hcm77 Privacy Policy —
Your Personal Data,
Protected by Design

This Privacy Policy ("Policy") is issued by hcm77 ("we", "us", "our", "the Platform") and applies to all personal data collected from individuals who access hcm77.net, use the hcm77 Android application, register an Account, or interact with any hcm77 service ("you", "Player", "User").

hcm77 is an online gaming and sports betting platform serving English-speaking users in Pakistan. All hcm77 Accounts are denominated in Pakistani Rupee (PKR). We are committed to processing your personal data lawfully, fairly, and transparently in accordance with this Policy.

By creating an hcm77 Account or using any of our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

hcm77 collects the following categories of personal data from Pakistan players:

We collect only the data that is necessary for the specific purposes described in this Policy. We do not collect special category data (such as health data, biometric data, or political opinions) unless required for specific regulatory compliance purposes, in which case we will inform you clearly at the point of collection.

hcm77 collects personal data through the following methods:

• Direct provision: When you register an Account, complete KYC verification, make deposits or withdrawals, contact customer support, or update your Account settings, you directly provide personal data to hcm77.
• Automated technical collection: When you access hcm77.net or use the hcm77 Android app, we automatically collect technical data including your IP address, device fingerprint, browser type, and session activity via server logs, cookies, and similar tracking technologies.
• Payment processor data: When you make a deposit or withdrawal via Easypaisa, JazzCash, HBL, or another payment method, the payment processor confirms transaction details to hcm77, including payment method identifiers and transaction amounts in PKR.
• Third-party verification services: During KYC processes, hcm77 may use identity verification service providers to cross-check the accuracy of documents you submit. These providers confirm or flag verification status but do not retain your documents beyond the verification transaction.
• Gaming platform data: All game activity — every spin, hand, bet, and session — is recorded by hcm77's gaming systems as part of normal platform operation, fair play monitoring, and regulatory compliance.

hcm77 processes your personal data for the following specific purposes, each on a defined legal basis:

• Account creation and management — Necessary for the performance of the contract between you and hcm77 (our Terms & Conditions).
• Processing PKR deposits and withdrawals — Necessary for contract performance and to comply with anti-money laundering (AML) legal obligations.
• Identity verification (KYC) — Required to comply with AML and responsible gaming legal obligations. We cannot process large withdrawals without verifying your identity.
• Fraud prevention and security monitoring — Legitimate interest in protecting hcm77, its players, and the financial system from fraudulent activity and unauthorised access.
• Responsible gaming monitoring — Legal obligation to identify signs of problem gambling and to provide appropriate interventions, as well as the legitimate interest of player protection.
• Customer support — Necessary for contract performance; we need your account information to help you effectively.
• Platform improvement and analytics — Legitimate interest in improving the hcm77 platform based on aggregated, anonymised usage patterns.
• Marketing and promotions — Consent-based; you can withdraw consent at any time from your Account settings or by contacting [email protected].
• Legal and regulatory compliance — Compliance with applicable laws, including data retention requirements and responses to lawful regulatory requests.

hcm77 does not sell, rent, or trade your personal data with third parties for their own marketing or commercial purposes. We share your data only in the following specific, limited circumstances:

• Payment processors: We share necessary financial transaction data with Easypaisa, JazzCash, HBL, UBL, MCB Bank, Meezan Bank, SadaPay, and other payment providers solely to process your PKR deposits and withdrawals. These providers process your data under their own privacy policies and applicable regulations.
• Game providers: hcm77's live casino and slot titles are powered by licensed game providers (including Evolution Gaming, Pragmatic Play, and others). These providers process minimal technical data to deliver and certify game outcomes. They do not receive your full identity or financial data.
• KYC and identity verification providers: We share identity document data with licensed KYC service providers solely to complete your identity verification. These providers are contractually prohibited from using your data for any other purpose.
• Fraud prevention services: Technical data (including IP addresses and device fingerprints) may be shared with fraud detection services to protect against unauthorised account access and financial fraud.
• Legal and regulatory authorities: hcm77 will disclose personal data to relevant authorities where required to do so by law, court order, or valid regulatory request. We will notify affected users of such disclosures where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of hcm77's business assets, player data may be transferred to the acquiring entity. You will be notified of any such transfer and your choices regarding your data.

hcm77 retains personal data for as long as is necessary for the purposes set out in this Policy, subject to the following retention guidelines:

When data reaches the end of its retention period, hcm77 securely deletes or anonymises it so that it can no longer be linked to any identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

hcm77 takes the security of your personal data extremely seriously and implements technical and organisational measures appropriate to the risk level of the data being processed. The following security measures are in place at all times:

