sand77 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how sand77 ("sand77", "we", "our", or "us") collects, uses, stores, shares, and protects the personal data of players and visitors who access the sand77 Platform at sand77.bio (the "Platform"). This Policy applies to all services offered on the Platform, including online casino games, sports betting, colour games, fish shooting games, and the sand77 PKR wallet.

By registering for a sand77 account or using the Platform in any capacity, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the sand77 Platform.

This Policy should be read alongside the sand77 Terms & Conditions, which govern the overall relationship between sand77 and its players. sand77 serves English-speaking players in Pakistan and this Policy reflects the privacy practices applicable to that player base.

2. Data Controller

sand77 is the data controller responsible for the personal data collected through the Platform. All enquiries relating to this Privacy Policy or your personal data should be directed to the sand77 Data Protection contact using the details provided in Section 15 of this Policy.

3. Personal Data We Collect

sand77 collects the following categories of personal data from players and Platform visitors:

• Identity Data: Full legal name, date of birth, Pakistani CNIC number, and CNIC image as provided during KYC verification.
• Contact Data: Pakistani mobile phone number and email address (where provided).
• Financial Data: Deposit and withdrawal transaction records, payment method details (JazzCash account, Easypaisa account, bank account name and number for HBL, UBL, Meezan Bank, or Bank Alfalah), and PKR wallet balance history.
• Gameplay Data: Betting history, game session logs, wagering activity, and bonus usage records.
• Technical Data: IP address, device type, browser type and version, operating system, screen resolution, and session duration data collected automatically when you access the Platform.
• Usage Data: Pages visited, navigation patterns, search queries within the Platform, and interaction logs.
• Communications Data: Records of your correspondence with sand77 support, including support chat logs and submitted enquiries.
• Responsible Gaming Data: Records of self-exclusion requests, deposit or loss limits set, and any communications related to responsible gaming interventions.

4. How We Collect Your Data

sand77 collects personal data through the following channels:

• Direct provision: Data you provide when registering a sand77 account, completing KYC verification, making deposits or withdrawals, contacting support, or setting responsible gaming limits.
• Automated collection: Technical and usage data collected automatically through cookies, log files, and similar technologies when you access and navigate the Platform.
• Third-party providers: Identity and fraud verification data received from KYC verification partners; payment confirmation data received from JazzCash, Easypaisa, and banking partners when processing transactions.

5. How We Use Your Personal Data

sand77 uses the personal data it collects for the following purposes:

• To create, verify, manage, and maintain your sand77 player account;
• To process PKR deposits, withdrawals, and all financial transactions on the Platform;
• To verify your identity and age in compliance with KYC obligations;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and respond to your enquiries;
• To administer bonuses, promotions, and loyalty programmes;
• To monitor and enforce compliance with the sand77 Terms & Conditions;
• To operate and enforce responsible gaming tools, including self-exclusions and deposit limits;
• To improve and personalise your experience on the Platform through analysis of usage patterns;
• To send essential account communications, including security alerts and transaction confirmations;
• To comply with applicable legal and regulatory obligations.

6. Legal Basis for Processing

sand77 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between sand77 and you as a registered player, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable anti-money laundering, age verification, and fraud prevention obligations.
• Legitimate interests: Processing for fraud detection, Platform security, responsible gaming monitoring, and aggregate analytics, where such interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications where you have provided explicit consent, which may be withdrawn at any time by contacting sand77 support.

7. Sharing Your Personal Data

sand77 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. sand77 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah, to the extent necessary to process your financial transactions;
• KYC and identity verification providers: Third-party services used to verify your CNIC and age;
• Game software providers: To the extent necessary for game operation, providers may receive pseudonymised gameplay data;
• IT and infrastructure providers: Cloud hosting, security, and Platform maintenance providers operating under confidentiality obligations;
• Regulatory and law enforcement authorities: Where sand77 is legally required to disclose data in response to lawful requests, court orders, or regulatory requirements.

All third-party service providers engaged by sand77 are required to handle personal data in accordance with applicable data protection standards and are prohibited from using your data for their own independent purposes.

8. Data Retention

sand77 retains personal data for as long as is necessary for the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting obligations. In general:

• Active player account data is retained for the duration of the account relationship and for a minimum period thereafter as required by applicable law;
• Financial transaction records and KYC documentation are retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements;
• Responsible gaming records, including self-exclusion history, are retained for a minimum period to enable enforcement of exclusion periods and to comply with regulatory obligations.

When personal data is no longer required, sand77 will securely delete or anonymise it in accordance with applicable data protection standards.

9. Data Security

sand77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for all data in transit, access controls restricting data access to authorised personnel, and secure storage of KYC documents and financial records.

Whilst sand77 takes all reasonable precautions to protect your data, no method of electronic storage or transmission over the internet is completely secure. You are responsible for maintaining the security of your sand77 login credentials. Please review the security guidance in the sand77 Terms & Conditions for your account protection obligations.

10. Cookies and Tracking Technologies

sand77 uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Essential cookies: Required for the Platform to function correctly, including maintaining your login session and storing your language preferences. These cannot be disabled without impairing Platform functionality.
• Analytics cookies: Used to collect aggregate, anonymised data about how players navigate and use the Platform, enabling sand77 to identify and address usability issues.
• Security cookies: Used to detect and prevent fraudulent account access and unusual session behaviour.

sand77 does not use advertising or behavioural profiling cookies. You may manage cookie settings through your browser. Disabling essential cookies may prevent you from logging in or using certain Platform features.

11. Your Rights as a Data Subject

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

• Right of access: To request a copy of the personal data sand77 holds about you;
• Right to rectification: To request correction of inaccurate or incomplete personal data;
• Right to erasure: To request deletion of your personal data in circumstances where retention is no longer legally required;
• Right to restrict processing: To request that sand77 limit the use of your data in certain circumstances;
• Right to withdraw consent: To withdraw consent to optional processing (such as marketing communications) at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact sand77 support. sand77 will respond to data subject requests within a reasonable timeframe. We may need to verify your identity before processing certain requests.

12. Children and Underage Users

The sand77 Platform is strictly intended for adults aged 18 years and above. sand77 does not knowingly collect personal data from persons under the age of 18. If you are a parent or guardian and believe that a person under 18 has provided personal data to sand77, please contact us immediately. Upon verification, sand77 will close the account and delete all associated personal data without undue delay.

13. International Data Transfers

In the course of operating the Platform, your personal data may be transferred to and processed in jurisdictions outside Pakistan, including by our third-party technology and KYC service providers. Where such transfers occur, sand77 takes reasonable steps to ensure that your personal data is handled with an equivalent level of protection as required under this Policy.

14. Changes to This Privacy Policy

sand77 reserves the right to update or revise this Privacy Policy at any time. Material changes will be communicated to registered players via the mobile number or email address on file. The updated Policy will be posted on this page with a revised "Last Updated" date. Continued use of the Platform following publication of an updated Policy constitutes your acceptance of the revised terms.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by sand77, please contact the sand77 Data Protection team. All communications are handled in English.

Email: [email protected]

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