SECTION 1
Who We Are — Data Controller
ra777 is the operator of the online gaming platform accessible at ra777.bio (and any associated subdomains or mobile-optimised interfaces). For the purposes of this Privacy Policy, ra777 acts as the data controller in respect of personal data collected from players and visitors to the platform.
ra777 operates under an internationally recognised gaming licence. Our platform is designed and maintained for use by Pakistani players and is operated with an understanding of the local digital ecosystem — including Pakistani mobile wallets (JazzCash, EasyPaisa), national identity infrastructure (CNIC), and local banking institutions (HBL, UBL, Meezan Bank).
If you have any questions about how ra777 handles your personal data, or if you wish to exercise any of your data rights, please contact our Data Protection point of contact at [email protected].
SECTION 2
Categories of Personal Data We Collect
ra777 collects personal data across several categories. The table below sets out the types of data we collect, why we collect it, and the primary legal basis for doing so:
| Data Category |
Examples |
Primary Purpose |
| Registration Data |
Full name, Pakistani mobile number, date of birth, username, password (hashed) |
Account creation and authentication |
| Identity Verification (KYC) |
CNIC number, CNIC scan (front & back), selfie photograph |
Age verification, identity verification, AML compliance |
| Financial Data |
JazzCash/EasyPaisa number, bank account details, deposit and withdrawal history, PKR balances |
Payment processing, fraud prevention, regulatory compliance |
| Gameplay Data |
Game session logs, bet amounts, win/loss records, game type, time and duration of play |
Service delivery, responsible gaming monitoring, dispute resolution |
| Device & Technical Data |
IP address, device type, browser type and version, operating system, screen resolution |
Security, fraud detection, platform optimisation |
| Usage Data |
Pages visited, features used, time on platform, navigation patterns, search queries within platform |
Platform improvement, user experience personalisation |
| Communication Data |
Support chat transcripts, email correspondence, feedback submissions |
Customer service, complaint resolution, quality assurance |
| Marketing Preferences |
Opt-in/opt-out status for SMS and email marketing, promotion interactions |
Personalised marketing (where consented) |
SECTION 3
How We Collect Your Data
ra777 collects personal data through the following channels and methods:
- Direct Submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or responding to a promotion.
- Automated Collection: Technical and usage data collected automatically when you access or use the ra777 platform, including via cookies, session logs, server logs, and analytics tools.
- Payment Providers: Transaction confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card payment processors when you make deposits or withdrawals. ra777 does not store complete card numbers — this data is handled by PCI-DSS compliant payment processors.
- Identity Verification Services: Where ra777 uses third-party identity verification providers to assist with CNIC validation, we may receive verification status and risk flag data from those providers.
- Game Providers: Aggregate and session-level gameplay data from the game studios whose titles are hosted on ra777.
ra777 does not purchase personal data from data brokers, scrape data from social media platforms, or acquire personal information about Pakistani users from any source other than the data collection methods described above.
SECTION 4
Legal Basis for Processing Your Data
ra777 processes your personal data on the following legal bases:
- Contractual Necessity: Processing required to create and maintain your account, process transactions, deliver games, and fulfil our service obligations under the ra777 Terms and Conditions.
- Legal Obligation: Processing required to comply with our international gaming licence conditions, anti-money-laundering obligations, KYC requirements, and applicable financial regulations.
- Legitimate Interests: Processing carried out for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring — where these interests do not override your fundamental data rights.
- Consent: Processing for marketing communications, optional analytics, and non-essential cookies, where you have provided explicit opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.
