Section 01
Introduction
This Privacy Policy ("Policy") is issued by w778 ("Operator", "we", "us", "our"), the operator of the online gambling platform accessible at https://w778.cam ("Platform"). It governs the collection, processing, storage and disclosure of personal data relating to users ("User", "you", "your") of the Platform.
w778 takes the privacy of its users seriously. We are committed to processing personal data in a transparent, fair and lawful manner, and to implementing appropriate technical and organisational measures to protect that data against unauthorised access, loss or misuse.
By registering an Account on the Platform or otherwise using our services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the Platform.
Notice for Pakistani Users: w778 is an international online gambling platform. It is not operated under Pakistani law, and it is not regulated, licensed, endorsed or authorised by the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any Pakistani provincial authority or financial institution. This Policy does not constitute legal advice. You are responsible for understanding the data protection laws applicable to you in your jurisdiction.
Section 02
Definitions
Throughout this Policy, the following terms carry the meanings assigned below:
- "Account" — a registered user profile created on the w778 Platform.
- "Controller" — the entity that determines the purposes and means of processing personal data. For the purposes of this Policy, the Controller is w778.
- "Cookie" — a small text file placed on your device by the Platform when you visit, used to store session data, preferences and analytics information.
- "KYC Data" — identity, age and address verification documents and information collected as part of Know Your Customer compliance procedures.
- "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, IP address, payment details and device identifiers.
- "Processing" — any operation performed on personal data, including collection, storage, use, disclosure and deletion.
- "Processor" — a third party that processes personal data on behalf of and under instruction from the Controller.
- "Sensitive Data" — a subset of personal data that warrants enhanced protection, including government-issued identity document numbers, financial account details and, where relevant, information about gambling behaviour and health status.
- "Third Party" — any person or entity other than you, the Operator, or the Operator's authorised Processors.
Section 03
Data We Collect
We collect personal data in the following categories:
3.1 Registration & Identity Data
- Full legal name
- Date of birth
- Email address
- Residential address (including city — for example, Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar — and country)
- Username and encrypted password
- Phone number (where provided)
3.2 KYC & Verification Data
- Government-issued identity document (e.g., Pakistani National Identity Card — CNIC — or passport)
- Proof of residential address (e.g., utility bill, bank statement)
- Proof of ownership of payment methods used
- Source of funds information where required by compliance procedures
- Facial likeness data where liveness-check technology is employed during KYC verification
3.3 Financial & Transaction Data
- Deposit and withdrawal transaction records, including amounts, timestamps and payment references
- Payment method details (partially masked card numbers, mobile wallet references, bank account identifiers)
- Account balance history
- Bonus and promotion usage records
3.4 Betting & Gaming Activity Data
- Bets placed, games played, wager amounts and outcomes
- Session timestamps, duration and frequency
- Responsible gambling tool settings applied to the Account
3.5 Technical & Device Data
- IP address and approximate geolocation derived from IP
- Device type, browser type and operating system
- Referring URL and navigation paths within the Platform
- Cookie identifiers and session tokens
3.6 Communications Data
- Records of correspondence with our support team via chat, email or messaging tools
- Feedback and complaint submissions
- Responses to surveys or promotional enquiries (where applicable)
Section 04
How We Collect Your Data
We collect personal data through the following channels:
- Directly from you — when you register an Account, complete KYC verification, make a deposit or withdrawal, use support channels, or participate in promotions.
- Automatically — when you access and use the Platform, through cookies, server logs and similar tracking technologies that record technical and behavioural data.
- From third-party verification providers — identity verification agencies, KYC technology providers and fraud-prevention partners may provide or cross-reference data to assist with Account verification.
- From payment processors — payment gateway providers confirm transaction status and may share limited transaction metadata necessary to process deposits and withdrawals.
Payment Method Context: References to payment services such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah on this Platform are for contextual information only. None of these providers share user data with w778, endorse this Platform, or are affiliated with our data processing activities.
