sand77 Privacy Policy — Your Data, Our Responsibility

1.Data Controller

For the purposes of this Privacy Policy, sand77 (operating at sand77.lol) acts as the data controller in respect of personal data provided by registered players and website visitors. sand77 is responsible for determining the purposes for which and the means by which personal data is processed in connection with the delivery of its online gambling platform and associated services.

Questions regarding this policy or sand77's data handling practices may be directed to the customer support team via the contact details provided in Section 13 of this document.

2.Data We Collect

sand77 collects personal data across several categories, as summarised in the table above and detailed further here. The data we collect falls into the following principal categories:

• Identity and verification data: Your full legal name, date of birth, CNIC or other government-issued identity document details, and nationality — collected as part of the registration and KYC process mandated by our gaming licence.
• Contact data: Email address and Pakistani mobile number — necessary for account access, OTP two-factor authentication, and customer support communication.
• Financial data: Details of payment methods used (JazzCash wallet identifiers, EasyPaisa references, partial bank account details for HBL, UBL, or Meezan transfers, or partial card details for Visa/Mastercard transactions) — retained to comply with anti-money laundering obligations and to facilitate deposit and withdrawal processing.
• Device and technical data: IP addresses, browser type and version, device identifiers, session timestamps, and login location data — used for platform security and fraud detection.
• Gameplay and transaction data: Full records of bets placed, games participated in, bet amounts, win/loss outcomes, session durations, and balance history — retained for regulatory compliance, dispute resolution, and responsible gaming monitoring.

3.How We Use Your Data

sand77 uses personal data collected from players for the following purposes:

• To create, manage, and administer your sand77 account, including identity verification and KYC compliance.
• To process deposit and withdrawal transactions via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card payment methods in PKR.
• To deliver the games, live dealer tables, sportsbook markets, and other platform services to which you are entitled as a registered member.
• To monitor platform security, detect and prevent fraud, and identify unusual account activity including suspicious login attempts.
• To comply with anti-money laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) obligations imposed by our gaming licence.
• To monitor player activity for the purposes of responsible gaming — including identifying patterns that may indicate problem gambling behaviour and applying limits where appropriate.
• To communicate with you regarding your account status, security alerts, withdrawal approvals, and changes to these policies.
• To send promotional communications, where you have provided explicit consent, and to manage opt-out requests in accordance with your preferences.
• To resolve disputes, respond to regulatory inquiries, and produce records required by applicable law or licensing authority.

4.Sharing Your Data

sand77 does not sell, rent, or transfer your personal data to unaffiliated third parties for marketing or commercial purposes. Your data may, however, be disclosed to the following categories of third parties strictly in the context of delivering platform services and meeting legal obligations:

• Payment service providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card payment processors receive the minimum data necessary to process transactions on your behalf.
• KYC and identity verification services: Third-party identity verification partners may receive identity document data for automated or manual verification as required by our licensing obligations.
• Gaming platform and software providers: Game studios and live dealer network operators (including MT Live) receive session data necessary to deliver game content and maintain game integrity records.
• Regulatory and licensing authorities: Our gaming licence authority may require access to player data, transaction records, and compliance documentation as part of their oversight function.
• Law enforcement and competent authorities: sand77 will disclose data where required by a valid legal order, court order, or official regulatory request.
• IT and security infrastructure providers: Cloud hosting, cybersecurity, and technical infrastructure partners process data strictly as data processors under binding agreements that prohibit any independent use of that data.

5.Cookies & Tracking Technologies

sand77 uses cookies and similar tracking technologies on its website to support platform functionality, maintain login sessions, enhance security, and understand how players interact with the platform. The categories of cookies used on sand77 include:

• Strictly necessary cookies: Required for the platform to function. These enable login session management, security token validation, and core navigation. They cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences (such as language settings and display options) to improve your experience across sessions.
• Analytical cookies: Collect aggregate, anonymised data about how visitors use the sand77 website to help us improve page structure, performance, and content.
• Security cookies: Support fraud detection, unusual login identification, and session integrity verification.