SECTION 5
How ra777 Uses Your Personal Data
Your personal data is used by ra777 for the following specific purposes:
- Creating, maintaining, and authenticating your ra777 player account;
- Processing PKR deposits and withdrawals via JazzCash, EasyPaisa, and banking channels;
- Verifying your identity and age (21+) in accordance with KYC requirements;
- Detecting, investigating, and preventing fraudulent activity, account sharing, and bonus abuse;
- Monitoring gameplay patterns to identify signs of problem gambling and provide responsible gaming interventions;
- Providing customer support in English and Urdu through live chat and email channels;
- Complying with AML obligations, including transaction monitoring and suspicious activity reporting;
- Sending transactional notifications — deposit confirmations, withdrawal updates, account security alerts — via SMS to your registered Pakistani mobile number;
- Sending marketing communications about promotions, new games, and platform updates, where you have opted in;
- Analysing platform usage patterns to improve the ra777 user experience and game library;
- Resolving disputes relating to game outcomes, transactions, or account matters;
- Maintaining records required by our international gaming licence for audit and regulatory review purposes.
Automated Decision-Making: ra777 uses automated systems for fraud detection and account risk assessment. Where an automated decision results in account suspension or restriction, you have the right to request a manual review by contacting support within fourteen (14) days of the automated action.
SECTION 6
Data Sharing & Third-Party Disclosure
6.1 General Principle. ra777 does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. Your data is shared only with the categories of recipients described in this section, and only to the extent necessary for the stated purpose.
6.2 Service Providers. ra777 engages third-party service providers to assist in platform operation. These providers process data on our behalf, under contractual data processing agreements that obligate them to protect your data and use it only for the specified purpose. Categories include: payment processing, identity verification, cloud hosting infrastructure, game content delivery, customer support tooling, and fraud detection services.
6.3 Regulatory and Law Enforcement Disclosure. ra777 may be required to disclose personal data to regulatory bodies, licensing authorities, law enforcement agencies, or courts where required to do so by applicable law, court order, or our gaming licence conditions. Where possible, ra777 will notify affected players before making such disclosures, except where prohibited by law.
6.4 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of ra777 assets, your personal data may be transferred to the successor entity. You will be notified of any such transfer and given the opportunity to request deletion of your data before the transfer is completed, subject to applicable legal retention requirements.
ra777 will never disclose your personal data to any third party in exchange for commercial compensation. If you receive a communication claiming to represent ra777 and requesting sensitive data, please contact [email protected] immediately — this may indicate a phishing attempt.
SECTION 7
KYC & Identity Verification Data
7.1 What We Collect. As part of the Know Your Customer (KYC) process, ra777 collects a copy of your Computerised National Identity Card (CNIC) — front and back — along with a live selfie photograph taken at the time of verification. For larger withdrawal amounts or where additional risk indicators are present, ra777 may request supplementary documentation such as proof of payment method ownership.
7.2 Why We Collect It. KYC data is collected to: (a) verify that you are at least 21 years of age; (b) confirm that you are the registered owner of the account; (c) meet anti-money-laundering obligations under our international gaming licence; and (d) prevent identity fraud and multi-accounting.
7.3 How It Is Stored. CNIC images and selfie photographs are stored on encrypted servers with access restricted to authorised KYC compliance personnel. This data is not shared with any third party except identity verification service providers engaged specifically for KYC purposes under binding data processing agreements.
7.4 Retention Period. KYC documentation is retained for the duration of your account's existence plus an additional five (5) years following account closure, in compliance with AML record-keeping requirements under our gaming licence. At the expiry of this retention period, the data is securely and permanently deleted.
SECTION 8
Cookies & Tracking Technologies
8.1 What Cookies We Use. The ra777 platform uses the following categories of cookies and similar tracking technologies:
- Strictly Necessary Cookies: Essential for platform functionality — session management, login state preservation, and security token handling. These cannot be disabled without rendering the platform unusable.
- Performance Cookies: Used to collect aggregated data about how players use the platform — page load times, error rates, and feature usage. This data is used to identify and resolve technical issues.
- Functional Cookies: Store your platform preferences — language settings, game lobby layout, and notification preferences — to provide a consistent experience across sessions.
- Analytics Cookies: Used to understand aggregate usage patterns on the platform. Where consent is required for these cookies, we will request it before setting them.
