77nd Privacy Policy – How We Collect, Use, and Protect Your Data

1 Introduction and Scope

This Privacy Policy ("Policy") describes how 77nd ("77nd", "we", "us", "our") collects, processes, stores, and protects personal data relating to any individual ("you", "the User", "Player") who accesses or uses the 77nd website located at https://77nd.io and all associated services, games, and features (together, "the Platform").

This Policy applies to all personal data collected through the Platform, regardless of the device or method by which you access it. It covers data collected during account registration, gameplay, financial transactions, customer support interactions, and any other engagement with 77nd's services.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference into the overall user agreement between you and 77nd.

By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2 Data Controller

77nd operates as the data controller in respect of the personal data collected through the Platform. As data controller, 77nd determines the purposes and means of processing your personal data and is responsible for ensuring that processing activities comply with applicable data protection principles.

All data protection queries, access requests, and formal complaints should be directed to the 77nd Data Protection contact via the email address provided in Section 15 of this Policy. 77nd will endeavour to respond to all data protection enquiries within 30 days of receipt.

3 Information We Collect

77nd collects personal data in the following categories. The specific data points collected will depend on the nature of your interaction with the Platform:

3.1 Registration and Identity Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Email address
• Mobile phone number
• Residential address (city, district, country)
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• National Identity Card (NID) number and scanned copy
• Passport data page (where NID is unavailable)
• Driving licence (as alternative identity document)
• Selfie or live photograph (for biometric identity match where required)
• Source-of-funds documentation (where enhanced due diligence is triggered)

3.3 Financial and Transaction Data

• Mobile wallet account identifiers (bKash, Nagad, Rocket, Upay numbers — masked after verification)
• Bank card details (card number masked; only last four digits retained)
• Bank account information (Dutch-Bangla Bank, City Bank, and other supported institutions)
• Deposit amounts, dates, and transaction reference numbers
• Withdrawal requests, amounts, and processing records
• Account balance history

3.4 Gameplay and Betting Data

• Bet history, wager amounts, and outcomes
• Games accessed and session durations
• Responsible gaming tool usage (deposit limits set, session times configured, self-exclusion requests)
• Bonus and promotion claims and wagering progress
• Reward Points balance and tier status within the 77nd VIP Rewards program

3.5 Technical and Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type and version
• Unique device identifiers
• Login timestamps and session activity logs
• Referral source (how you arrived at 77nd.io)

3.6 Communications Data

• Content of support tickets, live chat transcripts, and email correspondence submitted to 77nd
• Survey responses and feedback submissions
• Notification preferences (email, SMS opt-in or opt-out status)

77nd does not knowingly collect sensitive special-category personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data for identification purposes) except where biometric matching is expressly required during a mandatory KYC check, in which case the data is processed for identity verification only and deleted once the check is complete.

4 How We Use Your Information

The personal data collected by 77nd is used exclusively for the purposes described in this Policy. The primary purposes are as follows:

77nd will not use your personal data for any purpose that is incompatible with the purposes listed above without first notifying you and, where required, obtaining your explicit consent.

5 Lawful Basis for Processing

Every processing activity carried out by 77nd relies on one of the following lawful bases:

• Contractual necessity: Processing required to perform the contract between you and 77nd — including account creation, payment processing, and gameplay delivery.
• Legal obligation: Processing required to comply with applicable laws — including anti-money laundering (AML) requirements, age verification obligations, and fraud reporting duties.
• Legitimate interests: Processing carried out for 77nd's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided those interests are not overridden by your data protection rights.
• Consent: Processing for which you have given explicit, freely given, informed, and specific consent — primarily promotional email and SMS communications. You may withdraw consent at any time by contacting support or updating your notification preferences within your account settings.

