1
Introduction
This Privacy Policy ("Policy") is published by tdd777 ("tdd777", "we", "us" or "our"),
the operator of the website accessible at https://tdd777.cam (the "Platform").
This Policy applies to all personal data collected, processed and stored by tdd777 in
connection with your use of the Platform.
tdd777 operates as an English-language online gaming information platform serving users
in Pakistan and other jurisdictions. We take data protection seriously and are committed
to handling your personal information with transparency, integrity and respect for your
privacy rights.
By registering on or continuing to use the Platform, you acknowledge that you have read
and understood this Privacy Policy and consent to the collection and use of your personal
data as described herein. If you do not agree with this Policy, please discontinue use
of the Platform immediately.
This Privacy Policy should be read in conjunction with our
Terms & Conditions, which are incorporated by reference.
In the event of any conflict between this Policy and the Terms & Conditions on a
privacy matter, this Policy shall prevail.
2
Definitions
In this Privacy Policy, the following terms shall have the meanings set out below:
- "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, CNIC number, IP address, device identifiers and financial data.
- "Processing" — any operation performed on personal data, including collection, recording, storage, use, disclosure, transmission, alteration, restriction or deletion.
- "Controller" — the entity that determines the purposes and means of processing personal data; in this context, tdd777.
- "Processor" — a third party that processes personal data on behalf of the Controller under contractual obligation.
- "Data Subject" — the individual to whom personal data relates; in this context, a registered User of the Platform.
- "KYC" — Know Your Customer; the identity and document verification process required for account compliance and withdrawal eligibility.
- "Cookie" — a small data file placed on your device by the Platform to support session management, analytics and preference storage.
3
Data We Collect
tdd777 collects personal data through several channels in connection with your use of
the Platform. The categories of data collected are set out below:
| Category |
Examples |
Collection Method |
| Registration Data |
Full name, date of birth, email address, username, password hash, country of residence, city (e.g., Karachi, Lahore, Islamabad) |
Account registration form |
| Identity Verification (KYC) |
CNIC number, passport number, government-issued ID document images, selfie/liveness verification |
KYC verification process |
| Financial Data |
Deposit and withdrawal transaction records, payment method identifiers (e.g., reference to Easypaisa, JazzCash, bank transfer), transaction amounts in PKR or other currencies |
Payment processing and cashier transactions |
| Technical Data |
IP address, device type, operating system, browser type and version, screen resolution, session timestamps |
Automatic collection during Platform use |
| Behavioural Data |
Pages visited, games played, session duration, click paths, betting history, bonus usage |
Platform analytics and session tracking |
| Communications Data |
Support enquiries, live chat transcripts, email correspondence content |
Customer support interactions |
| Responsible Gambling Data |
Deposit limits set, self-exclusion requests, session time limit preferences, cooling-off period records |
Responsible gambling tool usage |
Sensitive Data: KYC documentation (including CNIC and passport data) constitutes
sensitive personal data. tdd777 applies enhanced security controls to this category of data
and limits access to authorised compliance personnel only. This data is collected solely for
identity verification and anti-fraud compliance purposes.
4
Data Processing
tdd777 processes your personal data for the following specific and defined purposes:
-
Account Management: Creating and maintaining your registered account,
authenticating your identity upon login, and administering your account settings and preferences.
-
KYC and Anti-Fraud Compliance: Verifying your identity in accordance with
applicable anti-money laundering (AML) and Know Your Customer (KYC) obligations. This
includes processing identity documents to confirm eligibility and prevent fraudulent activity.
-
Transaction Processing: Processing deposits and withdrawal requests, maintaining
accurate financial records, and communicating with payment processors. References to familiar
Pakistani payment rails (Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah)
are for identification of your selected payment method only; no endorsement of gambling by
these providers is implied.
-
Responsible Gambling Compliance: Operating responsible gambling tools
including deposit limits, self-exclusion enforcement, session time tracking and reality
check notifications. Data processed for these purposes is handled with heightened care
and is not used for marketing.
-
Customer Support: Responding to your enquiries, complaints and support
requests. Support communications are retained to maintain an accurate record of interactions
and to improve service quality.
-
Platform Security and Fraud Prevention: Monitoring for suspicious activity,
detecting and preventing multiple account registration, identifying pattern-based fraud and
protecting the integrity of the Platform.
-
Analytics and Platform Improvement: Analysing aggregated and anonymised
behavioural data to understand usage patterns, improve platform performance and enhance
the user experience for Pakistani users and others.
-
Legal and Regulatory Compliance: Retaining records as required by applicable
law, responding to lawful requests from competent authorities, and maintaining records
necessary for the resolution of disputes.
5
Lawful Basis for Processing
tdd777 processes your personal data only where a lawful basis for processing exists.
