77b7 Privacy Policy — How We Protect and Handle Your Personal Data

1.1 Data Controller. The data controller responsible for your personal data is 77b7 (referred to in this policy as "77b7", "we", "us", or "our"). 77b7 operates the online betting and casino platform accessible at 77b7.io. For all data-related enquiries, the primary point of contact is [email protected].

1.2 Scope. This Privacy Policy applies to all personal data collected, stored, and processed in connection with your use of the 77b7 website and all associated services, including but not limited to sports betting, live casino, slots, card games, and customer support interactions. It applies to all members and visitors regardless of the device used to access the platform — desktop, mobile, or tablet — and regardless of location within Bangladesh, including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar.

1.3 Third-Party Links. The 77b7 platform may contain links to third-party services such as payment processors. This Privacy Policy does not extend to third-party websites or services. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of 77b7.

1.4 Children and Minors. The 77b7 platform is strictly for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.

2.1 Data You Provide Directly. We collect personal data that you actively provide to us, including during account registration (full name, date of birth, email address, mobile number), during identity verification (government-issued ID documents, proof of address), when making financial transactions (payment account numbers, transaction amounts), and when communicating with our support team (chat messages, email content, complaint details).

2.2 Data Collected Automatically. When you access and use the 77b7 platform, we automatically collect certain technical and usage data. This includes your IP address, device identifiers, browser type and version, operating system, pages visited, time and duration of visits, games accessed, bet amounts, and interaction events. This data is collected via server logs, session tracking software, and cookies.

2.3 Data from Third Parties. In limited circumstances, 77b7 may receive personal data about you from third parties. This includes identity verification data from KYC service providers, fraud-risk scores from fraud detection partners, and transaction confirmation data from payment processors such as bKash, Nagad, Rocket, Upay, Visa, and Mastercard. We treat data received from third parties with the same level of care as data collected directly from you.

2.4 Data You Choose Not to Provide. Where the provision of personal data is required to deliver a service (for example, providing your mobile number to process a bKash withdrawal), failure to provide that data will mean we are unable to deliver the relevant service. We will always inform you at the point of collection whether the provision of specific data is mandatory or optional.

77b7 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and secure your 77b7 member account, including authentication and session management.
• Service Delivery: To process your bets, execute deposits and withdrawals, credit bonuses, settle winnings, and deliver all platform features and game content.
• Identity Verification (KYC): To verify your identity and age (21+) as required by responsible gaming principles and anti-money laundering (AML) obligations.
• Fraud and Security: To detect, investigate, and prevent fraudulent activity, account takeover, money laundering, bonus abuse, and other prohibited conduct as defined in the 77b7 Terms & Conditions.
• Customer Support: To respond to your enquiries, process complaints, and resolve disputes efficiently and fairly.
• Responsible Gaming: To monitor betting behaviour for signs of problem gambling and to deliver appropriate responsible gaming tools, prompts, and interventions in accordance with the 77b7 Responsible Gaming Policy.
• Platform Improvement: To analyse usage patterns, identify technical issues, test new features, and improve the overall quality and performance of the 77b7 platform.
• Legal Compliance: To meet our obligations under applicable laws and regulations, including record-keeping, responding to lawful requests from authorities, and enforcing our Terms & Conditions.
• Marketing Communications: To send you promotional offers, bonus notifications, and event updates — but only where you have expressly consented to receive such communications. You may withdraw marketing consent at any time by contacting [email protected].

77b7 does not use automated decision-making or profiling in a way that produces legal or similarly significant effects on members, except where this is required for fraud prevention, in which case you have the right to request human review of any automated decision that affects your account.

77b7 processes your personal data on the following legal bases:

• Contract Performance: Processing that is necessary to provide the services you have contracted with us for — including account management, bet processing, deposits, withdrawals, and customer support.
• Legitimate Interests: Processing that is necessary for 77b7's legitimate business interests, provided those interests are not overridden by your rights. This includes fraud detection, platform security, responsible gaming monitoring, and platform improvement analytics.
• Legal Obligation: Processing that is required to comply with applicable legal and regulatory obligations, including KYC/AML requirements, retention of financial records, and response to lawful authority requests.
• Consent: Processing carried out on the basis of your freely given, specific, informed, and unambiguous consent — principally for direct marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

5.1 Service Providers. 77b7 shares personal data with carefully selected third-party service providers who assist us in operating the platform. These include identity verification providers, payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard), fraud detection services, cloud hosting providers, and customer support software vendors. All third-party providers are bound by data processing agreements that require them to process data only on our instructions and to maintain appropriate security standards.

5.2 Game Studio Providers. Game content on the 77b7 platform is provided by third-party studios including Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, Microgaming, and Spribe. Limited technical data (such as session tokens and game result data) is shared with these providers for the purpose of delivering the game experience. These providers operate their own privacy policies in respect of any data they independently collect.

5.3 Legal and Regulatory Disclosure. 77b7 may disclose personal data to law enforcement agencies, regulatory authorities, or other government bodies where required to do so by law, court order, or in response to a valid legal process. We will notify affected members of such disclosures where we are legally permitted to do so.

5.4 Business Transfers. In the event that 77b7 undergoes a merger, acquisition, or sale of all or part of its assets, personal data held about members may be transferred to the acquiring entity. Members will be notified of any such transfer and of any material changes to data processing that result from it.

5.5 No Sale of Data. 77b7 does not sell, rent, lease, or otherwise transfer personal data to third parties for their own independent commercial use. This commitment is absolute and applies to all categories of personal data we hold about you.

6.1 What Are Cookies. Cookies are small text files placed on your device when you visit the 77b7 platform. They allow the platform to recognise your device, maintain your session, remember your preferences, and collect analytics data about how the platform is used.

