xp77 Privacy Policy

xp77 (referred to throughout this Privacy Policy as "xp77", "we", "us", or "our") is an internationally licensed online gaming operator offering casino games, sports betting including PSL and international cricket markets, and related entertainment services through the website xp77.club.

xp77 acts as the data controller in respect of the personal data of all registered players and website visitors. As data controller, xp77 determines the purposes for which and the manner in which personal data is collected and processed. xp77 is committed to handling personal data responsibly and in full compliance with applicable international data protection standards.

This Privacy Policy applies to all personal data collected through the xp77.club website and any associated mobile interface, including data collected during the registration process, during gameplay, during deposit and withdrawal transactions, and through customer support interactions. This policy should be read alongside the xp77 Terms and Conditions, which are available at xp77.club/terms-conditions.

xp77 collects personal data from players through several channels. The categories of personal data we collect, and the context in which each category is collected, are set out below:

xp77 uses the personal data we collect for the following specific and documented purposes. We do not use your personal data for any purpose not described in this policy without first obtaining your explicit consent or establishing a separate lawful basis for the new use.

• Account management: Creating, maintaining, and administering your xp77 player account, including authenticating your identity at login and processing any account-level requests you make.
• Payment processing: Processing PKR deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard, and processing withdrawal requests to your designated payment method.
• Regulatory compliance: Fulfilling our KYC, AML, and responsible gaming obligations under our international gaming licence, including age verification (21+ requirement), identity verification, and transaction monitoring.
• Platform security and fraud prevention: Detecting, investigating, and preventing fraudulent activity, cheating, collusion, money laundering, and unauthorised account access.
• Responsible gaming: Monitoring account activity for indicators of problem gambling behaviour, administering self-exclusion, deposit limits, and cooling-off periods, and fulfilling any mandatory responsible gaming obligations under our licence conditions.
• Customer support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions for quality assurance and dispute resolution purposes.
• Service improvement: Analysing aggregated, anonymised usage data to improve platform performance, game offerings, and the overall player experience. This analysis does not involve profiling individual players for commercial purposes.
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates by email or SMS, where you have not opted out of such communications. You may opt out at any time by contacting support@xp77.club.

xp77 processes personal data on one or more of the following lawful bases, in accordance with internationally recognised data protection principles:

• Contractual necessity: Processing required to perform the contract between you and xp77, including account registration, payment processing, and provision of gaming services.
• Legal obligation: Processing required to comply with xp77's legal and regulatory obligations, including KYC verification, AML transaction monitoring, age verification, and responsible gaming programme administration.
• Legitimate interests: Processing carried out on the basis of xp77's legitimate business interests, including platform security, fraud prevention, service improvement, and certain internal analytics activities, provided such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for direct marketing communications, where you have provided your consent at the time of registration or subsequently. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

xp77 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Personal data may be shared with the following categories of third parties, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• Payment processors: JazzCash, EasyPaisa, and our card payment processing partners receive the minimum financial data necessary to complete your PKR deposit or withdrawal transaction. These providers operate under their own privacy policies and PCI-DSS compliance frameworks.
• KYC and identity verification providers: Third-party identity verification services may process your identity documents and personal details on xp77's behalf for the purpose of fulfilling our KYC and age verification obligations.
• AML and fraud screening providers: Transaction data may be shared with AML screening and fraud detection services for the purpose of identifying and preventing financial crime.
• Regulatory authorities: xp77 may be required to disclose player data to our licensing authority, law enforcement agencies, or other regulatory bodies where required by law or by the conditions of our gaming licence.
• Platform infrastructure providers: Cloud hosting, content delivery, and platform infrastructure providers may process certain technical data in the course of operating and maintaining the xp77 platform.

xp77 uses cookies and similar tracking technologies on xp77.club. A cookie is a small text file placed on your device by a website you visit. xp77 uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function correctly. These include session authentication cookies that keep you logged in during your xp77 session. These cookies cannot be disabled without breaking core platform functionality.
• Performance and analytics cookies: Used to collect anonymised data about how players use xp77.club, including pages visited, time spent on each page, and error events. This data is used in aggregate to improve platform performance and is not linked to your personal identity.
• Preference cookies: Used to remember your platform preferences, such as language settings, between sessions.

