77d77 Privacy Policy — How We Handle Your Personal Data

Who We Are

77d77 is an online casino and sports betting platform operated at https://77d77.io, serving players in Bangladesh. References to "77d77", "we", "us", or "our" throughout this Privacy Policy refer to the operator of the 77d77 platform. References to "you" or "your" refer to any individual who accesses or uses the 77d77 platform, whether as a registered account holder or as an unregistered visitor browsing the site.

77d77 acts as the data controller in respect of personal data collected through the platform. As data controller, 77d77 determines the purposes for which your personal data is collected and the manner in which it is processed. Where 77d77 engages third-party service providers to process data on its behalf — for example, payment processors or identity verification services — those providers act as data processors and are contractually bound to process your data only in accordance with 77d77's instructions and this Privacy Policy.

If you have any questions about this Privacy Policy, your personal data, or your privacy rights, the primary contact channel is the 77d77 support team, reachable 24/7 via live chat on the platform or by email at [email protected].

Data We Collect

77d77 collects personal data in two broad categories: data you provide directly when using the platform, and data we collect automatically through your device and browsing behaviour. The table below summarises the specific types of data within each category.

How We Collect Your Data

77d77 collects your personal data through the following channels and mechanisms:

• Direct registration: When you create an account on 77d77, you provide identity and contact data through the registration form. This data is collected at the point of submission and stored in your account profile.
• KYC and verification submissions: When you upload identity documents for age or identity verification, those documents are transmitted securely to 77d77's verification partner for processing. The outcome of verification (pass/fail) is recorded on your account; the document images are handled according to the retention terms described in Section 9.
• Deposit and withdrawal transactions: When you initiate a deposit via bKash, Nagad, Rocket, Upay, or bank transfer, the payment provider shares transaction reference data with 77d77 to confirm payment. 77d77 does not receive or store your full mobile banking PIN or bank card number.
• Platform activity: As you browse the 77d77 website, place bets, play casino games, or interact with platform features, usage and transaction data is generated and recorded automatically in server logs and game provider APIs.
• Cookies and tracking technologies: 77d77 uses cookies and similar tracking technologies as described in Section 6. These collect technical and usage data passively as you navigate the platform.
• Support interactions: When you contact the 77d77 support team via live chat or email, the content of that communication — including any personal data you voluntarily share — is recorded as a support ticket and retained for quality assurance and dispute resolution purposes.
• Third-party fraud prevention: 77d77 uses third-party fraud detection and anti-money laundering screening tools that may cross-reference data you provide against external risk databases. These checks are performed for legal compliance and platform security purposes.

Why We Process Your Data

77d77 processes your personal data for the following specific purposes. Each purpose is linked to a legal basis, which is detailed in Section 5.

• Account creation and management: To create and maintain your 77d77 account, authenticate your identity at login, and apply your account preferences and responsible gaming settings across sessions.
• Age and identity verification: To comply with our obligation to prevent underage gambling. All players must be 21 years of age or older. Verification data is used to confirm your age and legal identity before withdrawal processing.
• Payment processing: To facilitate deposits from bKash, Nagad, Rocket, Upay, and Bangladesh bank accounts, and to process withdrawal requests back to verified payment methods in your name.
• Anti-money laundering (AML) compliance: To monitor account transaction patterns for signs of money laundering, fraud, or financial crime. Unusual transaction patterns may trigger enhanced due diligence review. 77d77 may be obligated to report suspicious activity to relevant authorities.
• Platform security and fraud prevention: To detect and prevent unauthorised account access, bonus abuse, multi-accounting, automated bot activity, and other forms of fraudulent or prohibited conduct.
• Customer support: To respond to your questions, investigate complaints, and resolve disputes. Support records are retained to ensure consistency and to allow escalation reviews if required.
• Responsible gaming: To administer deposit limits, loss limits, session time limits, cooling-off periods, and self-exclusion requests. We also monitor gaming patterns for signs of potentially harmful behaviour and may proactively reach out where responsible gaming concerns are identified.
• Marketing communications: To send you promotional offers, bonus notifications, and platform news by email or SMS, where you have consented to receive such communications. You may withdraw consent at any time as described in Section 13.
• Platform improvement: To analyse aggregated usage data to improve the platform's navigation, game selection, and overall user experience. This analysis is conducted on anonymised or aggregated data sets and does not involve individual profiling.
• Legal obligations: To comply with applicable record-keeping, anti-money laundering, and regulatory obligations that require us to retain certain transaction and identity records for defined periods.

