Privacy Policy — hm77

Introduction

This Privacy Policy ("Policy") describes how hm77 ("we", "us", "our"), the operator of the information platform at hm77.cam (the "Platform"), collects, uses, stores and protects personal data relating to individuals ("you", "your") who access or use the Platform.

hm77 is an English-language online betting and casino information platform serving users across Pakistan — including users in Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar — and internationally. The Platform provides educational and informational content about online sports betting, live casino, PKR deposit and withdrawal processes, and responsible gambling. hm77 does not operate a gambling service, does not accept bets or wagers, and does not process financial transactions on behalf of users.

We are committed to handling personal data responsibly, transparently and in accordance with applicable data protection principles. This Policy sets out in plain English what data we collect, why we collect it, how long we keep it, and what your rights are with respect to that data.

Definitions

"Personal Data"

Any information relating to an identified or identifiable natural person — including name, email address, IP address, device identifiers and browsing behaviour on this Platform.

"Processing"

Any operation performed on personal data, including collection, storage, use, disclosure, alteration and deletion.

"Data Controller"

The entity that determines the purposes and means of processing personal data. For data collected through hm77.cam, the Data Controller is hm77.

"Data Processor"

A third party that processes personal data on behalf of the Data Controller under a written agreement — for example, an analytics service provider or hosting provider.

"Cookies"

Small text files placed on your device by a website to store information about your visit, such as session state and preference settings.

"User" / "You"

Any individual who accesses or uses hm77.cam, regardless of whether they submit personal data to the Platform.

"Platform"

The hm77 website accessible at hm77.cam, including all pages, guides and content published under that domain.

Data Controller

The Data Controller for personal data collected through the Platform is hm77, operating the website at hm77.cam. For all data-related enquiries, requests or complaints, users should contact hm77 using the details set out in Section 16 of this Policy.

• hm77 does not maintain a registered physical office in Pakistan. Contact is available exclusively via the email address provided in Section 16.
• hm77 is not affiliated with, operated by, or subject to oversight from the State Bank of Pakistan, the Pakistan Telecommunication Authority, or any Pakistani government body for the purposes of data processing.
• Where hm77 engages third-party data processors (e.g., hosting or analytics providers), those processors are bound by appropriate data processing agreements and may not use your data for their own independent purposes.

Data We Collect

hm77 collects a limited set of data to operate the Platform effectively. The categories of data we may collect are described below.

• hm77 does not collect payment information, bank account details, CNIC numbers, passport numbers or other sensitive financial or identity data from users at any point.
• hm77 does not request or store passwords, gambling account credentials or PKR transaction records relating to third-party operator accounts.
• Where users voluntarily submit an email address for enquiry purposes, that address is used solely to respond to the enquiry and is not added to any marketing list without explicit separate consent.
• Data collected through the Platform is kept to the minimum necessary to achieve the purposes described in Section 5.

Purposes of Processing

hm77 processes personal data only for the following purposes:

• Platform Operation: To serve web pages, maintain platform performance and ensure the technical stability of hm77.cam for all users.
• Analytics & Improvement: To understand how users interact with the Platform — which guides are most read, how navigation flows work, which content categories attract the most engagement — so that content and user experience can be improved over time.
• Enquiry Handling: To receive and respond to user questions, feedback or requests submitted through the Platform's contact features.
• Security & Fraud Prevention: To detect, investigate and address abuse, malicious access attempts, automated scraping or other misuse of the Platform.
• Legal Compliance: To comply with any applicable legal obligation, including responding to lawful requests from competent legal authorities.
• Content Personalisation (Limited): To remember user preferences such as language settings or display options within a single browsing session. hm77 does not build persistent behavioural profiles of individual users.

Legal Basis for Processing

hm77 processes personal data on the following legal bases, depending on the nature of the data and the processing activity:

• Legitimate Interests: For technical data and usage data collected automatically, processing is based on hm77's legitimate interest in operating, maintaining and improving the Platform, provided that interest is not overridden by user rights and freedoms.
• Consent: For non-essential cookies placed on a user's device, processing is based on consent where required by applicable law. Users may withdraw cookie consent at any time by adjusting their browser settings.
• Contractual Necessity: For data submitted voluntarily by a user making an enquiry, processing is necessary to respond to that request and fulfil the communication the user has initiated.
• Legal Obligation: hm77 may process and disclose personal data where required to comply with a binding legal obligation, lawful court order or regulatory requirement from a competent authority.

Cookies & Tracking Technologies

hm77 uses cookies and similar technologies to operate and improve the Platform. The types of cookies in use are described below.

• hm77 does not place advertising cookies, retargeting pixels or social media tracking cookies on your device without explicit disclosure.
• You can control cookie placement through your browser settings. Most modern browsers allow you to block or delete cookies — refer to your browser's help documentation for instructions. Disabling essential cookies may affect Platform functionality.
• hm77 does not use fingerprinting technology or cross-site tracking techniques to identify or track users across other websites.
• If third-party analytics tools are used (e.g., for aggregated traffic analysis), those tools are configured to anonymise IP addresses where technically possible and are not permitted to use data collected on hm77 for their own commercial purposes.