6 Cookies and Tracking Technologies

77nd uses cookies and similar tracking technologies on the Platform to maintain session continuity, improve platform performance, and analyse user behaviour in aggregate. The categories of cookies used are as follows:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without impairing your ability to use the Platform.
• Functional cookies: Remember your preferences (such as language settings, responsible gaming limits, and notification preferences) so you do not need to re-enter them on each visit.
• Analytics cookies: Collect aggregated, anonymised data about how players interact with the Platform, which pages are visited most frequently, and where technical errors occur. This data helps 77nd improve the platform experience.
• Marketing cookies: Where you have consented, these cookies enable 77nd to serve relevant promotional content and track the effectiveness of marketing campaigns. Marketing cookies are not set without your prior consent.

You may manage your cookie preferences at any time through your browser settings. Blocking strictly necessary cookies will impair platform functionality. Blocking other categories will not prevent you from using the Platform but may reduce the personalisation of your experience.

77nd does not use cookies to build personal profiles for sale to third parties, and does not allow third-party advertising networks to set cookies on the Platform.

7 Sharing Your Information

77nd does not sell, rent, or trade your personal data. We may share your data only in the following circumstances and only to the extent strictly necessary for the stated purpose:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, and City Bank receive the minimum financial data required to process your deposits and withdrawals. Each processor operates under its own privacy framework and is bound by contractual data handling obligations with 77nd.
• Identity verification providers: Third-party KYC service providers receive identity documents solely for the purpose of verifying your identity and age. These providers are contractually prohibited from using your data for any other purpose.
• Game software providers: Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Ezugi, and other licensed game studios receive session and gameplay data necessary to deliver the game experience. They do not receive your full identity or financial data.
• Fraud and AML compliance partners: Where required by our internal risk management framework, anonymised or pseudonymised data may be shared with specialist fraud detection or AML screening services.
• Legal and regulatory authorities: 77nd will disclose personal data to law enforcement agencies, financial intelligence units, or other competent authorities where legally required to do so, or where disclosure is necessary to prevent serious harm or fraud.
• Professional advisers: Legal counsel, auditors, and accountants may access relevant data on a strictly need-to-know basis and under confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of 77nd's business, player data may be transferred to the successor entity. You will be notified of any such transfer by prominent notice on the Platform at least 30 days in advance.

In all cases where data is shared with third-party service providers, 77nd requires those providers to implement appropriate technical and organisational security measures and to process data only in accordance with 77nd's documented instructions.

8 International Data Transfers

77nd operates as an offshore platform and may store or process personal data on servers located outside Bangladesh. Where your personal data is transferred to a country that does not provide a level of data protection equivalent to the standards set out in this Policy, 77nd will implement appropriate safeguards, which may include:

• Standard contractual clauses approved by recognised data protection authorities
• Binding corporate rules where applicable
• Contractual data processing agreements with third-party recipients that impose obligations at least equivalent to those in this Policy

By using the 77nd Platform, you acknowledge that your data may be processed in jurisdictions outside Bangladesh and that the data protection laws of those jurisdictions may differ from Bangladeshi law. 77nd will take all reasonable steps to ensure your data remains protected regardless of where it is processed.

9 Data Retention

77nd 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 and regulatory obligations. The following retention guidelines apply:

• Active account data: Retained for the full duration of your account's active status.
• Closed account data: Following account closure, identity and transaction records are retained for a minimum of 5 years to comply with anti-money laundering record-keeping requirements.
• KYC documents: Retained for 5 years from the date of verification or account closure, whichever is later.
• Transaction records: Retained for 5 years from the date of each transaction.
• Support communications: Retained for 3 years from the date of the most recent communication in a support thread.
• Marketing consent records: Retained for 3 years from the date consent was given or withdrawn, whichever is more recent.
• Cookie and analytics data: Anonymised aggregated analytics data may be retained indefinitely. Individual session data is retained for no more than 13 months.

When retention periods expire, personal data is securely deleted or anonymised in accordance with 77nd's internal data disposal procedures. Anonymised data that cannot be re-linked to an individual is not subject to retention limits and may be retained for statistical and platform improvement purposes.