Legal Bases for Processing

77d77 processes your personal data on one or more of the following legal bases, depending on the specific purpose:

• Contractual necessity: Processing that is necessary to provide the 77d77 service to you under the Terms & Conditions you agreed to at registration. This covers account management, payment processing, bonus crediting, and dispute resolution.
• Legal obligation: Processing required to comply with applicable law, including anti-money laundering obligations, age verification requirements, and financial record-keeping mandates. 77d77 cannot offer services without collecting data for these legally required purposes.
• Legitimate interests: Processing conducted for 77d77's legitimate business interests, where those interests are not overridden by your privacy rights. This includes fraud prevention, platform security monitoring, and aggregated usage analytics for service improvement.
• Consent: Processing that relies on your freely given, informed consent — specifically for marketing communications by email or SMS. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

Cookies and Tracking Technologies

77d77 uses cookies — small text files stored on your device — and similar tracking technologies to operate the platform, improve your experience, and support security and analytics functions. The following types of cookies are used:

• Strictly necessary cookies: These cookies are essential for the platform to function. They maintain your login session, remember your account preferences, and enable core features such as the cashier and game loading. These cookies cannot be disabled without rendering the platform non-functional.
• Security cookies: Used to detect and prevent fraudulent activity, including CSRF (cross-site request forgery) protection tokens, device fingerprint identifiers, and session integrity tokens. These cookies are a component of 77d77's account security infrastructure.
• Analytics cookies: Used to collect aggregated, anonymised data about how players navigate the platform — which pages are visited most frequently, which game categories attract the most engagement, and where players encounter difficulties. This data informs platform improvement decisions. Analytics data is not linked to individual player identities.
• Preference cookies: Store your platform preferences such as language settings, responsible gaming display options, and notification preferences, so that they persist across sessions without requiring you to reconfigure them each time you log in.

77d77 does not use third-party advertising or retargeting cookies. Cookies set by game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) within their game iframes are subject to those providers' own cookie policies and are used solely to operate the game interface.

Sharing Your Data

77d77 does not sell your personal data. We share your personal data only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, and Sonali Bank receive the transaction data necessary to process your deposit or withdrawal. These providers are independent data controllers in respect of their own payment processing operations and are subject to their own privacy policies and regulatory obligations.
• Identity verification partners: Where 77d77 uses a third-party KYC (know your customer) provider to verify your identity or age, your identity documents and personal details are shared with that provider for the purpose of the verification check only. The provider is contractually prohibited from using your data for any other purpose.
• Fraud prevention and AML screening services: 77d77 may share data with contracted risk screening services to check transaction patterns and player profiles against fraud and money laundering risk indicators. These services act as data processors under 77d77's instruction.
• Game content providers: When you play a game provided by Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, or another studio, limited technical data (such as a session token, game round ID, and wager amount) is exchanged with the provider's gaming server to operate the game. Game providers do not receive your full identity data.
• Legal and regulatory authorities: 77d77 may disclose personal data to law enforcement agencies, financial intelligence authorities, or courts where required by applicable law, a valid legal order, or where necessary to prevent or investigate fraud or financial crime. 77d77 will notify you of such disclosures where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of the 77d77 business, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and the privacy terms applicable to your data post-transfer before it takes effect.

International Data Transfers

77d77 operates primarily to serve players based in Bangladesh. Some of our third-party service providers — including game content studios and technical infrastructure partners — may process data on servers located outside Bangladesh. Where personal data is transferred internationally, 77d77 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Privacy Policy.

Safeguards for international transfers include contractual clauses that require the recipient to apply data protection standards consistent with 77d77's obligations, and selection of service providers whose data centres operate under recognised international security certifications (such as ISO 27001). 77d77 does not transfer your financial data to jurisdictions with inadequate data protection frameworks without implementing additional contractual or technical protections.

If you wish to obtain further information about the specific safeguards in place for any particular international transfer, you may contact the support team at the email address listed in Section 15.

Data Retention

77d77 retains your personal data for the minimum period required to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply to the main data categories:

When a retention period expires, personal data is securely deleted using industry-standard data destruction methods, or anonymised so that it can no longer be linked to an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytics purposes without privacy impact.

Security Measures

77d77 implements layered technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• TLS/SSL encryption: All data transmitted between your browser or device and the 77d77 platform is encrypted in transit using TLS 1.2 or higher. This protects your login credentials, payment data, and personal details from interception during transmission.
• Encrypted data storage: Sensitive data — including identity documents and financial records — is encrypted at rest using AES-256 encryption or equivalent standards. Passwords are never stored in plaintext; they are processed through a one-way cryptographic hash function with salt before storage.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff with access to sensitive data are subject to background checks, confidentiality obligations, and regular security awareness training.
• Two-factor authentication (2FA): 77d77 supports two-factor authentication for player accounts to add an additional layer of protection beyond the username and password. Players are encouraged to enable 2FA in their account security settings.
• Intrusion detection and monitoring: 77d77's infrastructure is monitored continuously for anomalous access patterns, attempted intrusions, and unusual data queries. Automated alerts are triggered by events that indicate potential security incidents, enabling rapid response.
• Third-party security audits: 77d77 engages independent security professionals to conduct periodic penetration testing and vulnerability assessments of the platform's infrastructure and application layer.

Your Privacy Rights

As a player on the 77d77 platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact the support team as described in Section 15.

