Your Privacy at 77ga — Protected

1 About This Privacy Policy

This Privacy Policy ("Policy") explains how 77ga ("we", "us", "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "your", "the Player") who access or use the 77ga website, mobile interface, and associated online gaming and betting services (collectively, the "Platform").

77ga is committed to protecting the privacy and personal data of all players, particularly those based in Bangladesh. Our data practices are designed to be transparent, proportionate, and secure. This Policy should be read alongside our Terms and Conditions, which govern the broader contractual relationship between you and 77ga.

By registering a 77ga account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the 77ga Platform.

2 Data We Collect

The categories of personal data we collect depend on how you interact with the 77ga Platform. We collect information in the following ways:

2.1 Data You Provide Directly

When you register an account, verify your identity, contact support, or participate in promotions, you may provide us with the following personal data:

• Full legal name and date of birth
• Email address and mobile phone number
• Residential address (city, district, postal code)
• Identity verification documents (national ID card, passport, driver's licence)
• Payment method details (bKash number, Nagad number, Rocket number, bank account details)
• Username, password hash, and security question responses
• Correspondence and communications sent to our support team

2.2 Data We Collect Automatically

When you use the 77ga Platform, we automatically collect certain technical and behavioural data through cookies, log files, and analytics tools:

• IP address and approximate geolocation (country and city level)
• Device type, operating system, and browser version
• Session timestamps, login history, and session duration
• Pages visited, games played, bets placed, and in-platform navigation patterns
• Transaction identifiers and payment gateway reference numbers
• Referring URL and entry/exit pages

2.3 Data From Third Parties

In certain circumstances we may receive personal data about you from third-party sources, including:

• Identity verification and KYC service providers who confirm the authenticity of documents you submit
• Payment processors such as bKash, Nagad, and Rocket who confirm transaction status
• Fraud prevention and anti-money-laundering screening services
• Responsible gaming databases that record self-exclusion registrations

3 How We Use Your Data

77ga uses the personal data we collect for the following specific and lawful purposes:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

4 Legal Basis for Processing

77ga processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing required to fulfil our obligations to you under the Terms and Conditions, including operating your account, processing transactions, and providing access to games.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money-laundering obligations, age verification requirements, and fraud reporting duties.
• Legitimate Interests: Processing conducted for 77ga's legitimate business interests, such as fraud prevention, platform security, responsible gaming monitoring, and improving the overall player experience — provided those interests are not overridden by your fundamental rights.
• Consent: Processing for purposes where you have provided clear, freely given, and specific consent — primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Sharing Your Data

77ga does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following limited and controlled circumstances:

5.1 Service Providers

We engage carefully selected third-party service providers who process personal data on our behalf solely to enable the operation of the 77ga Platform. These providers include identity verification services, payment processing partners (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank), fraud prevention tools, cloud hosting providers, and customer support software vendors. All service providers are bound by contractual data processing agreements that prohibit them from using your data for any purpose other than providing services to 77ga.

5.2 Legal and Regulatory Disclosure

We may disclose your personal data to law enforcement agencies, regulatory bodies, courts, or other government authorities where we are required to do so by applicable law, court order, or other legal process. We will endeavour to notify you of such disclosures where we are legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 77ga's business assets, your personal data may be transferred to the acquiring entity. We will ensure that any such transfer is subject to appropriate confidentiality and data protection commitments, and we will notify you of any material change in data controller prior to the transfer taking effect.

5.4 Responsible Gaming Partners

Where you have registered a self-exclusion or requested a cooling-off period, we may share relevant information with responsible gaming bodies and shared exclusion databases to ensure your exclusion is honoured effectively across partner platforms.

6 Cookies & Tracking Technologies

77ga uses cookies and similar tracking technologies to ensure the Platform functions correctly, to personalise your experience, and to analyse usage patterns so we can continue to improve our services for Bangladeshi players.

6.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. They enable core features such as account login sessions, security tokens, and game state persistence. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations to provide a more personalised experience.
• Analytical Cookies: Collect anonymised data about how players navigate the Platform — which pages are visited most frequently, how long sessions last, and where players encounter difficulties. This data helps us optimise the Platform.
• Marketing Cookies: Used only where you have opted into marketing communications. These help us understand which promotions are most relevant to your interests so we can send more targeted offers.

6.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and set preferences for specific websites. Please note that disabling strictly necessary cookies will prevent you from logging in to your 77ga account and using core Platform features.

7 Data Retention

77ga retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal obligations. The following general retention periods apply:

• Active account data: Retained for the lifetime of your account and for a period of five years following account closure, to comply with legal and financial record-keeping obligations.
• KYC and identity verification documents: Retained for a minimum of five years from the date of submission or account closure, whichever is later, in accordance with anti-money-laundering regulations.
• Transaction records: Retained for seven years from the date of each transaction to satisfy financial reporting and audit requirements.
• Support correspondence: Retained for three years from the date of the last interaction unless the correspondence forms part of an ongoing dispute or legal proceeding.
• Marketing preferences and opt-in records: Retained for as long as you remain subscribed plus two years after unsubscription as evidence of consent management.
• Analytical and behavioural data: Typically anonymised or aggregated within 13 months of collection so that no individual player can be identified from the resulting dataset.