Section 05
Data Processing & Use
We use your personal data for the purposes set out below. In each case, we identify the relevant legal basis for processing in Section 6.
| Purpose |
Data Used |
| Account registration and management |
Registration & identity data |
| Identity and age verification (KYC) |
KYC & verification data |
| Processing deposits and withdrawals |
Financial & transaction data |
| Delivering betting and gaming services |
Betting & gaming activity data |
| Fraud detection and anti-money laundering |
All categories where relevant |
| Responsible gambling monitoring and enforcement |
Activity data, limits settings, session data |
| Customer support and dispute resolution |
Communications data, Account history |
| Platform security, integrity and audit |
Technical & device data, activity records |
| Legal and regulatory compliance |
KYC data, financial records, activity logs |
| Service improvement and analytics |
Anonymised or aggregated technical data |
| Promotional communications (where consented) |
Email, preferences, activity data |
Section 06
Legal Basis for Processing
We process your personal data on one or more of the following legal bases:
- Contractual Necessity: Processing required to fulfil our obligations to you under the w778 Terms & Conditions, including Account management, payment processing and delivery of betting and gaming services.
- Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML requirements, record-keeping obligations and responses to lawful authority requests.
- Legitimate Interests: Processing necessary for our legitimate business interests — including fraud prevention, platform security, responsible gambling monitoring and service analytics — where these interests are not overridden by your fundamental rights.
- Consent: Where we rely on your consent — for example, for marketing communications — you may withdraw that consent at any time by contacting our support team or using the opt-out mechanism provided in our communications.
Section 07
Data Sharing & Disclosure
We do not sell your personal data to third parties. We may share your data with the following categories of recipient, strictly for the purposes described in this Policy:
- KYC & Identity Verification Providers: Third-party services that assist with identity, age and address verification during the Account registration and KYC process.
- Payment Processors: Payment gateway providers who process deposit and withdrawal transactions. These processors receive only the data necessary to facilitate the transaction.
- Fraud Prevention & Security Partners: Technology providers that assist with detecting and preventing fraudulent activity, account takeover attempts and suspicious transactions.
- IT Infrastructure and Hosting Providers: Cloud hosting, server and data storage providers who process data on our behalf under contractual data processing agreements.
- Gaming Technology Partners: Game providers and sports data partners who supply content or market data to the Platform — limited to the data necessary for game delivery and bet settlement.
- Legal and Regulatory Authorities: We may disclose personal data to law enforcement agencies, regulatory bodies or courts where required to do so by applicable law or valid legal process.
- Professional Advisors: Legal, audit and compliance advisors who are bound by professional confidentiality obligations.
Third-Party Processors: All third-party Processors engaged by w778 are required to handle personal data in accordance with our instructions and applicable data protection standards. We conduct due diligence on Processors before engagement and require contractual data processing agreements to be in place.
Section 08
Data Retention
We retain personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law or regulation. The following general principles apply:
- Active Account Data: Retained for the duration of your Account registration and for a defined period following Account closure, in accordance with our record-keeping obligations.
- KYC & Identity Records: Retained for a minimum period following Account closure as required under applicable anti-money laundering and record-keeping regulations. In many licensing jurisdictions, this period is five years or more.
- Financial Transaction Records: Retained for a minimum period following each transaction, consistent with financial record-keeping requirements in the applicable licensing jurisdiction.
- Correspondence Records: Support interactions and dispute records are retained for a defined period following resolution, to facilitate any subsequent review or appeal.
- Technical & Log Data: Typically retained for a shorter period, sufficient for security monitoring and analytics purposes, and then deleted or anonymised.
When personal data is no longer required, it is securely deleted or anonymised in a manner that prevents identification of the individual.
Section 09
Data Security
w778 implements appropriate technical and organisational security measures to protect your personal data against accidental loss, unauthorised access, alteration or disclosure. These measures include:
- Encryption in Transit: All data transmitted between your device and the Platform is encrypted using 256-bit TLS (Transport Layer Security) protocols.
- Encryption at Rest: Sensitive data — including KYC documents and financial records — is encrypted in storage using industry-standard encryption algorithms.
- Access Controls: Access to personal data within our organisation is restricted on a need-to-know basis and protected by authentication requirements. Access logs are maintained and reviewed.
- Password Security: Account passwords are stored using one-way hashing algorithms. We do not store plaintext passwords.
