what is legally required;
• Group Entities: Where applicable, Personal Data may be shared within the BC77 corporate group for the purposes of internal administration, compliance and risk management;
• Professional Advisers: Lawyers, auditors, accountants and other professional advisers engaged by BC77 may have access to Personal Data on a need-to-know basis, subject to binding confidentiality obligations.

BC77 retains Personal Data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulatory obligation. The following indicative retention principles apply:

• Account Data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with AML/CTF record-keeping requirements;
• KYC Documents: Retained for the period required by the Operator's licensing conditions and applicable AML regulations — typically a minimum of five (5) years from the date of last transaction or account closure;
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Support Communications: Retained for a minimum of two (2) years from the date of last interaction for quality assurance and complaint resolution purposes;
• Marketing Data: Retained until you withdraw consent or request deletion, subject to any overriding legal obligation to retain;
• Technical & Log Data: Typically retained for up to twelve (12) months for security and fraud monitoring, unless a specific incident requires longer retention.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents identification.

BC77 implements a range of technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include, without limitation:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encrypted storage of sensitive data at rest, including KYC documents and financial records;
• Two-factor authentication (2FA) for Account access, available and encouraged for all users;
• Role-based access controls restricting staff access to Personal Data on a strict need-to-know basis;
• Regular security reviews, vulnerability assessments and penetration testing of Platform infrastructure;
• Contractual obligations requiring all Data Processors to maintain equivalent security standards.

No method of electronic transmission or storage is completely secure. BC77 cannot guarantee absolute data security but commits to responding promptly and transparently to any confirmed security incident that materially affects your Personal Data.

The BC77 Platform uses cookies and similar tracking technologies. A cookie is a small text file stored on your device when you visit the Platform. Cookies are used for the following purposes:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in and security tokens. These cannot be disabled without impairing core functionality;
• Performance & Analytics Cookies: Used to collect anonymised or pseudonymised data on how users interact with the Platform — pages visited, time on site, error reports. This data helps BC77 improve the user experience;
• Functional Cookies: Store your preferences — such as language settings, display preferences and previously visited sections — to personalise your experience;
• Marketing & Tracking Cookies: Used, where consented, to deliver relevant promotional content and measure the effectiveness of marketing campaigns. These are only deployed where you have provided explicit consent.

You may manage or disable cookies through your browser settings. Please note that disabling certain categories of cookies may impair the functionality of the Platform. Most modern browsers provide options to block, delete or receive notifications about cookies.

Subject to applicable law and any overriding legal obligations that BC77 is required to honour (such as AML record-keeping requirements), you have the following rights in respect of your Personal Data:

To exercise any of the above rights, please contact the BC77 support team using the details in Section 15. BC77 will respond to all data rights requests within a reasonable timeframe. BC77 may require identity verification before processing a request to prevent unauthorised access to another person's data.

BC77 acknowledges that users accessing the Platform from Pakistan do so within a specific regulatory environment. The following considerations apply to Personal Data processing in the Pakistani context:

12.1 KYC Documents. Pakistani users completing identity verification will typically be asked to submit their CNIC (Computerised National Identity Card) issued by NADRA, or a current Pakistani passport. These documents are processed solely for identity verification and age confirmation purposes. BC77 does not share CNIC data with Pakistani government authorities unless compelled by a lawful legal process.

12.2 Payment Data. Where users reference Pakistani payment infrastructure — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — financial transaction data is processed only to the extent necessary to administer the transaction. These references on the Platform are for contextual familiarity and do not imply that any of these entities are confirmed data-processing partners or that they endorse gambling services.

12.3 Cross-Border Data Transfers. By using the Platform, Pakistani users acknowledge that their Personal Data may be transferred to and processed in jurisdictions outside Pakistan where the Operator's servers, KYC providers and other Data Processors are located. BC77 takes reasonable steps to ensure that such transfers are conducted under appropriate contractual safeguards.

12.4 No Pakistani Regulatory Authority. BC77 does not claim to be regulated, authorised, licensed or endorsed by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, the Securities and Exchange Commission of Pakistan (SECP) or any provincial authority. This Policy is not intended to constitute legal advice to Pakistani users. You should seek independent counsel if you have questions about the application of Pakistani law to your use of the Platform.

BC77 is strictly an adults-only platform. We do not knowingly collect, process or retain Personal Data from individuals under the age of 18 — or the higher minimum age required by the Operator's licensing conditions or applicable jurisdiction.

Mandatory KYC age verification is conducted on all accounts prior to allowing withdrawal of funds and may be triggered at any point during the account lifecycle. Where BC77 discovers or has reasonable grounds to believe that an Account belongs to a minor, the Account will be immediately suspended, all funds will be returned to the source of deposit (where legally permissible) and all associated Personal Data will be securely deleted, except where retention is required by law.

If you are a parent or guardian and believe that a minor has submitted Personal Data to BC77 or has created an account on the Platform, please contact the support team immediately using the details in Section 15.

BC77 reserves the right to amend, update or replace this Privacy Policy at any time. Where changes are material — for example, introducing a new processing purpose or changing the categories of third parties with whom data is shared — BC77 will endeavour to notify active users via a notice on the Platform or through account communications, and will update the "Effective Date" at the top of this document.

Your continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with a material change, you should cease using the Platform and may request account closure by contacting the support team.

BC77 recommends that you review this Policy periodically to remain informed of how your data is being handled.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or need to raise a data-related concern, please contact the BC77 Data & Privacy team through the following channels: