1. Introduction
This Privacy Policy ("Policy") is issued by com777 ("com777", "we", "us", "our"), the operator of the online gaming information platform accessible at https://com777.cam and any associated subdomains or services operated under the com777 brand (collectively, the "Platform").
This Policy describes how com777 collects, uses, discloses, stores and protects personal data relating to individuals ("you", "your", "the User") who access or use the Platform, including registered account holders, visitors who browse the Platform without registering, and individuals who contact com777 through any available support channel.
com777 is committed to protecting your privacy and handling your personal data responsibly and in accordance with applicable data protection laws and principles. This Policy should be read alongside our Terms & Conditions and Responsible Gambling policy, each of which is incorporated by reference.
By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with how your data is handled as described in this Policy, you should discontinue your use of the Platform immediately.
Note for Pakistani users: com777 is an English-language platform targeting Pakistani users. This Policy is written and enforceable in English. Where Pakistani data protection law or regulations apply to your data, this Policy reflects applicable general principles; however, this Policy does not constitute legal advice under Pakistani law. We do not claim authorisation from PTA, the State Bank of Pakistan or any Pakistani government authority in respect of data processing.
2. Definitions
The following definitions apply throughout this Policy unless the context requires otherwise:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information relating to an identified or identifiable natural person, including name, contact details, financial information, device identifiers and behavioural data that can be used, alone or in combination, to identify an individual. |
| "Processing" | Any operation performed on Personal Data, whether automated or manual, including collection, recording, storage, adaptation, retrieval, use, disclosure, transfer and deletion. |
| "Data Controller" | The entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, com777 acts as the Data Controller in respect of data collected via the Platform. |
| "Data Processor" | A third party that processes Personal Data on behalf of the Data Controller, under a contractual arrangement that includes appropriate data protection safeguards. |
| "KYC" | Know Your Customer — identity and age verification processes carried out by com777 or its appointed verification service providers. |
| "Cookies" | Small text files placed on your device by the Platform to facilitate functionality, session management and analytics. |
| "Special Category Data" | Particularly sensitive Personal Data including health information, biometric data and data revealing racial or ethnic origin. com777 does not intentionally collect Special Category Data except where required for specific responsible gambling or AML compliance purposes. |
3. Personal Data We Collect
com777 collects Personal Data across several categories, depending on how you interact with the Platform:
3.1 Registration and Account Data
When you create an Account on the Platform, we collect:
- Full legal name
- Date of birth (for age verification purposes)
- Email address
- Residential address (including city, province/state and country — for Pakistani users, this may include references to Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar or other cities)
- Username and encrypted password credentials
- Phone number (where provided)
3.2 KYC and Verification Data
To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we collect:
- Government-issued photographic identity documents (e.g., National Identity Card (CNIC), passport, driver's licence)
- Proof of residential address (e.g., utility bill, bank statement)
- Payment method ownership documents (e.g., bank statement or screenshot of a registered mobile wallet)
- Source-of-funds documentation where required
3.3 Financial and Transaction Data
We collect records of all financial transactions conducted through the Platform, including deposit amounts, withdrawal requests, payment method references (e.g., bank account identifiers, mobile wallet references), transaction timestamps and transaction statuses. Payment card or bank account numbers are processed by third-party payment processors and are not stored in full by com777.
3.4 Platform Usage and Behavioural Data
We automatically collect information about how you use the Platform, including:
- Pages visited, time spent, navigation paths and interaction patterns
- Game session data, wager amounts, outcomes and session durations
- Search queries and filter selections within the Platform
- Device type, operating system and browser version
- IP address and approximate geographic location
3.5 Communications Data
When you contact com777's support team, we retain records of the communication, including the content of support queries, responses provided, ticket reference numbers and timestamps. This applies to communications submitted by email to [email protected] or via any live chat function available on the Platform.
4. How We Collect Personal Data
com777 collects Personal Data through the following channels:
- Directly from you — information you provide when registering, completing KYC, making deposits or withdrawals, setting account preferences, using responsible gambling tools, or contacting support
- Automatically — through Cookies, server logs, analytics tools and tracking technologies as you use the Platform
- From third-party service providers — including KYC verification agencies, payment processors (such as those facilitating bank transfers, mobile wallet transactions or card payments), fraud-detection services and platform analytics providers
- From public sources — where permitted by applicable law, com777 may supplement your data with information from publicly available sources for fraud prevention and AML compliance purposes
Payment data note: References to Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Platform are for contextual and educational purposes only. These institutions have not endorsed gambling activity and are not data-processing partners of com777 unless explicitly verified in a separate contractual arrangement. Any data related to transactions via these channels is processed in accordance with the provider's own privacy terms.
5. Purposes of Data Processing
com777 processes Personal Data for the following purposes:
| Purpose | Description |
|---|---|
| Account Management | Creating, maintaining and administering your Account, including authentication, settings management and communication about your Account status. |
| KYC / AML Compliance | Verifying your identity and age, confirming source of funds and meeting Anti-Money Laundering obligations as required by the operator's license jurisdiction. |
| Payment Processing | Processing deposits and withdrawal requests, reconciling transaction records and investigating payment disputes. |
| Platform Operation | Delivering gaming content, sports betting markets and casino services; personalising the Platform experience; maintaining technical performance. |
| Responsible Gambling | Monitoring for indicators of problem gambling behaviour; administering self-exclusion, deposit limits and session controls; communicating responsible gambling guidance. |
| Customer Support | Responding to queries, resolving disputes, providing account assistance and maintaining support communication records. |
| Security & Fraud Prevention | Detecting and preventing fraud, bonus abuse, money laundering, account takeover and other prohibited activities. |
| Legal Compliance | Meeting legal obligations under applicable laws in the operator's license jurisdiction, including record-keeping, regulatory reporting and responding to lawful data requests. |
| Marketing & Communications | Sending promotional communications, where you have provided consent or where a legitimate interest applies. You may opt out of marketing communications at any time. |
| Analytics & Improvement | Analysing Platform usage patterns to improve user experience, content quality and technical performance. |
6. Legal Basis for Processing
com777 processes your Personal Data on the following legal bases, as applicable under the data protection laws of the operator's license jurisdiction:
- Contractual necessity: Processing required to perform the contract between you and com777, including Account management, payment processing and delivery of gaming services.
- Legal obligation: Processing required to comply with applicable laws, including KYC/AML obligations, record-keeping requirements and responses to lawful regulatory or court orders.
- Legitimate interests: Processing carried out in pursuit of com777's legitimate business interests, including fraud prevention, Platform security, analytics and service improvement, where such interests are not overridden by your rights and freedoms.
- Consent: Processing based on your freely given, informed and specific consent, including the use of non-essential Cookies and the sending of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.
7. Data Sharing & Disclosure
com777 does not sell, rent or trade your Personal Data. We may share your data with the following categories of recipients, under appropriate contractual protections:
7.1 Service Providers (Data Processors)
Third-party companies engaged by com777 to deliver specific operational functions, including: KYC and identity verification service providers; payment gateway and processing partners; cloud hosting and infrastructure providers; fraud detection and AML compliance tools; customer support platform providers; and analytics and performance monitoring services. All such providers are required to process Personal Data only in accordance with com777's written instructions and applicable data protection requirements.
7.2 Regulatory and Legal Authorities
com777 may disclose Personal Data to regulatory authorities, law enforcement agencies, courts or other public bodies where required or permitted to do so by applicable law, including in response to lawful orders, subpoenas, warrant requirements, or as necessary to protect the legal rights of com777 or third parties.
7.3 Business Transfers
In the event of a merger, acquisition, restructuring, asset sale or other business transfer involving com777 or its parent entities, Personal Data held by com777 may be transferred to the relevant successor entity as part of that transaction. Affected users will be notified as required by applicable law.
7.4 No Third-Party Marketing Sharing
com777 does not share your Personal Data with third-party advertisers or marketing organisations for the purpose of targeting you with advertising without your explicit prior consent.
8. International Data Transfers
The com777 Platform is operated from the operator's license jurisdiction, which may be located outside Pakistan. As a result, your Personal Data may be transferred to, stored in and processed in jurisdictions other than your country of residence, including countries whose data protection laws may differ from those applicable in Pakistan.
Where such transfers occur, com777 implements appropriate safeguards to ensure your Personal Data receives an adequate level of protection, including contractual clauses that impose data protection obligations on receiving parties, consistent with applicable data protection standards.
By using the Platform, you acknowledge that your Personal Data may be transferred internationally as described in this section. If you have specific concerns about international data transfers, please contact us at [email protected].
9. Data Retention
com777 retains your Personal Data only for as long as is necessary to fulfil the purposes described in this Policy, and for as long as required to comply with applicable legal, regulatory, tax or accounting obligations.
As a general principle, Account data is retained for a minimum of five (5) years following Account closure, in accordance with standard AML and KYC record-keeping requirements applicable in the operator's license jurisdiction. Transaction records may be retained for longer periods where required by applicable law.
After the applicable retention period has expired, Personal Data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual. Backup copies of data may remain in secure offline storage for a transitional period following deletion from active systems.
Where you have provided consent for marketing communications, we retain your contact details for marketing purposes until you withdraw consent or until the Account is closed, whichever occurs first.
10. Cookies & Tracking Technologies
The com777 Platform uses Cookies and similar tracking technologies to ensure the Platform functions correctly, to analyse usage patterns and to personalise your experience. By continuing to use the Platform after being presented with Cookie information, you consent to the use of Cookies as described in this section.
The types of Cookies used on the Platform include:
You can manage Cookie preferences through your browser settings. Most browsers allow you to block or delete Cookies. Note that disabling Strictly Necessary Cookies may affect your ability to use certain Platform features. For detailed browser-specific instructions, consult your browser's help documentation.
11. Your Data Rights
Subject to applicable law, you have the following rights in relation to your Personal Data held by com777. To exercise any of these rights, contact us at [email protected]. We will respond to verified requests within a reasonable timeframe and in accordance with applicable legal requirements. Requests should be submitted in English.
Right of Access
Request a copy of the Personal Data com777 holds about you and information about how it is processed.
Right to Rectification
Request correction of inaccurate or incomplete Personal Data held about you.
Right to Erasure
Request deletion of your Personal Data where it is no longer needed for the purposes for which it was collected, subject to legal retention obligations.
Right to Restrict Processing
Request that we limit how we use your Personal Data in certain circumstances, such as while the accuracy of data is being verified.
Right to Data Portability
Request a copy of your Personal Data in a structured, commonly used, machine-readable format where processing is based on consent or contract.
Right to Object
Object to processing of your Personal Data where it is based on legitimate interests, including processing for direct marketing purposes.
Right to Withdraw Consent
Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
Rights Related to Automated Decisions
Request human review of any significant automated decision made about you, including automated account suspension or fraud-detection outcomes.
Identity verification: To protect your privacy, com777 may require you to verify your identity before processing any data rights request. We will not fulfil requests made by unverified third parties in respect of another person's data.
12. Data Security
com777 implements appropriate technical and organisational security measures to protect Personal Data against unauthorised access, accidental loss, alteration, disclosure or destruction. These measures include:
- Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform
- Access controls limiting internal data access to authorised personnel on a need-to-know basis
- Encrypted storage of sensitive data fields, including password credentials
- Regular security assessments and vulnerability monitoring of Platform infrastructure
- Contractual data security obligations imposed on third-party service providers and Data Processors
Despite these measures, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your Account credentials and for notifying com777 promptly if you suspect any unauthorised access to your Account. com777 cannot guarantee absolute security and accepts no liability for unauthorised access resulting from your failure to maintain credential security.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, com777 will notify affected individuals and relevant regulatory authorities as required by applicable law.
13. Children's Privacy
The com777 Platform is strictly intended for adults aged 18 years or older, or the higher minimum age required by the operator's license jurisdiction. com777 does not knowingly collect Personal Data from individuals below the applicable minimum age. If we become aware that Personal Data has been submitted by or on behalf of an individual below the minimum age, we will take prompt steps to delete that data and close the associated Account.
If you believe that a minor has provided Personal Data to com777, please contact us immediately at [email protected] so that we can investigate and take appropriate action.
14. Third-Party Links & Services
The com777 Platform may reference third-party services, payment providers or resources for informational or contextual purposes. These references do not constitute endorsements or partnerships. If you access third-party platforms or services referenced on com777, your data will be handled in accordance with those third parties' own privacy policies, over which com777 has no control and for which com777 accepts no responsibility.
com777 is not responsible for the privacy practices, content or security of third-party websites or services. We encourage you to review the privacy policies of any third party whose services you use in connection with your use of the com777 Platform.
15. Changes to This Privacy Policy
com777 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered users via a notice on the Platform or by email to the address associated with your Account, where reasonably practicable. The "Last Updated" date at the top of this page will reflect the date of the most recent amendment.
Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acknowledgement and acceptance of the revised Policy. If you do not agree with the changes, you should cease using the Platform and may request Account closure in accordance with the Terms & Conditions.
16. Contact Us
If you have any questions, concerns or requests regarding this Privacy Policy or the handling of your Personal Data, please contact com777 as follows:
Please include your Account username (if applicable), the nature of your privacy query or request, and sufficient information for us to verify your identity before processing the request. All communications must be submitted in English. We aim to acknowledge privacy requests within 5 business days and to provide a substantive response within 30 days, subject to the complexity of the request.