77a7 Privacy
Policy

77a7 (referred to in this policy as "77a7", "we", "us", or "our") operates the online betting and casino platform accessible at https://77a7.io. 77a7 is the data controller responsible for the personal data collected through the platform. We are committed to protecting the privacy and security of all players who use our services, particularly our registered player base in Bangladesh.

For all data protection enquiries, correction requests, access requests, and deletion requests, players should contact our dedicated Data Protection team at [email protected] with the subject line "Privacy Request". We aim to acknowledge all such requests within 5 business days and to resolve them within 30 calendar days.

2.1 Registration Data

When you create a 77a7 account, we collect the following information that you provide directly:

• Full legal name as it appears on your government-issued identity document
• Date of birth (used to verify that you are 21 years of age or older)
• Residential address, including city, district, and postal code within Bangladesh
• Email address (used for account communications and, where opted in, promotional messages)
• Mobile phone number (used for account verification, two-factor authentication, and transaction notifications)
• Username and encrypted password
• Preferred currency (Bangladeshi Taka, BDT)

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) obligations, we may request and collect copies of the following documents at various stages of your account lifecycle:

• National Identity Card (NID) — front and back
• Passport (photo page)
• Proof of residential address — such as a utility bill, bank statement, or official letter dated within the last 3 months
• Proof of payment method ownership — such as a screenshot of your bKash or Nagad account registration screen confirming your name and mobile number
• Source of funds documentation — for high-value transactions or where triggered by our internal risk assessment procedures

KYC documents are stored securely and accessed only by authorised compliance team members. They are not shared with third parties except where required by law or where necessary to complete the verification process through our contracted KYC service provider.

2.3 Transaction Data

We record details of all financial transactions conducted through your 77a7 account, including deposits, withdrawals, bonus credits, wagering activity, game results, and account balance changes. Transaction records include timestamps (in Bangladesh Standard Time, UTC+6), amounts in BDT, payment method identifiers (such as a partially masked bKash number), and transaction reference codes. This data is essential for account integrity, dispute resolution, and regulatory compliance.

2.4 Technical & Usage Data

When you access the 77a7 platform, we automatically collect certain technical information about your device and browsing session, including:

• IP address and approximate geographic location derived from that IP address
• Device type, operating system, and browser version
• Pages visited, time spent on each page, and navigation path through the platform
• Session start and end times
• Referring URL (the website or link you followed to arrive at 77a7)
• Error logs and crash reports relevant to platform performance

This technical data is used primarily for platform security, fraud detection, performance optimisation, and aggregate usage analytics. It is not used to build individual marketing profiles without your explicit consent.

2.5 Communications Data

When you contact the 77a7 support team via live chat, email, or any other channel, we retain records of those communications including the content of messages, timestamps, and the support agent who handled your enquiry. This information is used to ensure quality of service, to resolve disputes, and to improve our customer support processes.

77a7 uses the personal data we collect for the following purposes:

Purpose	Data Used
Account creation and management	Registration data, contact details, KYC documents
Age and identity verification	Date of birth, NID, passport, KYC documents
Processing deposits and withdrawals	Payment method identifiers, transaction data
Fraud prevention and platform security	IP address, device data, transaction patterns, login history
Regulatory and AML compliance	Full transaction history, KYC documents, source of funds
Customer support and dispute resolution	Communications data, account history, transaction records
Responsible gaming monitoring	Gameplay data, session duration, deposit and loss patterns
Platform improvement and analytics	Aggregated usage data, technical and error logs
Marketing communications (opt-in only)	Email address, mobile number, account preferences

77a7 processes your personal data on one or more of the following legal bases depending on the specific processing activity involved:

• Contractual necessity: Processing required to fulfil our obligations under the account agreement with you — including account setup, payment processing, and customer support.
• Legal obligation: Processing required to comply with applicable laws — including anti-money laundering obligations, KYC requirements, and fraud reporting duties.
• Legitimate interests: Processing necessary for our legitimate business interests where those interests are not overridden by your privacy rights — including platform security, fraud prevention, and aggregate analytics.
• Consent: Processing based on your freely given, specific, and informed consent — including sending marketing emails or SMS promotions and the use of non-essential cookies. You may withdraw this consent at any time.

77a7 does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share your data only in the following limited and controlled circumstances:

5.1 Service Providers

We share data with trusted third-party service providers who assist us in operating the platform. These providers act as data processors under our instruction and are contractually bound to handle your data only as directed by 77a7. They include: KYC and identity verification services; payment processing partners including bKash, Nagad, Rocket, Upay, Visa, and Mastercard; game content providers including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi; and cloud infrastructure and hosting providers. All service providers are required to implement appropriate technical and organisational security measures.

5.2 Legal and Regulatory Disclosure

77a7 may be required to disclose your personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where we are legally compelled to do so. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement and will notify you of any such disclosure where we are legally permitted to do so.

5.3 Business Transfers

In the event that 77a7 undergoes a merger, acquisition, or sale of all or substantially all of its assets, your personal data may form part of the transferred assets. In such circumstances, we will notify affected players by email or prominent notice on the platform prior to any transfer taking place, and we will ensure that the receiving entity is bound by privacy obligations no less protective than those set out in this policy.

Some of the third-party service providers we work with — in particular, international game studios and cloud infrastructure providers — may process data outside of Bangladesh. Where personal data is transferred to processors located in other countries, 77a7 ensures that appropriate safeguards are in place to maintain the same standard of data protection described in this policy. These safeguards include data processing agreements incorporating standard contractual obligations requiring recipients to protect data to an equivalent standard.