6.2 Types of Cookies We Use. 77b7 uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and recently played games to provide a more personalised experience.
• Analytics Cookies: Collect anonymised data about how members use the platform — pages visited, time on site, error events — to help us understand and improve platform performance. Analytics data is aggregated and does not identify individual users.
• Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including tracking unusual device behaviour or multi-accounting attempts.

6.3 Managing Cookies. You may control cookie settings through your browser's privacy settings. Please note that disabling strictly necessary cookies will impair your ability to use the 77b7 platform. Disabling analytics or functional cookies will reduce the quality of your experience but will not prevent access to core features.

6.4 Do Not Track. 77b7 respects Do Not Track (DNT) signals from your browser for analytics and non-essential tracking. Strictly necessary cookies are not affected by DNT signals.

7.1 Retention Principles. 77b7 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, to comply with legal obligations, or to resolve disputes and enforce our agreements. We do not retain data beyond the period for which a legitimate purpose exists.

7.2 Retention Periods. The following general retention periods apply:

• Active Account Data: Retained for the duration of your membership plus a minimum of 5 years following account closure, in order to satisfy AML record-keeping obligations and enable dispute resolution.
• Identity Verification Documents: Retained for a minimum of 5 years from the date of verification, in accordance with AML and KYC compliance requirements.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction.
• Customer Support Communications: Retained for 3 years from the date of the final communication in a support thread, unless the communication is directly linked to an active dispute or legal proceeding.
• Analytics and Usage Data: Anonymised after 12 months and retained in aggregate form indefinitely for platform improvement purposes.
• Marketing Consent Records: Retained for the duration of the consent plus 3 years to demonstrate compliance.

7.3 Deletion and Anonymisation. When data reaches the end of its retention period, it is securely deleted or irreversibly anonymised. Deletion requests submitted by members are processed within 30 days, subject to any overriding legal obligation to retain the data (such as AML retention requirements).

As a 77b7 member, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected]. We will respond to all verified requests within 30 days.

• Right of Access: You have the right to request a copy of all personal data that 77b7 holds about you, along with information about how it is being used and who it has been shared with.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated promptly.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to overriding legal retention obligations.
• Right to Restrict Processing: You may request that 77b7 restricts the processing of your data in certain circumstances — for example, while the accuracy of your data is being contested, or while an objection to processing is being considered.
• Right to Data Portability: Where processing is based on consent or contract performance, you have the right to receive your personal data in a structured, machine-readable format and to have it transferred to another data controller where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on legitimate interests. You also have an absolute right to object to the use of your data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal.
• Right to Human Review of Automated Decisions: Where an automated decision has produced a significant effect on your account (such as an account suspension triggered by fraud detection), you have the right to request that the decision be reviewed by a human member of the 77b7 team.

9.1 Technical Safeguards. 77b7 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include SSL/TLS encryption for all data in transit, AES-256 encryption for sensitive data at rest, firewalls and intrusion detection systems, regular penetration testing and vulnerability assessments, and strict access controls that limit staff access to personal data on a need-to-know basis.

9.2 Organisational Measures. All 77b7 staff who handle personal data are subject to confidentiality obligations and receive training on data protection best practices. Access to personal data is logged, monitored, and reviewed regularly. Third-party service providers are required to demonstrate equivalent security standards before being granted access to member data.

9.3 Data Breach Response. In the event of a personal data breach that is likely to result in a risk to member rights and freedoms, 77b7 will notify affected members without undue delay, providing details of the nature of the breach, the categories of data affected, the likely consequences, and the measures taken or proposed to address the breach. We maintain an internal incident response plan to ensure a prompt and coordinated response to any breach event.

9.4 Your Role in Security. While 77b7 takes extensive steps to protect your data, the security of your account also depends on you. We strongly encourage you to use a unique, strong password for your 77b7 account, to enable two-factor authentication (2FA) where available, to never share your login credentials, and to contact us immediately at [email protected] if you suspect any unauthorised access to your account.

10.1 Right to Update. 77b7 reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect updates to our data practices, changes in applicable law, new platform features, or feedback from members. The effective date at the top of this page will be updated to reflect the date of the most recent revision.

10.2 Notification of Material Changes. Where changes to this Privacy Policy are material — meaning they significantly affect how your data is processed or your rights in relation to that data — 77b7 will notify you by email to the address registered to your account at least 14 days before the changes take effect. Continued use of the platform after the effective date of updated Terms constitutes acceptance of the revised Privacy Policy.

10.3 Version History. Previous versions of the 77b7 Privacy Policy are available on request by contacting [email protected]. We maintain a complete version history to ensure full transparency about how our data practices have evolved over time.

11.1 Data Enquiries. For any questions, concerns, or requests relating to this Privacy Policy or the personal data that 77b7 holds about you, please contact our support team. Email: [email protected]. Our support team is available 24 hours a day, 7 days a week. All data-related requests will be escalated to the appropriate team member and responded to within 30 days. Bangladesh Standard Time (BST, UTC+6) applies to all operational hours references.

11.2 Complaints. If you are not satisfied with how 77b7 has handled your personal data or responded to a data rights request, you have the right to lodge a formal complaint. Please first raise the complaint directly with our support team at [email protected] so that we have the opportunity to resolve it internally. If you remain unsatisfied after our internal process is complete, you may escalate the matter through the appropriate dispute resolution channels referenced in the 77b7 Terms & Conditions.

11.3 Entire Policy. This Privacy Policy, together with the 77b7 Terms & Conditions and Responsible Gaming Policy, constitutes the complete statement of 77b7's data protection commitments to its members. In the event of any conflict between this Privacy Policy and any other document, this Privacy Policy shall prevail with respect to matters of data protection and privacy.