This Privacy Policy explains how xpk77 collects, uses, stores, shares and protects the personal data of users who access the Platform — including Pakistani users across Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. Please read this document carefully before using the Platform.
1.1 This Privacy Policy ("Policy") describes the data processing practices of xpk77 ("xpk77", "we", "us", "our") in relation to the website accessible at https://xpk77.cam (the "Platform") and all associated services.
1.2 xpk77 is an English-language online gaming information and entertainment platform. We take the privacy of our users — including all Pakistani users across the country — seriously and are committed to handling personal data responsibly, transparently and in accordance with applicable data protection standards.
1.3 By accessing or using the Platform, registering an account, interacting with any Platform feature or submitting any personal information to us, you acknowledge that you have read this Policy and consent to the data practices described herein.
1.4 If you do not agree with any part of this Policy, you should discontinue your use of the Platform and, if applicable, request that your Account be closed and your personal data deleted in accordance with the procedures described in Section 12 (Your Rights).
1.5 This Policy should be read in conjunction with our Terms & Conditions, which govern your overall use of the Platform.
The following definitions apply throughout this Privacy Policy:
| Term | Meaning |
|---|---|
| "Personal Data" | Any information that identifies, or could reasonably identify, a living individual — including name, email address, CNIC number, IP address, device identifiers and behavioural data. |
| "Processing" | Any operation performed on personal data, including collection, storage, use, disclosure, adaptation, retrieval, consultation, erasure or destruction. |
| "Data Controller" | The entity that determines the purposes and means of processing personal data — in this case, xpk77. |
| "Data Processor" | A third party that processes personal data on behalf of xpk77 under contractual instruction — such as a payment processor or identity verification provider. |
| "Consent" | A freely given, specific, informed and unambiguous indication of agreement to personal data being processed for a stated purpose. |
| "KYC" | Know Your Customer — the identity verification process requiring users to provide government-issued identification (e.g., CNIC for Pakistani users) and supporting documents. |
| "Cookies" | Small text files placed on your device by the Platform that store session information, preferences and behavioural data to improve Platform functionality and analytics. |
3.1 xpk77 acts as the Data Controller for the personal data collected through the Platform. As Data Controller, we determine the purposes for which your personal data is processed and the means by which that processing takes place.
3.2 Where third-party service providers (Data Processors) process personal data on our behalf — such as payment verification services, identity checking providers, or analytics platforms — they do so strictly under contractual data processing agreements that bind them to handle your data in accordance with this Policy and applicable data protection standards.
3.3 xpk77 can be contacted in relation to data protection matters at the contact details set out in Section 16 of this Policy.
4.1 xpk77 collects personal data through several channels: directly from you when you register or use the Platform; automatically through your device and browser when you access the Platform; and in some cases, from authorised third parties such as identity verification services.
4.2 Registration and Account Data
When you create an Account, we collect:
4.3 Identity Verification (KYC) Data
To comply with applicable verification requirements and to prevent fraud, we may collect:
4.4 Payment and Transaction Data
When you make deposits or request withdrawals, we collect data including:
4.5 Gameplay and Behavioural Data
4.6 Technical and Device Data
4.7 Communications Data
When you contact our support team via live chat or email, we retain records of those communications — including your messages, support tickets, and any attachments — for quality assurance, dispute resolution and compliance purposes.
5.1 xpk77 uses your personal data only for the purposes set out in this Policy. The primary uses are described in the table below:
| Purpose | Data Categories Used |
|---|---|
| Account creation and management | Registration data, KYC data, communications data |
| Identity verification (KYC) | KYC data, payment data, registration data |
| Processing deposits and withdrawals | Payment data, KYC data, transaction data |
| Delivering Platform services | Account data, gameplay data, technical data |
| Fraud prevention and security | Technical data, payment data, KYC data, behavioural data |
| Anti-money laundering (AML) compliance | KYC data, transaction data, communications data |
| Responsible gambling monitoring | Gameplay data, account data, self-exclusion records |
| Customer support | Communications data, account data, transaction data |
| Marketing and promotions (with consent) | Account data, communications data, gameplay data |
| Platform analytics and improvement | Technical data, behavioural data, cookie data |
| Legal and regulatory obligations | All categories as required by applicable law |
5.2 xpk77 will not use your personal data for purposes materially different from those listed above without providing you with prior notice and, where required, obtaining your consent.
6.1 xpk77 processes personal data on one or more of the following legal bases, depending on the specific processing activity:
7.1 xpk77 does not sell, rent or trade your personal data to third parties for commercial purposes. We may share your personal data in the following limited circumstances:
7.2 All third-party Data Processors engaged by xpk77 are required to: (a) process personal data only on documented instructions from xpk77; (b) implement appropriate technical and organisational security measures; and (c) not engage sub-processors without xpk77's prior written authorisation.
8.1 xpk77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory or compliance obligations.
8.2 General retention guidelines applied by xpk77 are as follows:
8.3 When personal data is no longer required, xpk77 will securely delete or anonymise it in a manner that prevents reconstruction of the original personal data.
9.1 xpk77 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration or disclosure. These measures include but are not limited to:
9.2 Data Breach Procedures. In the event of a personal data breach that poses a risk to your rights and freedoms, xpk77 will notify affected users and relevant regulatory authorities without undue delay and in accordance with applicable legal requirements. Notification will include a description of the nature of the breach, likely consequences and the measures taken or proposed to address it.
9.3 While xpk77 takes reasonable precautions to protect your personal data, no method of internet transmission or electronic storage is 100% secure. You accept residual risk by choosing to use the Platform and are responsible for maintaining the security of your own login credentials.
