hor77 Privacy Policy

This Privacy Policy ("Policy") describes how hor77 ("hor77", "we", "us", "our") collects, uses, stores, shares, and protects personal information when you use the hor77 Platform — including the website at hor77.com, its mobile-optimised version, and all associated services offered to players in Pakistan and other jurisdictions.

We take our data protection obligations seriously. Pakistan players trust hor77 with their personal information — their CNIC details, their mobile numbers, their Easypaisa and JazzCash transaction histories — and we treat that trust as a non-negotiable responsibility. This Policy is written to be clear and understandable, not buried in legalese.

By registering an account on hor77, depositing funds, or placing any wager on the Platform, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your personal data as described herein.

For the purposes of this Privacy Policy, hor77 is the data controller in respect of your personal information. As data controller, hor77 is responsible for determining the purposes for which, and the means by which, your personal data is processed.

All data protection enquiries, access requests, and complaints should be directed to the hor77 Data Protection team. Contact details are provided in Section 15 of this Policy.

hor77 collects personal data in the following categories. The table below sets out each category, specific data points within it, and the primary purpose for which it is collected.

Note: hor77 does not collect sensitive categories of data such as racial or ethnic origin, political opinions, health data, or biometric data beyond the photographic CNIC verification image required for KYC.

hor77 collects personal data through the following channels:

• Direct submission: Information you provide when registering your hor77 account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account settings.
• Automated technical collection: Data collected automatically when you access the Platform — including your IP address, device type, browser information, session timing, and pages visited — via server logs, cookies, and similar tracking technologies.
• Payment processors: Transaction confirmation data received from Easypaisa, JazzCash, Raast, and bank transfer systems when you initiate a deposit or withdrawal on hor77.
• Identity verification providers: Data received from third-party KYC verification services that assist hor77 in confirming the authenticity of identity documents submitted by Pakistan players.
• Fraud prevention services: Risk signals and device reputation data received from third-party fraud prevention partners used to protect hor77 accounts and the platform from fraudulent activity.
• Responsible gaming databases: Where applicable, hor77 may check self-exclusion registries to identify individuals who have previously requested exclusion from online gambling platforms.

hor77 uses your personal data for the following purposes:

• Creating and managing your hor77 account, including login authentication and account security.
• Processing deposits to and withdrawals from your PKR account wallet via Easypaisa, JazzCash, Raast, HBL, UBL, MCB Bank, and USDT.
• Settling bets, resolving disputes, and generating account statements and transaction histories.
• Verifying your identity in accordance with KYC requirements and anti-money laundering obligations.
• Detecting and preventing fraud, unauthorised account access, and prohibited platform usage.
• Enforcing the 18+ age restriction and responsible gaming obligations applicable to your account.
• Sending operational communications including deposit confirmations, withdrawal notifications, security alerts, and account updates.
• Sending marketing communications about hor77 promotions and products, where you have provided consent or we have a legitimate interest — with the ability to opt out at any time.
• Improving the hor77 Platform through analysis of aggregate, anonymised usage patterns.
• Complying with legal obligations applicable to hor77's operation as an online gambling platform.

hor77 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to operate your hor77 account, process payments, settle bets, and deliver the Platform services you have requested.
• Legal obligation: Processing required to comply with anti-money laundering legislation, KYC requirements, responsible gaming obligations, and other applicable legal duties.
• Legitimate interests: Processing for fraud prevention, account security, Platform improvement, and certain direct marketing activities, where our interests are not overridden by your privacy rights.
• Consent: Processing for optional marketing communications and certain cookie-based tracking, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

hor77 does not sell your personal data to third parties. We share your data only in the following limited and controlled circumstances:

• Payment processors: Easypaisa, JazzCash, Raast, HBL, UBL, MCB Bank, and USDT exchange services receive the minimum data necessary to process your deposit or withdrawal transactions.
• KYC and identity verification partners: Third-party identity verification services receive your submitted identity documents solely to verify authenticity. These partners operate under binding data processing agreements with hor77.
• Game software providers: Your account reference and session data is shared with game providers — such as Evolution, Pragmatic Play, or Ezugi — for the purpose of delivering game sessions. These providers do not receive your full personal identity or financial data.
• Fraud prevention services: Risk signals are shared with anti-fraud partners to protect the integrity of the hor77 Platform.
• Legal authorities: hor77 may disclose personal data to competent legal, regulatory, or law enforcement authorities where required by applicable law or court order.
• Responsible gaming organisations: In circumstances where a responsible gaming intervention requires notification, anonymised or specifically mandated data may be shared with self-exclusion scheme operators.