The primary bases relied upon are as follows:
-
Contractual Necessity: Processing required to perform the contract with you
constituted by the Terms & Conditions — including account creation, game access, payment
processing and customer support.
-
Legal Obligation: Processing required to comply with applicable legal and
regulatory requirements, including KYC/AML obligations and lawful authority requests.
-
Legitimate Interests: Processing necessary for tdd777's legitimate business
interests, including fraud prevention, platform security, analytics and service improvement,
provided such interests are not overridden by your rights and interests.
-
Consent: Where we rely on your consent for specific processing activities
(such as non-essential cookies or direct marketing communications), we will seek your
explicit consent beforehand. You may withdraw such consent at any time without affecting
the lawfulness of prior processing.
-
Vital Interests: In exceptional circumstances, we may process personal data
where necessary to protect your vital interests or those of another person, for example in
the context of a responsible gambling crisis situation.
6
Data Sharing
tdd777 does not sell your personal data. We may share personal data with the following
categories of third parties only to the extent necessary for the defined processing purposes:
-
Payment Processors: Third-party payment service providers that process
your deposit and withdrawal transactions. These processors receive only the data required
to execute the specific transaction. They are bound by contractual data protection
obligations and applicable payment industry standards.
-
KYC and Identity Verification Providers: Third-party identity verification
services that process KYC documentation on our behalf. These providers are engaged as
data processors under contractual agreement and are not permitted to use your data for
independent purposes.
-
Fraud Prevention and AML Services: Specialised third-party services that
assist tdd777 in detecting fraudulent activity, preventing money laundering and maintaining
compliance with applicable regulations.
-
Analytics Providers: Platform analytics services that process aggregated
or pseudonymised behavioural data to support performance monitoring and user experience
improvement. Where consent is required for such processing, it will be sought.
-
Legal and Regulatory Authorities: tdd777 may disclose personal data to
competent legal, regulatory or law enforcement authorities where required by applicable
law, court order or legally binding regulatory request. Voluntary disclosure will not
be made without a lawful basis.
-
Business Transfers: In the event of a merger, acquisition, restructuring
or sale of tdd777 or its assets, your personal data may be transferred to the acquiring
entity, subject to the same level of data protection as described in this Policy. You
will be notified of any such transfer where practically possible.
Data Processor Contracts: All third-party processors engaged by tdd777
are subject to written data processing agreements that impose obligations equivalent to
those applicable to tdd777, including confidentiality, security and purpose-limitation
requirements.
7
Cookies & Tracking Technologies
tdd777 uses cookies and similar tracking technologies to support the operation, security
and performance of the Platform. The categories of cookies used are:
-
Strictly Necessary Cookies: Required for core Platform functionality,
including session authentication, security token management and account login. These
cookies cannot be disabled without impacting your ability to use the Platform.
-
Functional Cookies: Used to remember your preferences, such as language
settings, odds format selection and responsible gambling tool configurations.
-
Analytics Cookies: Used to collect aggregated data about how users
interact with the Platform, supporting performance improvements. Where consent is required
for analytics cookies, we will request it via a cookie consent mechanism.
-
Security Cookies: Used to detect and prevent fraud, protect against
automated attacks and maintain the integrity of login sessions.
You may control non-essential cookies through your browser settings. Please note that
disabling certain cookies may affect the functionality of specific Platform features.
Detailed cookie management instructions are available through your browser's help documentation.
8
Data Retention
tdd777 retains personal data only for as long as is necessary for the purposes for which
it was collected, or as required by applicable legal, regulatory or compliance obligations.
The following general retention principles apply:
-
Active Account Data: Personal data associated with an active account is
retained for the duration of the account's existence on the Platform.
-
Closed Account Data: Following account closure, personal data is retained
for a minimum period as required by applicable anti-money laundering and financial record-keeping
regulations. This period is typically five to seven years from the date of the last transaction,
subject to the applicable legal framework.
-
KYC Documentation: Identity verification documents are retained for the
period required by applicable AML regulations in the relevant jurisdiction, and are securely
deleted thereafter.
-
Transaction Records: Financial transaction records are retained for the
period required by applicable financial and regulatory record-keeping obligations.
-
Support Communications: Customer support records are retained for a defined
operational period to support dispute resolution and service quality improvement, and are
subsequently archived or deleted.
-
Analytics Data: Aggregated and anonymised analytics data may be retained
indefinitely as it does not constitute personal data upon anonymisation.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised
in accordance with tdd777's data disposal procedures.
9
Data Security
tdd777 implements appropriate technical and organisational measures to protect your personal
data against accidental loss, unauthorised access, disclosure, alteration or destruction.