77a7 retains personal data only for as long as is necessary for the purposes described in this policy, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the full duration of your account being open and active on the platform.
• Post-closure account data: Retained for a maximum of 5 years following voluntary account closure, to support any subsequent disputes, regulatory audits, or legal claims.
• Financial transaction records: Retained for a minimum of 7 years following each transaction in line with standard anti-money laundering and financial record-keeping obligations.
• KYC documents: Retained for the same period as financial transaction records — typically 7 years from the last transaction associated with the account.
• Support communications: Retained for up to 3 years following the closure of each support ticket, unless the matter escalates to a formal dispute or legal proceeding, in which case records are retained until final resolution.
• Marketing consent records: Retained for the duration of your consent plus 2 years following opt-out, as evidence of the consent having been given and withdrawn.

When retention periods expire, data is securely deleted or anonymised so that it can no longer be associated with an individual player.

As a 77a7 player, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact us at [email protected] with the subject line "Privacy Request" along with your account username and a description of your request.

• Right of Access: You have the right to request a copy of all personal data that 77a7 holds about you. We will provide this in a structured, commonly used, machine-readable format within 30 days of your request.
• 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. Please note that correcting certain data (such as your name or date of birth) may trigger an additional KYC verification step.
• Right to Erasure ("Right to Be Forgotten"): In certain circumstances, you may request that we delete your personal data. This right is subject to limitations — we cannot delete data that we are legally required to retain for financial compliance or fraud prevention purposes. Where deletion is not possible in full, we will inform you of the specific data that must be retained and the reason why.
• Right to Restrict Processing: You may request that we restrict the processing of your data in certain circumstances — for example, while a dispute regarding data accuracy is being resolved.
• Right to Data Portability: You have the right to receive certain data you have provided to us in a structured, machine-readable format and to have it transferred to another controller where technically feasible.
• Right to Object: You have the right to object to processing based on our legitimate interests at any time. You also have an unconditional right to opt out of direct marketing at any time, which we will action immediately upon receipt.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to the withdrawal.

9.1 What Are Cookies

Cookies are small text files placed on your device by the 77a7 platform when you visit the site. They allow the platform to recognise your device across page visits and sessions, helping to deliver a consistent and functional experience. We also use similar technologies such as local storage and session storage for equivalent purposes.

9.2 Types of Cookies We Use

77a7 uses the following categories of cookies:

• Strictly Necessary Cookies: These are essential for the platform to function correctly. They include session authentication cookies that keep you logged in across page navigations, security tokens that prevent cross-site request forgery attacks, and load-balancing cookies. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: These remember your preferences such as language settings, preferred game categories, and notification settings. They improve your experience but are not strictly essential to platform operation.
• Analytics Cookies: We use aggregated, anonymised analytics to understand how players navigate the platform — which pages are visited most frequently, where users drop off in the registration flow, and which game categories are most popular. This data is processed in aggregate only and is not linked to individual player identities without consent.

77a7 does not use third-party advertising cookies, social media tracking pixels, or cross-site behavioural profiling technologies. We do not participate in any advertising network data-sharing arrangements.

9.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please be aware that disabling strictly necessary cookies will impair the functionality of the 77a7 platform and may prevent you from logging into your account. Instructions for managing cookies are available in the help documentation for all major browsers including Chrome, Firefox, Safari, and Edge.

The 77a7 platform is strictly for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from any individual under the age of 21. If we become aware that a person under the age of 21 has registered an account or provided personal data to us, we will immediately close that account, delete all associated personal data, and void any transactions or balances connected to that account.

If you are a parent or guardian and believe that a minor has registered on the 77a7 platform, please contact us immediately at [email protected] with relevant details. We take underage gambling prevention extremely seriously and will act on all such reports without delay.

77a7 employs a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Key measures include:

• Encryption in transit: All data transmitted between your device and the 77a7 platform is encrypted using 256-bit TLS/SSL protocols. The padlock icon in your browser address bar confirms this encryption is active.
• Encryption at rest: Sensitive personal data stored on our servers — including identity documents and payment method details — is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. Staff members who require access to player data to perform their job functions are granted the minimum necessary access and are subject to confidentiality obligations and regular security training.
• Two-factor authentication: 77a7 supports two-factor authentication (2FA) for player accounts. We strongly recommend enabling 2FA via your account security settings to add an additional layer of protection against unauthorised access.
• Regular security audits: Our platform and infrastructure undergo regular independent security assessments, including penetration testing and vulnerability scanning, to identify and remediate potential weaknesses before they can be exploited.
• Data breach response: In the unlikely event of a data breach that poses a risk to your rights and freedoms, 77a7 has a documented incident response plan. Affected players will be notified promptly with details of the breach, the data affected, and the steps we are taking to contain and remediate it.

While we take all reasonable steps to protect your data, no internet-based service can guarantee absolute security. You also play a role in keeping your account secure — please use a strong, unique password, enable 2FA, and never share your login credentials with anyone.

77a7 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable legal obligations. When material changes are made, we will notify registered players by email to the address associated with their account and/or by a prominent notice on the platform, with reasonable advance notice of at least 14 days where practicable.

The date of the most recent revision is displayed at the top of this document. Your continued use of the 77a7 platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this policy, you should cease using the platform and contact us to request account closure.

For all privacy-related enquiries, subject access requests, correction requests, erasure requests, or complaints regarding how 77a7 handles your personal data, please contact our Data Protection team using the details below:

• Email: [email protected] (subject line: "Privacy Request")
• Response time: Acknowledgement within 5 business days; resolution within 30 calendar days
• Platform: https://77a7.io

Please include your 77a7 account username, the nature of your request, and any relevant supporting information when contacting us. We may be required to verify your identity before processing certain types of requests — particularly access and erasure requests — to protect against fraudulent submissions.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter through appropriate legal channels available in your jurisdiction. 77a7 takes all privacy complaints seriously and is committed to resolving them fairly and transparently.