You may configure your browser to decline non-essential cookies. Please note that disabling strictly necessary cookies will impair your ability to use sand77 account features. sand77 does not use third-party advertising cookies or behavioural targeting cookies linked to external advertising networks.

6.Data Retention

sand77 retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:

• Account and identity data: Retained for the duration of your active account and for a minimum of five years following account closure, in compliance with AML record-keeping obligations under our gaming licence.
• Financial and transaction records: Retained for a minimum of five years following the date of each transaction, as required by anti-money laundering legislation applicable to our licence jurisdiction.
• Gameplay records: Retained for a minimum of three years for dispute resolution and regulatory audit purposes.
• Marketing preferences and consent records: Retained for the lifetime of the account plus two years from the date of last interaction, for suppression list management and consent audit trail purposes.
• Technical and security logs: Retained for up to twelve months from the date of creation for security investigation purposes.

7.Security Measures

sand77 maintains technical and organisational security measures appropriate to the sensitivity of the personal data we process. These measures include 256-bit SSL encryption for all data in transit; encryption of sensitive personal data at rest within our systems; salted and hashed storage of all account passwords; role-based access controls limiting internal access to personal data to personnel whose job function requires it; regular security auditing and penetration testing by independent third-party security firms; and incident response procedures for timely detection and response to any data security event.

Notwithstanding these measures, no data transmission or storage system can be guaranteed to be 100% secure. In the event of a data breach that poses a material risk to affected players, sand77 will notify relevant parties in accordance with applicable notification obligations under our licensing framework.

8.Your Data Rights

Subject to applicable law and sand77's legitimate regulatory and legal obligations, you hold the following rights in respect of your personal data held by sand77:

To exercise any of the above rights, please contact sand77 customer support via live chat or the email address in Section 13. sand77 will respond to data rights requests within a reasonable timeframe, and in any event within 30 days of receipt, unless complexity or volume justifies a reasonable extension, of which you will be informed.

9.Minors & Age Policy

sand77 does not knowingly collect personal data from individuals under the age of 21. Our platform is strictly restricted to adults aged 21 and above. Where sand77 discovers or has reasonable grounds to believe that an account is held by a person under 21, the account will be immediately suspended, the relevant data will be secured pending investigation, and no further data processing for account or gaming purposes will occur. This is an absolute and non-negotiable policy.

10.International Data Transfers

In order to deliver platform services, personal data collected by sand77 may be processed by infrastructure, software, or service partners located outside of Pakistan. Where such international transfers occur, sand77 takes appropriate steps to ensure that adequate data protection standards are in place, consistent with the data protection requirements applicable under our gaming licence framework. By using sand77 and providing your personal data, you acknowledge that such transfers may occur.

11.Responsible Gaming Data Processing

sand77 processes gameplay data, session durations, deposit frequency, and betting patterns specifically for responsible gaming monitoring purposes. This processing enables the platform to identify players who may be exhibiting signs of problem gambling behaviour and to offer or apply appropriate responsible gaming interventions, including deposit limit recommendations, cooling-off period suggestions, or self-exclusion support. This processing is conducted in the legitimate interest of player welfare and is mandated by our licensing obligations. Players may not opt out of responsible gaming-related data processing while maintaining an active sand77 account.

12.Policy Updates

sand77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, the services we offer, or applicable regulatory requirements. Material changes will be communicated to registered players via email to their registered address or via a prominent notice on the sand77 platform. The effective date at the top of this policy will be updated accordingly. Your continued use of sand77 following the publication of a revised Privacy Policy constitutes your acknowledgement of the revised terms.

13.Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a data protection concern, please contact the sand77 customer support team. Our bilingual support team (English and Urdu) is available 24/7 via live chat from within your account dashboard, and can also be reached at the email address shown in the footer of this website. We serve players across Karachi, Lahore, Islamabad, Faisalabad, Multan, and all regions of Pakistan.

If you are dissatisfied with sand77's response to a data privacy concern, you retain the right to escalate your complaint to the relevant supervisory authority applicable under the terms of our gaming licence jurisdiction.