Specific security measures in place include:
- Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the Platform;
- Encryption of stored sensitive personal data, including KYC documentation and financial records;
- Role-based access controls limiting personal data access to authorised personnel with a demonstrated operational need;
- Multi-factor authentication requirements for administrative system access;
- Regular security assessments and vulnerability monitoring of Platform infrastructure;
- Incident response procedures for the detection, investigation and notification of data security incidents.
Your Security Responsibilities: While tdd777 takes extensive measures to
protect your data, the security of your account also depends on actions within your control.
You are responsible for maintaining the confidentiality of your login credentials, using a
strong unique password, and notifying tdd777 immediately if you suspect unauthorised access
to your account.
In the event of a personal data breach that poses a risk to your rights and interests,
tdd777 will take steps to notify affected users and relevant authorities in accordance with
applicable data protection law and within required notification timeframes.
10
User Rights
Subject to applicable data protection law, you hold the following rights in relation to
the personal data held by tdd777. You may exercise any of these rights by contacting us
at the support email address provided in Section 14 of this Policy.
You have the right to request a copy of the personal data tdd777 holds about you,
along with information about how that data is processed, the purposes of processing,
the categories of data held and the recipients of that data. Access requests will be
responded to within the timeframe required by applicable law (typically 30 days).
You have the right to request correction of any inaccurate or incomplete personal data
held by tdd777. Rectification requests should be submitted with supporting evidence
where the correction relates to identity or financial data. We will action verified
rectification requests promptly.
You may request deletion of your personal data in certain circumstances — for example,
where the data is no longer necessary for the purpose for which it was collected, where
you withdraw consent and no other lawful basis exists, or where processing is unlawful.
This right is subject to exceptions where retention is required by law, including AML
and financial record-keeping obligations which may override a deletion request.
You may request that tdd777 restricts the processing of your personal data in certain
situations — for example, while you contest the accuracy of data we hold, or while an
objection to processing is being assessed. During a restriction period, your data will
be stored but not actively processed beyond what is legally required.
Where processing is based on your consent or on contract, and is carried out by automated
means, you have the right to receive your personal data in a structured, commonly used
and machine-readable format, and to request that this data be transmitted to another
controller where technically feasible.
You have the right to object to processing of your personal data where that processing
is based on tdd777's legitimate interests. Where you raise an objection, we will cease
processing unless we can demonstrate compelling legitimate grounds that override your
interests, rights and freedoms, or unless processing is required for legal claims.
Exercising Your Rights: All rights requests should be submitted to
[email protected].
Please include your registered account username and a clear description of the right
you wish to exercise. We will respond within the timeframe required by applicable
data protection law — typically 30 days from receipt of a valid request.
11
Minors
The Platform is strictly intended for adults aged 18 years and above, or the higher
minimum age required by the applicable operator's license jurisdiction. tdd777 does not
knowingly collect personal data from persons under this age threshold.
If tdd777 becomes aware that personal data has been collected from a minor without
appropriate parental or guardian consent, we will take immediate steps to delete that
data and close the associated account. If you believe that a minor has registered on
the Platform, please contact us immediately at the support email address in Section 14.
tdd777 implements age verification controls during the registration process and through
KYC procedures to minimise the risk of minor access to the Platform. We take our
obligations in this area seriously and do not permit any exceptions to the minimum
age policy.
12
International Data Transfers
tdd777 and certain of its third-party processors may operate from or store data in
jurisdictions outside the country in which you reside. Where personal data is transferred
internationally, tdd777 ensures that appropriate safeguards are in place to maintain
an equivalent level of data protection, including:
- Transfers to jurisdictions that have been assessed as providing adequate data protection;
- Use of contractual safeguards, including standard data protection clauses, where transfers occur to jurisdictions without an adequacy assessment;
- Binding data processor agreements that impose appropriate security and purpose-limitation obligations on the recipient.
Users in Pakistan should note that data protection law in Pakistan is evolving. tdd777
does not claim that all processing activities are subject to Pakistani data protection
legislation. Users are encouraged to review applicable Pakistani law and seek independent
advice regarding their data protection rights in the Pakistani legal context.
13
Policy Amendments
tdd777 reserves the right to update or amend this Privacy Policy at any time to reflect
changes in applicable law, data protection best practice, Platform functionality or
business operations. When material changes are made to this Policy, we will:
- Update the "Last Updated" date at the top of this page;
- Where practically possible, notify registered users via account notification or email;
- Maintain the previous version of the Policy available for a reasonable period following any material update.
Your continued use of the Platform following publication of an updated Privacy Policy
constitutes your acceptance of the revised terms. If you do not agree with a material
amendment, you should discontinue use of the Platform and may request account closure
in accordance with the procedures described in our Terms & Conditions.
We recommend bookmarking this page and reviewing the Policy periodically, particularly
prior to any financial transactions on the Platform.