Where personal data is no longer required, it is securely deleted from our systems or anonymised such that it can no longer be associated with any individual player. We do not retain data "just in case" — each retention period has a specific, documented justification.

8 Data Security

77ga implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security infrastructure includes:

• SSL/TLS Encryption: All data transmitted between your device and the 77ga Platform is encrypted using industry-standard TLS protocols, ensuring that intercepted data cannot be read by unauthorised parties.
• Encrypted Data Storage: Sensitive data fields including payment identifiers and KYC document references are encrypted at rest using AES-256 encryption standards.
• Access Controls: Access to personal data within 77ga's systems is restricted to authorised personnel on a strict need-to-know basis. All staff with access to player data are subject to confidentiality obligations and regular security training.
• Intrusion Detection: Our platform infrastructure is monitored continuously for suspicious activity, unusual login patterns, and potential security threats. Automated alerts are triggered when anomalies are detected.
• Two-Factor Authentication: Players are strongly encouraged to enable two-factor authentication (2FA) on their 77ga accounts for an additional layer of login security.
• Regular Security Audits: We conduct periodic internal and external security assessments to identify vulnerabilities and ensure our defences remain current against evolving threats.

Despite our best efforts, no security system is entirely impenetrable. In the unlikely event of a data breach that affects your personal data, we will notify affected players as promptly as practicable and take all reasonable steps to mitigate any resulting harm.

9 Your Data Rights

As a player on the 77ga Platform, you hold a number of rights in relation to your personal data. We are committed to honouring these rights promptly and transparently. Your rights include:

• Right of Access: You have the right to request a copy of all personal data that 77ga holds about you, along with information about how it is being processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where we have processed your data unlawfully. Please note that certain legal retention obligations may prevent us from deleting all data immediately.
• Right to Restriction: You have the right to request that we restrict the processing of your data in certain circumstances — for example, while a dispute about data accuracy is resolved.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request a copy of your personal data in a structured, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of 77ga's legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, please contact our support team at the email address provided in Section 14 of this Policy. We aim to respond to all valid data rights requests within 30 days of receipt. We may need to verify your identity before processing your request.

10 Children & Minors

The 77ga Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Our registration process includes mandatory age verification steps, and we reserve the right to request supporting identity documents to confirm a player's age at any point.

If 77ga discovers or has reasonable grounds to suspect that an account is held by a person under the age of 21, the account will be suspended immediately, all associated personal data will be reviewed, and any winnings or bonuses accumulated by the underage account will be voided. Deposited funds may be returned to the payment source at 77ga's discretion following investigation.

Parents and guardians who believe that a minor in their household may have accessed the 77ga Platform are encouraged to contact us immediately at [email protected] so that we can take prompt remedial action. We also recommend the use of internet parental control tools to prevent underage access to online gaming platforms.

11 Marketing Communications

77ga may send you promotional communications about bonuses, new games, seasonal offers (such as Eid or Pohela Boishakh specials), and platform updates. We will only send marketing communications to players who have explicitly opted in to receive them during registration or through their account settings.

11.1 Opting Out

You may opt out of marketing communications at any time through one of the following methods:

• Clicking the "Unsubscribe" link included in any marketing email from 77ga.
• Updating your communication preferences within your 77ga account settings.
• Contacting our support team at [email protected] and requesting removal from marketing lists.

Unsubscription requests are processed within 48 hours. Please note that opting out of marketing does not affect transactional communications such as deposit confirmations, withdrawal notifications, account security alerts, or KYC requests — these are necessary communications related to your account and cannot be disabled.

11.2 Profiling for Marketing

Where you have consented to marketing, we may use automated profiling to identify which promotions and game recommendations are most likely to be relevant to your interests, based on your game history, deposit patterns, and stated preferences. This profiling does not produce any legally significant decisions about you. You may object to this profiling at any time by contacting support.

12 Third-Party Links

The 77ga Platform may contain references to third-party services such as game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) or payment partners. While we exercise care in selecting our partners, 77ga does not control and is not responsible for the privacy practices or content of any third-party websites, applications, or services.

This Privacy Policy applies solely to data processed by 77ga through the 77ga Platform. If you interact directly with a third-party service provider's interface, that provider's own privacy policy governs the collection and use of your data in that context. We encourage you to review the privacy policies of any third-party services you use in connection with your online gaming activities.

13 Updates to This Policy

77ga reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes to this Policy, we will notify registered players by email to the address on record and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The effective date at the top of this document will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed of how we are protecting your personal data. Continued use of the 77ga Platform after the publication of any revised Policy constitutes your acceptance of the updated terms.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 77ga holds about you, please contact our dedicated support team. We are available 24 hours a day, 7 days a week, and aim to respond to all privacy-related enquiries within 5 business days.

Support contact (plain text — not a clickable link): [email protected]

When contacting us about a data rights request, please include your registered account username, the specific right you wish to exercise, and any relevant details to help us locate and process your request efficiently. We may need to verify your identity before acting on your request to protect the security of your account.

For responsible gaming concerns or self-exclusion requests, please also visit our dedicated Responsible Gaming page for additional tools and guidance available directly within your account settings.