All third-party recipients of your data are contractually bound to process it only for the specified purpose and to maintain appropriate security standards consistent with those of hor77.

hor77 uses cookies and similar technologies on the Platform to provide functionality, improve performance, and support certain analytics and marketing activities. Cookies used by hor77 fall into the following categories:

• Strictly necessary cookies: Required for core Platform functionality, including maintaining your login session, remembering your PKR wallet state, and enabling secure navigation between pages. These cannot be disabled.
• Functional cookies: Remember your preferences such as language, responsible gaming limit settings, and previously selected game categories to personalise your hor77 experience.
• Analytics cookies: Collect anonymised data about how Pakistan players navigate and use the Platform, helping hor77 identify performance improvements and usability issues. hor77 uses only aggregated, non-identifiable analytics data.
• Security cookies: Used to detect and prevent fraudulent login attempts, bot activity, and other security threats to hor77 accounts.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the core hor77 Platform, though some convenience features may be affected.

hor77 recognises the following privacy rights of Pakistan players in respect of their personal data held by hor77:

To exercise any of the above rights, please contact the hor77 Data Protection team via live chat support or by email at the address in Section 15. hor77 will respond to all verified requests within 30 days. We may request proof of identity before processing a data subject request to protect against unauthorised access to another person's data.

hor77 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal obligation. The following retention guidelines apply:

• Account and identity data: Retained for the lifetime of the account plus 7 years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Financial and transaction data: Retained for 7 years from the date of each transaction, in accordance with financial record-keeping obligations.
• Betting and gaming records: Retained for 5 years from the date of each wager for dispute resolution and audit purposes.
• Support communications: Live chat transcripts and email records are retained for 2 years from the date of correspondence, or until resolution of any related dispute, whichever is longer.
• Technical and security logs: Retained for 13 months for security incident investigation purposes, then securely deleted.
• Marketing preferences and consent records: Retained for the duration of the account plus 3 years as evidence of consent or opt-out.

Upon expiry of applicable retention periods, personal data is securely and irreversibly deleted from hor77 systems. Where anonymisation is technically possible and appropriate, anonymised data may be retained indefinitely for aggregate statistical purposes without identifying individual Pakistan players.

hor77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure:

• All data in transit between your device and hor77 servers is encrypted using TLS 1.3 with 256-bit AES cipher suites.
• Personal data at rest on hor77 infrastructure is encrypted using AES-256 encryption at the storage level.
• Access to personal data within hor77's internal systems is controlled by role-based access policies. Only staff with a specific business need to access certain data categories are granted access.
• Regular internal security audits and external penetration testing are conducted to identify and remediate vulnerabilities.
• hor77 maintains an incident response plan that specifies notification procedures within 72 hours of a confirmed data breach affecting Pakistan player information.
• All third-party data processors are assessed for security compliance before onboarding and are required to maintain equivalent security standards under contractual terms.

While hor77 takes all reasonable precautions to protect your data, no online system is entirely immune to security risk. You play an important role in your own data security by maintaining a strong hor77 password and enabling Two-Factor Authentication on your account.

hor77 is strictly an 18+ platform. We do not knowingly collect, process, or retain personal data from individuals under the age of 18. Age verification is conducted as a mandatory part of the hor77 account registration and KYC process.

If hor77 becomes aware or has reasonable grounds to believe that personal data has been submitted by a person under 18, that data will be deleted immediately, the associated account will be closed, and any deposits made will be returned to their original payment source following investigation.

Parents or guardians who believe their minor child has created a hor77 account should contact the hor77 support team immediately via live chat or by email at the address in Section 15. hor77 treats all such reports as urgent matters and will act without delay.

Some of the third-party services used by hor77 — including game software providers, KYC verification partners, and fraud prevention services — may process personal data in jurisdictions outside Pakistan. Where such transfers occur, hor77 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to the protections described in this Policy.

Safeguards applied to international transfers include contractual data protection clauses binding third-party recipients to equivalent data security and privacy standards, and selection of partners operating in jurisdictions with recognised data protection frameworks.

hor77 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform functionality. Where changes are material — meaning they significantly affect your rights or how your data is used — hor77 will notify registered Pakistan account holders by email at least 14 days before the updated Policy takes effect.

For minor clarifications and non-substantive updates, hor77 will update the Policy with immediate effect and publish a notice on the Platform. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision.

Your continued use of the hor77 Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you should close your account before the effective date and contact the hor77 support team to arrange return of your PKR balance.

For all privacy-related enquiries, data subject access requests, or complaints regarding hor77's handling of your personal data, please contact us using the details below:

• Live chat: 24/7 English live chat support available directly on the hor77 Platform. Select "Privacy / Data Protection" as the query category when prompted.
• Email: [email protected] (plain text — not a clickable link). Include "Privacy Request" in the subject line and your registered email address in the body of your message so we can locate your account.

hor77 aims to acknowledge all privacy requests within 5 business days and to provide a substantive response within 30 days. Complex requests — such as full data access requests requiring extensive system queries — may take up to 60 days, in which case we will notify you of the extended timeline promptly.

If you are not satisfied with hor77's response to a privacy complaint, you may have the right to escalate the matter to a relevant supervisory authority in your jurisdiction. hor77 will not penalise you in any way for making a privacy complaint or for exercising any of your data rights.