Your Privacy Matters to 77com

This Privacy Policy ("Policy") describes how 77com ("77com", "we", "us", "our"), the operator of the online betting and casino platform accessible at https://77com.io ("Platform"), collects, uses, stores, shares, and protects the personal data of individuals who access or use the Platform ("you", "Player", "User").

77com is committed to handling all personal data with transparency, integrity, and care. This Policy has been prepared in plain English to ensure that every player understands how their information is managed. Where technical or legal language is unavoidable, we have provided clear explanations.

This Policy should be read alongside the 77com Terms & Conditions (https://77com.io/terms-conditions) and Responsible Gaming Policy (https://77com.io/responsible-gaming), both of which are incorporated by reference. If you have any questions about this Policy, please contact our support team at [email protected] before using the Platform.

77com collects the following categories of personal data from players and visitors to the Platform. We have grouped these categories by type to make it easy to understand what information we hold and why.

2.1 Identity Data

• Full legal name (as it appears on government-issued identification);
• Date of birth (used to verify the 21+ age requirement);
• Gender (optional, provided at registration);
• Copies of government-issued photo identification (National ID Card, Passport, or Driving Licence) submitted during KYC verification.

2.2 Contact Data

• Email address (primary method of account communication);
• Mobile phone number (used for two-factor authentication and account alerts);
• Residential address (required for KYC and anti-money-laundering compliance).

2.3 Financial Data

• Mobile financial service account details (bKash, Nagad, Rocket, or Upay account numbers registered in your name);
• Transaction history including deposit amounts, withdrawal requests, bonus credits, and bet settlements;
• Account balance history.

2.4 Behavioural & Usage Data

• Betting and gaming activity: markets wagered on, bet amounts, outcomes, session duration, and frequency of play;
• Pages visited and features used within the Platform;
• Time and date stamps of all Platform interactions;
• Responsible gaming tool usage (deposit limits set, cooling-off periods activated, self-exclusion requests).

2.5 Technical Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser version;
• Session identifiers and authentication tokens;
• Cookie identifiers (see Section 7 for full cookie details).

2.6 Communications Data

• Records of correspondence between you and 77com support, including chat transcripts and email threads;
• Complaint and dispute records;
• Marketing communication preferences and opt-in/opt-out records.

77com collects personal data through the following channels:

• Direct provision by you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact customer support, or respond to a survey or promotion.
• Automated collection: When you browse or interact with the Platform, our systems automatically collect technical data such as IP address, device information, session data, and behavioural analytics through server logs, cookies, and similar tracking technologies.
• Third-party payment providers: When you deposit or withdraw using bKash, Nagad, Rocket, or Upay, those providers share transaction confirmation data with 77com to facilitate the processing of your funds. 77com receives only the confirmation and relevant account reference; full payment credential data remains with the payment provider.
• Identity verification services: Where 77com engages a third-party KYC or identity verification provider, that provider may return verification results (pass/fail/escalate) alongside any flags raised during the check.
• Fraud and risk screening tools: Automated risk-scoring systems may collect and analyse behavioural patterns to detect potential fraud, money laundering, or prohibited conduct, consistent with 77com's AML obligations.

The table below summarises the primary purposes for which 77com processes your personal data, together with the categories of data used for each purpose.

Purpose	Data Categories Used
Account registration and management	Identity, Contact
Age and identity verification (KYC)	Identity, Contact, Financial
Processing deposits and withdrawals	Identity, Financial
Fraud prevention and AML compliance	Identity, Financial, Technical, Behavioural
Responsible gaming monitoring	Behavioural, Communications
Customer support and dispute resolution	Identity, Contact, Communications
Sending service notifications and alerts	Contact
Sending marketing communications (with consent)	Contact, Behavioural
Platform analytics and product improvement	Behavioural, Technical
Legal and regulatory compliance	All categories as required

77com does not use automated decision-making that produces legal or similarly significant effects without human review. Where automated risk-scoring results in an account restriction, a member of our compliance team will review the decision before it is actioned.