- Two-Factor Authentication: Two-factor authentication options are available for Account login to provide an additional layer of security.
- Regular Security Reviews: We conduct regular technical security reviews and vulnerability assessments of the Platform and our data processing infrastructure.
Your Role in Security: While we take significant steps to protect your data, you also play an important role. Keep your Account credentials private, use a strong and unique password, enable two-factor authentication where available, and contact our support team immediately if you suspect any unauthorised access to your Account.
Section 10
Cookies & Tracking Technologies
The w778 Platform uses cookies and similar tracking technologies to operate essential Platform functions, maintain user sessions, and collect analytics data that helps us improve the Platform.
10.1 Types of Cookies We Use
- Essential Cookies: Required for the Platform to function. These include session authentication tokens, security cookies and load-balancing cookies. Without these cookies, the Platform cannot operate correctly.
- Functional Cookies: Used to remember your preferences — such as language settings and responsible gambling tool configurations — to personalise your experience on the Platform.
- Analytics Cookies: Used to collect aggregated data about how users interact with the Platform — pages visited, features used and session duration — to help us understand usage patterns and improve the service. Analytics data is anonymised or pseudonymised where possible.
- Security Cookies: Used to detect and prevent fraud, bot activity and other security threats by tracking behavioural signals during your session.
10.2 Managing Cookies
You can manage or disable non-essential cookies through your browser settings. Note that disabling essential cookies will impair the functionality of the Platform, including your ability to log in and maintain an active session. Detailed instructions for managing cookies in common browsers are available in your browser's help documentation.
Section 11
Your Rights
Depending on the data protection laws applicable to your situation, you may have some or all of the following rights in respect of your personal data. We will assess each request in accordance with applicable law and our compliance obligations.
Right of Access
Request a copy of the personal data we hold about you and information about how it is used.
Right to Rectification
Request correction of any inaccurate or incomplete personal data held about you.
Right to Erasure
Request deletion of your personal data where we no longer have a lawful basis to retain it, subject to legal retention obligations.
Right to Restrict Processing
Request that we restrict the processing of your data in certain circumstances, such as while a rectification request is under review.
Right to Data Portability
Request a structured, machine-readable copy of the personal data you have provided to us, where technically feasible.
Right to Object
Object to our processing of your personal data based on legitimate interests, including for direct marketing purposes.
To exercise any of these rights, please contact our Data Support team using the contact details in Section 15. We will respond to verifiable requests within a reasonable timeframe. We may need to verify your identity before processing your request.
Section 12
Children's Data
The w778 Platform is strictly intended for adults aged 18 years and over — or the higher minimum age required by the applicable operator licensing jurisdiction or the User's country of residence. We do not knowingly collect personal data from persons under the applicable minimum age.
If we become aware that an Account has been registered by a person below the applicable minimum age, we will immediately suspend the Account, conduct an age verification review, and delete any personal data associated with the underage registration in accordance with our KYC and compliance procedures.
If you have reason to believe that a minor has registered an Account on our Platform, please contact our support team immediately at [email protected].
Section 13
International Data Transfers
w778 is an international platform and your personal data may be transferred to, stored in, and processed in countries other than your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.
Where such transfers occur, we take steps to ensure that appropriate safeguards are in place — including contractual data processing agreements, standard contractual clauses or equivalent transfer mechanisms applicable in the relevant licensing jurisdiction — to protect your data in transit and at its destination.
Pakistan-Specific Notice: Your personal data may be processed outside Pakistan in jurisdictions where the Platform's operators and infrastructure are located. Pakistan's data protection framework is evolving. This Platform is not subject to the jurisdiction of Pakistani data protection authorities. If you have concerns about the lawfulness of data transfers from Pakistan, seek independent legal advice.
Section 14
Policy Amendments
We reserve the right to update this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or our operational practices. Where material changes are made, we will endeavour to notify registered Users via a notice on the Platform or by email to the registered Account address, with reasonable advance notice.
The "Effective Date" and "Last Reviewed" dates at the top of this Policy reflect when it was last updated. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the changes.
We encourage you to review this Policy periodically to stay informed about how we are protecting your personal data.