8.2 Cookie Consent. Strictly necessary cookies are deployed without consent as they are required for the platform to function. For all other cookie categories, ra777 will present a cookie consent notice on your first visit and on subsequent visits where your consent preference has expired. You may update your cookie preferences at any time from your account settings.
8.3 Cookie Lifespan. Session cookies are deleted when you close your browser. Persistent cookies are retained for periods ranging from 30 days (analytics) to 12 months (preference storage), after which they expire and are renewed only with fresh consent where required.
SECTION 9
Data Security Measures
ra777 implements a multi-layer security architecture to protect your personal data against unauthorised access, disclosure, loss, or alteration:
- Encryption in Transit: All data transmitted between your device and ra777 servers is encrypted using TLS 1.3 with 256-bit AES encryption. This applies to login sessions, deposit flows, game sessions, and support chat.
- Encryption at Rest: Sensitive data stored on ra777 servers — including KYC documents, payment details, and account credentials — is encrypted at rest using AES-256 encryption.
- Password Security: Player passwords are never stored in plain text. They are processed using one-way cryptographic hashing with salting, meaning that even ra777 personnel cannot retrieve your original password.
- Access Controls: Internal access to personal data is restricted on a need-to-know basis. All internal access is logged and subject to regular access review. KYC documents are accessible only to KYC compliance personnel.
- Intrusion Detection: ra777 operates continuous security monitoring systems that detect and alert on anomalous access patterns, potential data breaches, and suspicious account activity in real time.
- Penetration Testing: The ra777 platform undergoes periodic third-party penetration testing. Identified vulnerabilities are patched on a priority basis aligned with severity ratings.
Despite these measures, no digital system can be guaranteed 100% secure. ra777 commits to notifying affected players without undue delay in the event of a data breach that is likely to result in a risk to their rights and freedoms.
SECTION 10
Data Retention
ra777 retains your personal data only for as long as is necessary for the purpose for which it was collected, or for such longer period as may be required by applicable law or our gaming licence obligations. The following general retention periods apply:
- Active Account Data: Retained for the full duration of your active account relationship with ra777.
- KYC and Identity Documents: Retained for the duration of account existence plus five (5) years post-closure.
- Financial Transaction Records: Retained for seven (7) years from the date of each transaction, in compliance with AML record-keeping requirements.
- Gameplay Logs: Retained for five (5) years from the date of each session, for dispute resolution and responsible gaming audit purposes.
- Support Communications: Retained for three (3) years from the date of the last communication.
- Marketing Consent Records: Retained for the duration of the consent period plus two (2) years as evidence of the consent given.
- Dormant Account Data: If your account has been inactive for 24 consecutive months and is subsequently closed, your data is transitioned to archive status and retained only for the minimum period required by our regulatory obligations.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to an identified or identifiable individual.
SECTION 11
Your Data Rights
As a player on the ra777 platform, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact [email protected]:
- Right of Access: You may request a copy of all personal data ra777 holds about you. We will provide this within fourteen (14) calendar days of a verified request, in a commonly used electronic format.
- Right to Rectification: You may request correction of any personal data that is inaccurate or incomplete. Corrections to registration data can often be made directly via your account settings; corrections to KYC data require contacting support.
- Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where: (a) the data is no longer necessary for the purpose it was collected; (b) you withdraw consent and no other legal basis applies; or (c) the processing was unlawful. This right is subject to overriding retention obligations under AML law and our gaming licence.
- Right to Restriction: You may request that ra777 restrict processing of your data while a rectification or objection request is under review.
- Right to Data Portability: You may request a copy of the personal data you provided to ra777 in a structured, machine-readable format (JSON or CSV), for transfer to another service provider.
- Right to Object: You may object to processing based on legitimate interests, including profiling for responsible gaming purposes. ra777 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
- Right to Withdraw Consent: Where processing is based on consent (e.g., marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.
ra777 will respond to all verified data rights requests within fourteen (14) calendar days. Where a request is complex or numerous, we may extend this period by an additional fourteen (14) days with written notice. We do not charge a fee for processing data rights requests except where requests are manifestly unfounded, excessive, or repetitive.
SECTION 12
Children, Minors & Age Verification
The ra777 platform is strictly intended for adults aged 21 years and above. ra777 does not knowingly collect personal data from any individual under the age of 21. The KYC process — which requires submission of a CNIC — serves as our primary age verification mechanism, as Pakistani CNICs are issued only to individuals aged 18 and above, and we additionally enforce a 21+ playing age requirement.
If ra777 discovers that a registered account belongs to or has been accessed by a person under 21, the account will be immediately closed, all pending withdrawals will be suspended pending investigation, and any deposited funds (net of any applicable regulatory holds) will be returned to the original payment source after satisfactory identity resolution.
If you believe that a minor has registered on ra777 using fraudulent credentials, or has accessed the platform using your account details, please notify us immediately at [email protected]. ra777 will prioritise such reports and take immediate protective action.
SECTION 13
International Data Transfers
ra777 operates infrastructure in jurisdictions outside Pakistan, including cloud hosting, identity verification services, and game content delivery networks. As a result, your personal data may be transferred to, processed in, and stored in countries outside Pakistan.
Where such international transfers occur, ra777 implements appropriate safeguards to ensure that your data receives equivalent protection to that provided under the data protection principles set out in this Policy. These safeguards include contractual data transfer agreements with recipient entities that impose data protection obligations equivalent to those binding on ra777.
Transfers to game providers, payment processors, and infrastructure providers are carried out only with entities that have demonstrated compliance with recognised data protection standards and who are contractually bound to process data only as directed by ra777.
SECTION 14
Third-Party Links & Integrations
The ra777 platform may contain references to, or integrations with, third-party services — including payment gateways (JazzCash, EasyPaisa) and game content providers. When you interact with these third-party services, you may be subject to their own privacy policies, which operate independently from this Policy.
ra777 is not responsible for the privacy practices, data handling procedures, or security measures of any third-party service. We encourage you to review the privacy policy of any third-party service before submitting personal information to it.
Payment processing pages (including JazzCash and EasyPaisa transaction authorisation screens) are operated by those respective payment providers, not by ra777. ra777 receives only transaction confirmation and status data from these providers — not your full payment credentials.
SECTION 15
Updates to This Privacy Policy
ra777 may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, platform features, or applicable law. The "Last Updated" date at the top of this Policy indicates the date of the most recent revision.
Where updates are material — meaning they substantively affect how we collect, use, or share your personal data, or affect your data rights — ra777 will provide at least fourteen (14) days' advance notice via your registered mobile number (SMS) or email address before the updated Policy takes effect.
For non-material updates (such as typographical corrections, clarifications that do not change the substance of any provision, or updates to contact details), the revised Policy will be posted on this page without prior notice. Your continued use of the ra777 platform following the effective date of any updated Policy constitutes acceptance of the revised terms.
We encourage you to review this Policy periodically. Previous versions of this Privacy Policy are available upon request from [email protected].
SECTION 16
Contact & Data Complaints
If you have any questions, concerns, or requests relating to this Privacy Policy or how ra777 processes your personal data, please contact us via the following channels:
- Email: [email protected] (for data rights requests, please mark the subject "Data Rights Request")
- Live Chat: Available 24/7 via your ra777 account dashboard — available in English and Urdu
ra777 commits to acknowledging all privacy-related enquiries within 48 hours and providing a substantive response within fourteen (14) calendar days.
If you are not satisfied with ra777's response to a data protection concern, you have the right to escalate your complaint to the relevant data protection supervisory authority in the jurisdiction governing ra777's gaming licence, or to seek independent legal advice. Details of the relevant supervisory authority are available from our support team upon request.
For responsible gaming concerns — including requests to set deposit limits, activate self-exclusion, or access problem gambling support — please visit our Responsible Gaming page or contact our support team directly.