Privacy Policy — How HQ77 Collects, Uses & Protects Your Data

1. Introduction

1.1 This Privacy Policy (hereinafter "Policy") describes how HQ77 (hereinafter "HQ77", "we", "us" or "our"), operating via the platform accessible at hq77.cam, collects, processes, stores, discloses and otherwise handles personal data relating to registered users, visitors and other individuals who interact with our platform (collectively "you" or "User").

1.2 HQ77 is an English-language online gambling platform designed primarily for adult users, with a principal audience of Pakistani players. By registering an account or continuing to use the HQ77 platform after this Policy has been made available to you, you acknowledge that you have read and understood its contents.

1.3 This Policy should be read together with the HQ77 Terms & Conditions. In the event of any inconsistency between this Policy and the Terms & Conditions regarding data matters, this Policy shall prevail.

2. Definitions

The following terms carry the meanings set out below throughout this Policy:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, payment details, IP address and device identifiers.
• "Processing" means any operation or set of operations performed on Personal Data — including collection, recording, storage, adaptation, retrieval, use, disclosure and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, HQ77.
• "Data Processor" means any third party that processes Personal Data on behalf of HQ77 under a contractual arrangement.
• "User" / "you" means any individual who visits, registers on, or uses the HQ77 platform in any capacity.
• "KYC" means Know Your Customer — the identity, age and source-of-funds verification process required to operate an account and process transactions.
• "Cookies" means small text files stored on your device by a web browser when you visit a website, used to retain information about your session and preferences.
• "PKR" means Pakistani Rupees, the display currency of the HQ77 platform.

3. Data Controller

3.1 HQ77, operating at hq77.cam, acts as the Data Controller in respect of Personal Data collected from users of the platform. All data protection queries, rights requests and complaints should be directed to the contact details provided in Section 16 of this Policy.

3.2 HQ77 does not claim to be registered with, regulated by, or subject to the oversight of Pakistani data protection authorities, the Pakistan Telecommunication Authority (PTA), or the State Bank of Pakistan. Users are advised to be aware of their rights and obligations under applicable laws in their own jurisdiction.

4. Personal Data We Collect

4.1 HQ77 collects Personal Data in several ways — through information you provide directly, through your use of the platform, and through automated technical means. The categories of data we collect include:

4.2 Data You Provide Directly

4.3 Data Collected Automatically

5. How We Process Your Data

5.1 HQ77 processes your Personal Data for specific, documented purposes. We do not process Personal Data in ways that are incompatible with the purposes for which it was originally collected. The principal processing purposes are:

• Account Management: Creating, verifying and maintaining your user account, including KYC identity and age verification procedures.
• Service Delivery: Providing access to the sports betting, live casino, slots, esports and other gambling products available on the platform, and processing associated transactions in PKR.
• Payment Processing: Processing deposits and withdrawal requests, which may involve sharing data with relevant payment intermediaries. Payment methods referenced (including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah) are provided as familiar context only — actual payment integrations are confirmed in the cashier section and do not imply data-sharing partnerships with those named institutions absent a confirmed integration.
• Fraud Prevention & Security: Detecting, investigating and preventing fraudulent activity, money laundering, bonus abuse, multiple account creation, and other prohibited conduct.
• Regulatory & Legal Compliance: Fulfilling obligations imposed by applicable anti-money laundering (AML) requirements, age verification rules, and other legal obligations relevant to our operating license jurisdiction.
• Responsible Gambling: Operating deposit limits, loss limits, session controls, self-exclusion tools and responsible gambling monitoring systems to protect user welfare.
• Customer Support: Responding to queries, complaints and support requests submitted via live chat or email.
• Platform Improvement: Analysing aggregated usage data to improve platform performance, game selection and user experience.
• Marketing Communications: Sending promotional messages and bonus notifications where you have provided consent to receive such communications. You may opt out at any time.

6. Legal Basis for Processing

6.1 HQ77 relies on the following legal bases when processing your Personal Data, as applicable under the data protection laws of the jurisdiction in which our operating entity is established:

• Contractual Necessity: Processing required to perform our contract with you — registering your account, processing bets, managing payments and providing support.
• Legal Obligation: Processing required to comply with applicable law, including KYC/AML obligations, age verification requirements and record-keeping duties.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform analytics and maintaining the integrity of our services, where those interests are not overridden by your fundamental rights.
• Consent: Processing for direct marketing communications and non-essential cookies, where you have given freely-given, informed and withdrawable consent.

7. Data Sharing & Disclosure

7.1 HQ77 does not sell your Personal Data to third parties. We may share your Personal Data with the following categories of recipients, strictly as necessary for the purposes described in Section 5:

• Payment Service Providers: To process deposits and withdrawals. These processors are bound by contractual data protection obligations and may only use your data for payment processing purposes.
• Identity Verification Services: Third-party KYC providers who assist in verifying the identity and age of users as part of our compliance obligations.
• Game Content Providers: Game studios and sports data technology providers who supply the games and betting markets on the platform. Data shared is limited to what is technically necessary to deliver the gaming session.
• Fraud & Risk Management Providers: Third-party fraud detection and risk assessment tools that help us identify and prevent prohibited activity on the platform.
• Regulatory & Law Enforcement Authorities: Where required by applicable law, court order, or regulatory obligation, HQ77 may be required to disclose Personal Data to relevant authorities.
• Professional Advisors: Legal counsel, auditors and other professional advisors, bound by duties of confidentiality, where necessary for the operation of the business.