10.1 xpk77 uses cookies and similar tracking technologies (including pixels, local storage and session storage) to operate the Platform, remember your preferences, analyse usage and improve the user experience for Pakistani users.
10.2 The following categories of cookies are used on the Platform:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Essential for Platform operation — login session management, security tokens, load balancing. Cannot be disabled. | Session |
| Functional | Remember your preferences such as language, currency display (PKR) and responsible gambling limit settings. | Up to 12 months |
| Analytics | Track aggregated Platform usage patterns — pages visited, session duration, device types, geographic region (city/country level only). Used to improve Platform performance and content. | Up to 24 months |
| Marketing | Where consent has been provided, track interactions with promotional content to measure effectiveness. Subject to separate consent. | Up to 12 months |
10.3 You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the Platform. For other cookie categories, you may opt out without affecting core Platform access.
10.4 xpk77 does not use cookies to track sensitive personal data such as payment card details or government identification numbers.
11.1 xpk77's Platform infrastructure and some of its third-party Data Processors may be located in countries outside Pakistan. When personal data is transferred to such countries, xpk77 takes steps to ensure that appropriate safeguards are in place to protect your data to a standard equivalent to this Policy.
11.2 Safeguards for international transfers may include: (a) contractual data protection clauses between xpk77 and the Data Processor; (b) use of processors located in jurisdictions with recognised data protection frameworks; or (c) other legally recognised transfer mechanisms.
11.3 Where you are a Pakistani user, please note that Pakistan's data protection landscape is evolving. xpk77 commits to applying data protection standards that are reasonable and proportionate to the nature of the data processed, regardless of the physical location of storage.
12.1 xpk77 respects your rights over your personal data. The following rights are available to all Platform users, subject to applicable legal exceptions:
12.2 To exercise any of the above rights, please contact xpk77 at the details provided in Section 16. We will respond to verified requests within 30 days. Where requests are complex or numerous, we may extend this period by a further 60 days, and will inform you of any such extension.
12.3 xpk77 may need to verify your identity before processing a data rights request to ensure we are not disclosing or deleting another person's data in error.
13.1 The Platform is strictly for adults aged 18 years or older, or the higher minimum age required by the applicable operator licence jurisdiction. xpk77 does not knowingly collect personal data from minors.
13.2 Age verification is performed during the KYC process. Any Account found to have been registered by a person under the applicable minimum age will be closed immediately, and the relevant personal data will be handled in accordance with applicable responsible gambling and regulatory requirements.
13.3 If you are a parent or guardian and believe your child has registered an Account on xpk77, please contact our support team immediately so that the Account can be investigated and closed. The child's personal data will be deleted to the extent permitted by applicable legal retention obligations.
14.1 The Platform may contain references to or integrations with third-party services — such as payment providers, game studios or analytics platforms. xpk77 does not control and is not responsible for the data practices of third-party services. Each third party's data handling is governed by its own privacy policy.
14.2 Payment provider names referenced on xpk77 — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — are used as familiar Pakistani payment references in an educational context. Their mention does not imply data sharing with those providers except where specifically required to process a transaction you initiate.
14.3 xpk77 is not responsible for the content, privacy practices or data security of any third-party websites or services, whether or not they are referenced on the Platform.
15.1 xpk77 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law or Platform functionality. The "Last Updated" date at the top of this page will be revised whenever a material change is made.
15.2 Where changes are material — meaning they significantly affect your rights or how we use your data — xpk77 will make reasonable efforts to notify you in advance via email or a prominent Platform notification.
15.3 Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of that revised Policy. If you do not agree to the changes, you should close your Account and request deletion of your personal data in accordance with Section 12.
15.4 We encourage all Platform users to review this Policy periodically — particularly Pakistani users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar who access the Platform regularly.
16.1 For any questions, concerns or requests relating to this Privacy Policy, the personal data we hold about you, or the exercise of your data rights, please contact xpk77 through the following channels:
Data rights requests, privacy queries and complaints:
[email protected]Response time: within 30 days for data rights requests; 24–48 hours for general enquiries on business days.
Available during peak Pakistan hours for initial queries and support:
12:00 PM – 12:00 AM PST (UTC+5)For complex data rights matters, please follow up by email to ensure a documented record of your request.
When submitting a data rights request, please include your registered account email address and a description of your request so we can verify your identity and respond accurately. xpk77 will not charge a fee for responding to data rights requests unless they are manifestly unfounded, excessive or repetitive.
Six principles that guide how xpk77 handles personal data for every user, including Pakistani users across the country.
xpk77 does not sell, rent or trade your personal data to any third party for commercial purposes. Your data exists to operate your Account and keep the Platform secure — nothing else.
All data transmitted between your device and our servers uses SSL/TLS encryption. Passwords are hashed. Sensitive identifiers are masked. Pakistani users on mobile networks benefit from the same encryption standards as desktop users.
Access, rectification, erasure, portability and objection rights are not just listed in a policy document — they are actually processable. Contact our support team and your request will be handled within 30 days.
We collect only the data we genuinely need to operate the Platform and comply with applicable obligations. We do not collect personal data speculatively or "just in case." Every data category serves a defined purpose.
We use strictly necessary cookies to operate the Platform, functional cookies to remember your PKR display preference and responsible gambling settings, and analytics cookies to improve content. Marketing cookies require separate consent.
We do not knowingly collect data from anyone under 18, or the higher minimum age where required. Age verification is mandatory during KYC. Any Account identified as belonging to a minor is closed immediately and the data handled responsibly.
If you have questions about how your data is used, want to exercise your rights, or need to report a privacy concern, our support team is available via live chat and email. Pakistani users from Karachi to Peshawar can reach us during peak PST hours.
🔒 Your privacy is taken seriously at xpk77. 🔞 18+ only. Please gamble responsibly.