• Right of access: You may request a copy of the personal data 77d77 holds about you. We will provide this within 30 days of receiving a valid request, in a structured, commonly used, machine-readable format where technically feasible.
• Right to rectification: If any personal data 77d77 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Account contact information (email address, mobile number) can be updated directly in your account settings; identity and verification data changes must be submitted through the support team with supporting documentation.
• Right to erasure: You may request that 77d77 delete your personal data. This right applies where the data is no longer necessary for the purpose for which it was collected, where you withdraw consent (for consent-based processing), or where processing is unlawful. This right does not apply where 77d77 is required to retain data to comply with a legal obligation — for example, AML record-keeping requirements will override an erasure request for transaction and identity data within the mandatory retention period.
• Right to restriction of processing: You may request that 77d77 restrict processing of your personal data in certain circumstances — for example, while you dispute the accuracy of data we hold, or while we assess the grounds for an erasure request.
• Right to data portability: Where processing is based on your consent or on a contract, you may request that 77d77 provide your personal data in a structured, machine-readable format so that you can transfer it to another service provider.
• Right to object: You may object to processing of your personal data where the legal basis is 77d77's legitimate interests. 77d77 will assess whether its legitimate interests override your privacy rights in the specific context and will cease processing if they do not.
• Right to withdraw consent: Where processing is based on your consent — specifically for marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

77d77 will respond to all valid privacy rights requests within 30 days. Where a request is complex or involves a large volume of data, we may extend this period by an additional 30 days and will inform you of the extension. 77d77 does not charge a fee for handling privacy rights requests unless a request is manifestly unfounded or excessive.

Children and Minors

Age verification is a mandatory component of the 77d77 account verification process. Where 77d77 discovers or is informed that personal data has been collected from a person under the age of 21, it will immediately close the associated account, delete the personal data collected from the underage individual to the extent permitted by law, and return any deposits made. Any winnings accrued during the period of underage use are not payable and will be forfeited.

If you are a parent or guardian and believe that your child has registered an account on 77d77, please contact the support team immediately at [email protected] with the relevant account details. We will investigate and act promptly on verified reports of underage account registration.

Marketing Communications

77d77 may send you promotional communications — including bonus offers, seasonal promotions (such as Eid or Pohela Boishakh offers), and platform news — by email or SMS, subject to your marketing consent preferences. Marketing communications are sent only to players who have opted in to receive them at registration or through their account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the unsubscribe link included in every marketing email sent by 77d77;
• Updating your communication preferences in your account settings under the "Notifications" section;
• Contacting the support team via live chat or email and requesting removal from the marketing list.

Withdrawal of marketing consent does not affect your ability to use the 77d77 platform or your eligibility for bonuses. You will continue to receive transactional communications — such as deposit confirmations, withdrawal notifications, and account security alerts — regardless of your marketing preferences, as these are necessary for the operation of your account and are not subject to marketing consent.

77d77 does not use automated decision-making or profiling for the purpose of directing individualised marketing offers that have a significant legal or similarly significant effect on you. Promotional offers may be targeted at player segments based on general behavioural patterns (for example, players who have not deposited in the past 30 days) but these do not constitute individual automated decision-making in a legally significant sense.

Changes to This Policy

77d77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, platform functionality, or data processing practices. When material changes are made, 77d77 will notify registered players by email to the address on file and by a prominent notice displayed on the platform for a period of not less than 14 days prior to the changes taking effect.

The "Last Updated" date at the top of this Privacy Policy will be revised each time the document is materially amended. Non-material changes — such as minor typographical corrections or clarifications that do not affect the substance of the policy — may be made without prior notification, although the "Last Updated" date will still be revised.

Continued use of the 77d77 platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes and your consent to be bound by the updated terms, to the extent that consent is the applicable legal basis for any affected processing activity. If you do not agree with any changes to this Privacy Policy, you should cease using the platform and may request account closure by contacting the support team.

Archived versions of previous Privacy Policy documents are available from the support team on request, so that you can compare the current version with previous versions if you wish.

Contact and Data Requests

For all privacy-related enquiries, personal data access requests, erasure requests, or concerns about how 77d77 processes your personal data, please contact the support team through any of the following channels:

• Live chat: Available 24/7 directly on the 77d77 platform. Live chat is the fastest channel and typically connects you with a support agent within 2–5 minutes. All times Bangladesh Standard Time (BST, UTC+6).
• Email: [email protected] — include "Privacy Request" in the subject line to ensure your message is routed to the correct team. We aim to acknowledge all email enquiries within 24 hours and to resolve or substantively respond within 30 days.

When submitting a data access, rectification, or erasure request, please include your registered username and the email address associated with your account. 77d77 may need to verify your identity before processing the request to ensure that data is not disclosed to or deleted at the direction of an unauthorised party. Identity verification for privacy requests does not require document submission in most cases — answering account security questions is typically sufficient.

77d77 takes all privacy complaints seriously. If you submit a complaint and are not satisfied with the response you receive, you have the right to escalate your complaint to the relevant data protection authority or consumer protection body in your jurisdiction. 77d77 will cooperate fully with any such authority in the resolution of your complaint.