7.2 In all cases where third-party Data Processors are engaged, HQ77 requires them to operate under data processing agreements that mandate appropriate technical and organisational security measures and restrict them from using your data for any purpose beyond the contracted service.

8. Data Retention

8.1 HQ77 retains Personal Data for no longer than is necessary for the purposes for which it was collected, taking into account our legal and regulatory obligations. The general retention framework we apply is as follows:

8.2 Where an account is closed or suspended due to a breach of the Terms & Conditions or suspected fraud, HQ77 may retain relevant data for a longer period to support legal proceedings or regulatory reporting.

9. Cookies & Tracking Technologies

9.1 HQ77 uses cookies and similar tracking technologies to operate the platform, analyse usage and improve your experience. The categories of cookies we use are:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication tokens, security cookies and load-balancing cookies. They cannot be disabled without impairing core platform functionality. No consent is required for these cookies.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the platform — pages visited, game categories browsed, session length. This data helps us improve the platform. These cookies are activated on the basis of your consent where required.
• Functional Cookies: Store user preferences such as language selection, currency display preference (PKR) and previously entered non-sensitive form data to improve convenience. Activated with consent where required.
• Marketing Cookies: Used to track promotional campaign performance and, where you have consented, to deliver relevant offers. HQ77 does not use third-party advertising networks for behavioural retargeting on external websites.

9.2 You may manage cookie preferences through your browser settings. Disabling certain cookies may affect platform functionality. Most modern browsers allow you to view, block or delete cookies through the browser settings menu.

10. Your Data Protection Rights

10.1 Subject to applicable law and any limitations arising from our legal compliance obligations, you hold the following rights in respect of your Personal Data:

10.2 To exercise any of the rights listed above, please contact us at [email protected] (plain text — not a clickable link) with the subject line "Data Rights Request". We will respond within 30 days of receiving a valid, verifiable request. We may require identity verification before processing your request.

11. Data Security

11.1 HQ77 implements appropriate technical and organisational security measures designed to protect your Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your browser and the HQ77 platform;
• Encryption of sensitive data fields (including passwords) at rest using industry-standard cryptographic methods;
• Access controls limiting Personal Data access to staff and processors with a demonstrable need;
• Regular security assessments and monitoring of platform systems;
• Incident response procedures to detect, contain and report data breaches where required by applicable law.

11.2 Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. HQ77 cannot guarantee the absolute security of data transmitted to or stored on the platform. Users are encouraged to maintain the security of their own login credentials and to report suspected unauthorised account access immediately to our support team.

12. Minors

12.1 The HQ77 platform is strictly intended for adults aged 18 years or older — or the higher minimum age required by the applicable operator or license jurisdiction. HQ77 does not knowingly collect Personal Data from individuals below the minimum required age.

12.2 Where HQ77 becomes aware that Personal Data has been collected from a person below the minimum age requirement, that data will be deleted and the associated account closed as promptly as practicable. If you are a parent or guardian and believe your child has registered on HQ77, please contact us immediately at [email protected].

12.3 HQ77 encourages parents and guardians in Pakistan and elsewhere to use available parental control and content-filtering software to prevent minors from accessing online gambling platforms.

13. International Data Transfers

13.1 HQ77's platform infrastructure and some of its third-party service providers may be located in jurisdictions outside Pakistan. As a result, your Personal Data may be transferred to and processed in countries other than your country of residence.

13.2 Where such transfers occur, HQ77 takes steps to ensure that appropriate safeguards are in place to protect your Personal Data in accordance with the data protection requirements of the jurisdiction in which our operating entity is established. This may include the use of standard contractual clauses, data processing agreements or other recognised transfer mechanisms.

14. Pakistan-Specific Notice

14.1 HQ77 acknowledges that Pakistan is its primary user market and is mindful of the data-related expectations and concerns of Pakistani users. The following Pakistan-specific points are noted:

• HQ77 does not share your data with the Government of Pakistan, PTA, State Bank of Pakistan or any provincial regulatory authority unless compelled to do so by a valid legal order from a competent authority in the jurisdiction where HQ77 is legally obligated to comply.
• Payment references to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah appear on the platform as local payment context only. HQ77 does not share your data with these institutions unless you actively use an integrated payment method that technically requires data transmission to complete a transaction, in which case only the data necessary for that transaction is shared.
• IP-derived location data (including city-level inference — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar) is used for access control, fraud prevention and platform localisation purposes. It is not used to identify or track you for purposes unrelated to platform operation.
• HQ77 does not claim to be subject to, or compliant with, any Pakistani data protection legislation. Pakistani users are responsible for understanding their own legal position in relation to data rights under applicable Pakistani law.

15. Policy Amendments

15.1 HQ77 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered users via the email address associated with their account and/or by a prominent notice on the platform prior to the changes taking effect.

15.2 The review date displayed at the top of this page indicates when this Policy was last reviewed. You are encouraged to check this page periodically. Your continued use of the platform following notification of material changes constitutes your acknowledgement of the updated Policy.

16. Contact Us

For any queries, rights requests, complaints or concerns regarding this Privacy Policy or the handling of your Personal Data, please contact the HQ77 data team through the following channels:

• Data & Privacy Email: [email protected] — Subject line: "Privacy / Data Rights" (plain text — not a clickable link)
• Live Chat: Available 24/7 via the platform interface (operator-stated availability)
• Response Time: Data rights requests acknowledged within 5 business days; full response within 30 calendar days (Pakistan Standard Time, PKT UTC+5)

For general questions about the platform, our FAQ page provides quick answers. For the full terms governing your use of HQ77, please review the Terms & Conditions.