• 256-bit SSL/TLS encryption on all data transmitted between your device and hcm77's servers — the same standard used by Pakistan's major commercial banks including HBL and UBL.
• Encrypted database storage for all sensitive personal data including identity documents, payment method identifiers, and KYC verification records.
• Two-factor authentication (2FA) available on all hcm77 Accounts — we strongly recommend enabling this feature for all Pakistan players.
• Intrusion detection and prevention systems monitoring hcm77's servers in real time for unauthorised access attempts.
• Access controls and role-based permissions ensuring that hcm77 staff can only access the minimum personal data necessary to perform their specific job functions.
• Regular security audits conducted by independent third-party security specialists to identify and remediate vulnerabilities before they can be exploited.
• Data breach response protocol: In the event of a data breach affecting player data, hcm77 will notify affected players by email within 72 hours of becoming aware of the breach, including details of what data was affected and steps being taken to address it.

hcm77 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device by your browser. The following types of cookies are used on hcm77:

• Strictly necessary cookies: Required for hcm77 to function. These include session authentication tokens that keep you logged in to your Account. These cookies cannot be disabled as they are essential to the Services.
• Functional cookies: Remember your preferences (such as language settings and Account display preferences). These enhance your experience but the platform can operate without them.
• Analytics cookies: Collect anonymised data about how Pakistan players use hcm77 — which sections are visited most frequently, how long pages are viewed, and where players encounter difficulties. This data helps us improve the platform.
• Security cookies: Detect and prevent fraudulent login attempts, track suspicious session behaviour, and support device fingerprinting for Account protection.

You can manage cookie preferences through your browser settings. Disabling cookies beyond strictly necessary ones may affect some platform features. Most modern browsers allow you to view, delete, and block specific cookies via the browser's privacy or settings menu.

hcm77 is strictly an 18+ platform. We do not knowingly collect, store, or process personal data from individuals under the age of 18 years. All hcm77 Account registrations require confirmation that the applicant is at least 18 years of age.

If hcm77 discovers or is informed that personal data has been collected from an individual under 18, the following steps will be taken immediately:

• The Account will be suspended and access to all Services immediately blocked.
• All personal data associated with the Account will be permanently deleted from hcm77's systems within 72 hours.
• Any PKR balance in the Account will be refunded to the payment method used for deposits where technically possible.
• The matter may be reported to relevant child protection or regulatory authorities where legally required.

As an hcm77 Pakistan player, you hold the privacy rights summarised at the top of this page (access, rectification, erasure, objection, portability, and restriction). To exercise any of these rights, please contact hcm77 as follows:

• Email: Send your request to [email protected] with the subject line "Privacy Rights Request" and include your registered hcm77 username and a clear description of the right you wish to exercise.
• Identity verification: To protect your data, hcm77 may request identity verification before actioning certain requests (particularly access requests and erasure requests for accounts with pending balances).
• Response timeline: hcm77 will acknowledge all privacy rights requests within 5 business days and complete requests within 30 days. Complex requests may take up to 60 days — we will notify you if an extension is required.
• Free of charge: Exercising your privacy rights is free of charge. hcm77 may apply a reasonable administrative fee only in cases of manifestly unfounded or excessive requests.

Where hcm77 cannot fulfil a request in full — for example, because retaining certain financial records is required by law despite an erasure request — we will explain the specific reason and inform you of any alternative actions available to you.

With your consent at registration or through subsequent opt-in, hcm77 may send you marketing communications about promotions, new games, PSL betting markets, jackpot tournaments, and other platform updates. These may be delivered by email, SMS to your registered Pakistan mobile number, and in-app push notifications.

You can withdraw consent for marketing communications at any time through any of the following methods:

• Update your notification preferences directly in your hcm77 Account settings (Notifications tab).
• Click the "Unsubscribe" or "Opt Out" link included in every hcm77 marketing email.
• Contact [email protected] with the subject line "Marketing Opt-Out" — your preferences will be updated within 48 hours.

hcm77 integrates with third-party service providers to deliver the full platform experience. These include game providers, payment processors, KYC verification services, analytics providers, and fraud detection services. Each of these providers processes data under their own privacy policies and applicable data protection laws.

hcm77 conducts due diligence on all third-party service providers before integration and requires contractual data processing agreements where personal data is shared. hcm77 is not responsible for the privacy practices of third-party providers beyond the contractual obligations they have undertaken to us.

hcm77.net and the hcm77 Android app do not contain links to external websites for purposes other than platform function. Where external links are present for regulatory or support purposes, users are advised that visiting third-party sites is governed by those sites' own privacy policies.

hcm77 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform Services. Material changes will be communicated to all registered Pakistan players by email at least 14 days before the updated Policy takes effect.

The current version of this Privacy Policy is identified by the "Last Updated" date at the top of this page and in the table of contents sidebar. Previous versions are available upon request from [email protected].

For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by hcm77, please contact our English-language support team:

• Email: [email protected] (response within 2 hours on average)
• Subject line for privacy matters: "Privacy Request" or "Privacy Complaint"
• Support hours: Daily from 08:00 to 02:00 Pakistan Standard Time (PKT, UTC+5)

If you submit a privacy complaint to hcm77 and are not satisfied with our response within 30 days, you have the right to escalate your complaint to the relevant data protection or regulatory authority in your jurisdiction. hcm77 will cooperate fully with any legitimate regulatory investigation into our data practices.