10 Your Data Rights

Subject to applicable law, you have the following rights in relation to the personal data 77nd holds about you:

• Right of access: You may request a copy of the personal data 77nd holds about you, together with information about how it is processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data. You may also update basic account information (such as your contact number or address) directly through your account settings dashboard.
• Right to erasure: In certain circumstances — for example, where the data is no longer necessary for the original purpose — you may request deletion of your personal data. This right is subject to overriding legal obligations, such as AML record-keeping requirements, which may prevent full deletion.
• Right to restriction: You may request that 77nd restricts processing of your data where you contest its accuracy, object to processing, or require the data to be preserved for a legal claim.
• Right to data portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that 77nd provides your data in a structured, commonly used, machine-readable format.
• Right to object: You may object at any time to processing activities based on legitimate interests, including profiling. 77nd will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• 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 submit a written request to [email protected] including your account username and a description of the right you wish to exercise. 77nd will respond within 30 days of receiving a verifiable request. In complex or high-volume cases, this period may be extended by a further 30 days, of which you will be notified.

77nd may need to verify your identity before processing a data rights request to prevent unauthorised access to another person's data.

11 Security Measures

77nd implements a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 77nd's servers
• Encryption of sensitive data at rest, including identity documents and financial records
• Role-based access controls limiting data access to authorised personnel on a need-to-know basis
• Multi-factor authentication requirements for all internal administrative access
• Regular penetration testing and vulnerability assessments of the Platform infrastructure
• Intrusion detection and monitoring systems operating on a continuous basis
• Incident response procedures for detecting, reporting, and remediating personal data breaches
• Staff training on data protection obligations and security best practices

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 77nd will notify affected players without undue delay and will take all reasonable steps to contain and remediate the breach.

Notwithstanding the above measures, no data transmission over the internet and no storage system is completely secure. 77nd cannot guarantee absolute security and accepts no liability for breaches that occur despite the implementation of reasonable security measures.

12 Children and Minors

The 77nd Platform is strictly intended for individuals aged 21 years and above. 77nd does not knowingly collect personal data from any person under the age of 21. If 77nd becomes aware that personal data has been submitted by or on behalf of a person under 21, that data will be deleted immediately and the associated account will be permanently closed.

Parents and guardians who believe their child has registered on the 77nd Platform are encouraged to contact 77nd immediately at [email protected] so that the account can be investigated and closed without delay.

77nd employs age verification checks at registration and reserves the right to conduct additional document-based age verification at any time. These checks are a critical component of both our legal compliance obligations and our responsible gaming commitments. For more information, please visit the Responsible Gaming page.

13 Third-Party Links

The 77nd Platform may contain references or links to third-party services, including payment providers such as bKash, Nagad, Rocket, and Upay, whose own privacy policies govern the processing of data you submit directly to those services. 77nd is not responsible for the privacy practices of third-party platforms and encourages you to review their respective privacy notices before submitting any personal data to them.

The inclusion of any reference to a third-party service on the 77nd Platform does not constitute an endorsement of that service's privacy or security practices.

14 Changes to This Policy

77nd reserves the right to update or amend this Privacy Policy at any time. When material changes are made, 77nd will:

• Update the "Last Updated" date at the top of this Policy
• Display a prominent notice on the Platform for a period of at least 7 days following the change
• Where operationally feasible, send a notification to the registered email address associated with each active account

Your continued use of the 77nd Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with a revised Policy, you should close your account and cease using the Platform prior to the effective date of the change.

77nd recommends that you review this Policy periodically to remain informed of how your personal data is being handled.

15 Contact and Complaints

If you have any questions, concerns, or formal complaints regarding this Privacy Policy or the manner in which 77nd processes your personal data, please contact us using the details below. All communications should be in English to ensure accurate and timely handling.

• Email: [email protected]
• Response time: General privacy queries within 5 business days; formal data rights requests within 30 days
• Support hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)

Please include your registered account username and a clear description of your query or complaint. For data rights requests, please also specify which right you wish to exercise (see Section 10).

If you are not satisfied with 77nd's response to a formal data protection complaint, you may seek further recourse through applicable civil legal processes in the jurisdiction of your residence. 77nd will cooperate fully with any legitimate regulatory or legal inquiry relating to its data processing activities.