Data Sharing & Disclosure

hm77 does not sell, rent or trade personal data. We may share data in the following limited circumstances only:

• Service Providers: We may share data with trusted third-party service providers who process data on our behalf — including web hosting providers, analytics platforms and content delivery networks. All such providers are bound by data processing agreements that restrict their use of your data.
• Legal Requirements: We may disclose personal data to law enforcement agencies, regulatory authorities or courts where we are legally required to do so by a binding legal obligation or valid court order. We will not disclose data voluntarily in excess of what is legally required.
• Business Transfers: In the event of a merger, acquisition or transfer of hm77's operational assets, personal data held by hm77 may be transferred to the successor entity, subject to the same data protection obligations described in this Policy.
• Safety & Security: We may disclose data where we have a good-faith belief that disclosure is necessary to protect the safety, rights or property of hm77, its users or third parties — for example, in response to credible threats or active security incidents.
• hm77 does not share personal data with Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah, or any other Pakistani payment provider, financial institution or government body in the ordinary course of business.

Data Retention

• hm77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required to comply with applicable legal obligations.
• Server log data (including IP addresses and technical access records) is retained for a maximum of 90 days unless retention is required for an active security investigation.
• Analytics data in aggregated, anonymised form may be retained indefinitely for Platform improvement purposes, as it cannot be used to identify individual users.
• Enquiry correspondence (emails and contact submissions) is retained for a maximum of 12 months following the closure of the relevant enquiry, after which it is securely deleted.
• When the retention period for any category of data expires, hm77 will securely delete or anonymise that data so that it can no longer be attributed to an individual.
• Users may request early deletion of personal data held about them by submitting a written deletion request to the contact address in Section 16. Such requests are subject to the limitations described in Section 11.

Security Measures

hm77 applies reasonable technical and organisational security measures to protect personal data from unauthorised access, disclosure, alteration, loss or destruction. Measures in place include:

• SSL/TLS encryption for all data transmitted between user browsers and the Platform servers.
• Access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Regular review of hosting and infrastructure configurations to identify and address security vulnerabilities.
• Use of reputable, security-audited hosting and content delivery infrastructure.

Your Rights

Subject to applicable law, users have the following rights in relation to personal data hm77 holds about them:

• To exercise any of the rights above, submit a written request to the contact details in Section 16. hm77 will respond within a reasonable period and in any event within 30 days of receiving a valid request.
• hm77 may need to verify your identity before fulfilling a data rights request to ensure data is not disclosed to an unauthorised party.
• Some rights are subject to limitations under applicable law — for example, data that is required to be retained for legal compliance purposes cannot be deleted early.
• hm77 does not charge a fee for processing data rights requests in standard circumstances. Where requests are manifestly unfounded or excessive, hm77 reserves the right to charge a reasonable administrative fee.

Minors & Age Policy

• The Platform is intended for users who are at least 18 years of age, or the higher minimum age required by the applicable operator or license jurisdiction, as the content relates to gambling and betting information.
• hm77 does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been submitted by a minor, we will take prompt steps to delete that data.
• If you are a parent or guardian and believe that your child has provided personal data to hm77 without your consent, please contact us immediately using the details in Section 16.
• hm77 does not actively verify the age of users who browse the Platform passively. Users bear responsibility for ensuring that access by minors within their household is prevented.

International Data Transfers

• Personal data collected through hm77.cam may be stored or processed on servers located outside Pakistan, depending on the infrastructure and service providers used to operate the Platform.
• Where personal data is transferred outside Pakistan, hm77 takes reasonable steps to ensure that appropriate safeguards are in place — including the use of reputable, security-audited service providers — to protect that data to a standard consistent with this Policy.
• hm77 does not make transfers of personal data to parties in jurisdictions with materially lower data protection standards without appropriate contractual safeguards in place.
• By using the Platform from Pakistan or any other jurisdiction, users acknowledge that their data may be processed in countries outside their own jurisdiction, which may have different data protection rules.

Third-Party Platforms & Operator Independence

• hm77 content may describe or reference third-party gambling operators, game studios, payment providers and sports organisations. This Policy applies only to data collected by hm77 through hm77.cam and does not govern the data practices of any third-party platform.
• If you navigate to a third-party gambling operator or any other external platform referenced in hm77 content, that platform's own privacy policy governs the collection and use of your data. hm77 has no visibility into, control over or responsibility for how third-party platforms handle your personal data.
• hm77 strongly recommends that users review the privacy policies of any third-party platform before providing personal data, completing registration, or engaging in financial transactions on those platforms.
• Payment providers referenced on hm77 — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah — operate under their own independent privacy and data-processing frameworks. Their mention on hm77 does not imply any data-sharing relationship with hm77.

Policy Changes

• hm77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations or Platform features.
• Revised versions of this Policy will be published at this URL with an updated "Last Updated" date. Changes take effect immediately upon publication.
• Continued use of the Platform following the publication of an updated Policy constitutes acceptance of the revised terms.
• For material changes that significantly affect how we use your personal data, hm77 will make reasonable efforts to bring those changes to users' attention — for example, by means of a prominent notice on the Platform homepage.
• We recommend that users review this Policy periodically to remain informed of our current data practices. hm77 is not responsible for users who are unaware of updates because they did not review the Policy.

Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a complaint about hm77's data practices, please contact us using the details below. Email addresses are shown as plain text only and are not clickable links.

Where you have submitted a data rights request and are not satisfied with hm77's response, you may have the right to lodge a complaint with a relevant supervisory or data protection authority in your jurisdiction. Users in Pakistan should be aware that the applicable regulatory framework for data protection is evolving — hm77 recommends consulting a qualified legal professional for jurisdiction-specific guidance.