xp77 does not use third-party advertising cookies, retargeting cookies, or social media tracking pixels on xp77.club. You may configure your browser to refuse or delete cookies at any time, however please note that disabling strictly necessary cookies will impair your ability to use the xp77 platform.

xp77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our licensing obligations. The following general retention periods apply:

• Active account data: Retained for the duration of your registered player account, plus a minimum of five (5) years following account closure, in accordance with standard AML record-keeping requirements.
• Transaction records: PKR deposit and withdrawal records are retained for a minimum of five (5) years from the date of the transaction.
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant KYC process, whichever is later.
• Customer support records: Retained for a minimum of three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Marketing consent records: Retained for the duration of your consent, plus one (1) year following withdrawal of consent, to demonstrate compliance.

Where personal data is no longer required for any lawful purpose, xp77 will securely delete or anonymise it. Anonymised data (where all identifying elements have been irreversibly removed) may be retained indefinitely for statistical and analytical purposes.

xp77 implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data in transit between your device and xp77.club servers.
• Encryption of sensitive data at rest, including stored payment identifiers and identity documents.
• Role-based access controls limiting access to personal data to authorised xp77 personnel on a strict need-to-know basis.
• Regular security assessments and penetration testing of the xp77 platform infrastructure.
• Two-factor authentication (2FA) availability for all player accounts.
• Automated transaction monitoring systems designed to detect unusual account activity and flag potential security incidents in real time.

As described in the "Your Rights" section of this page, you have the right to access, correct, erase, port, object to, and restrict the processing of your personal data held by xp77. To exercise any of these rights, please contact our support team at support@xp77.club with the subject line "Data Rights Request".

When submitting a data rights request, please include your registered xp77 username and a clear description of the right you wish to exercise. xp77 will respond to all data rights requests within thirty (30) calendar days of receipt. In cases of particular complexity, the response period may be extended by a further two months, in which case xp77 will notify you of the extension and the reasons for it within the initial thirty-day period.

xp77 will not charge a fee for processing data rights requests unless the request is manifestly unfounded or excessive, in which case xp77 may charge a reasonable administrative fee or decline to act on the request, providing written reasons for that decision.

The xp77 platform is strictly intended for adults aged 21 years and over. xp77 does not knowingly collect personal data from any individual under the age of 21. If xp77 becomes aware that personal data has been collected from a person under the minimum age, that account will be immediately suspended and the personal data will be securely deleted, with any deposited funds returned in full net of withdrawals already processed.

If you are a parent or guardian and believe that a person under 21 in your household has registered an account with xp77, please contact us immediately at support@xp77.club so that we can take appropriate action without delay.

xp77 employs age verification procedures as part of the KYC process to prevent minors from accessing real-money gaming services. These procedures are a mandatory component of our responsible gaming programme and our international licensing obligations. Players are required to confirm their age at registration and may be required to provide documentary proof of age before deposits or withdrawals are processed.

xp77 reserves the right to update or modify this Privacy Policy at any time. Any changes will take effect immediately upon publication of the revised policy at xp77.club/privacy-policy. The "Last updated" date at the top of this page will be revised accordingly whenever material changes are made.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — xp77 will notify registered players by email to the address on their account prior to the changes taking effect, giving players the opportunity to review the updated policy before it applies to them. Continued use of xp77.club following notification of material changes constitutes your acceptance of the revised Privacy Policy.

xp77 encourages all players to review this Privacy Policy periodically to remain informed about how we protect their personal data. If at any time you disagree with the Privacy Policy, please discontinue your use of xp77.club and contact us to discuss account closure options.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way xp77 processes your personal data, please contact our privacy support team using the details below. We aim to acknowledge all privacy-related enquiries within 24 hours and to provide a full response within 30 calendar days.

• Email: support@xp77.club (subject line: "Privacy Policy Query")
• Data Rights Requests: support@xp77.club (subject line: "Data Rights Request")
• Platform: xp77.club