77com 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 under the Terms & Conditions you have agreed to — including account creation, transaction processing, and customer support.
• Legal obligation: Processing required to comply with applicable law, including anti-money-laundering regulations, Know Your Customer requirements, and regulatory reporting obligations.
• Legitimate interests: Processing carried out for 77com's legitimate business interests where those interests are not overridden by your privacy rights — including fraud prevention, platform security, product analytics, and responsible gaming monitoring.
• Consent: Processing carried out on the basis of your explicit consent — including sending marketing emails, SMS promotions, and any processing of special-category data. You may withdraw consent at any time by contacting [email protected] or updating your communication preferences within your account dashboard.

77com does not sell your personal data to any third party. We may share your data with the following categories of recipients only where necessary and only to the extent required for the purpose stated:

• Payment service providers (bKash, Nagad, Rocket, Upay): To process your deposit and withdrawal transactions. These providers act as independent data controllers for the payment leg of the transaction and are governed by their own privacy policies.
• KYC and identity verification providers: Third-party services used to verify the authenticity of identity documents and screen against sanctions, politically exposed persons (PEP), and adverse media databases.
• Fraud and AML screening tools: Risk analytics platforms that help 77com detect suspicious activity and fulfil anti-money-laundering obligations. Data shared is limited to what is necessary for the screening purpose.
• Customer support platforms: Cloud-based support ticketing and live chat systems that store records of your support interactions. These providers are contractually bound to process data only on 77com's instructions.
• Legal and regulatory authorities: Where required by applicable law, court order, or regulatory demand, 77com may disclose personal data to law enforcement agencies, financial intelligence units, or other governmental authorities in Bangladesh or internationally.
• Professional advisers: Lawyers, auditors, and accountants engaged by 77com where access to personal data is necessary for the delivery of their professional services, subject to confidentiality obligations.

All third-party processors engaged by 77com are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with 77com's documented instructions.

77com uses cookies and similar tracking technologies (collectively "Cookies") to operate the Platform efficiently, remember your preferences, analyse usage patterns, and deliver relevant content. The following categories of Cookies are used:

Cookie Type	Purpose	Duration
Strictly Necessary	Enable core Platform functions: user authentication, session management, security tokens, and load balancing.	Session / up to 24 hours
Functional	Remember your language preference, display settings, and previously set responsible gaming limits.	Up to 12 months
Analytics	Collect aggregated, anonymised data on how players navigate the Platform to help us improve page performance and user experience.	Up to 24 months
Marketing	Track engagement with promotional content to measure campaign effectiveness. Only activated with your explicit consent.	Up to 12 months

Strictly Necessary Cookies cannot be disabled as they are essential to the operation of the Platform. You may control Functional, Analytics, and Marketing Cookies through the cookie preference panel accessible from within your account settings. You may also manage cookies through your browser settings; however, disabling certain cookies may impair Platform functionality.

77com retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

Data Category	Retention Period	Basis
Account registration and identity data	Duration of account plus 5 years post-closure	AML legal obligation
KYC documents	Duration of account plus 5 years post-closure	AML legal obligation
Financial transaction records	Duration of account plus 7 years post-closure	AML / audit obligation
Betting and gaming activity logs	Duration of account plus 3 years post-closure	Legitimate interests / dispute resolution
Customer support communications	3 years from date of last interaction	Legitimate interests / dispute resolution
Marketing consent records	Until consent withdrawn, plus 3 years	Legal obligation (consent proof)
Analytics and technical logs	Up to 24 months on a rolling basis	Legitimate interests

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised. Anonymised data (from which no individual can be identified) may be retained indefinitely for aggregate statistical and product development purposes.

As a player whose personal data is processed by 77com, you have the following rights. To exercise any of these rights, please contact [email protected] with the subject line "Data Rights Request" and include your registered username and email address.

• Right of Access: You may request a copy of the personal data 77com holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data held on your account. For basic profile corrections (name spelling, contact details), you may also update these directly within your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected. This right is subject to override where retention is required by law (e.g., AML obligations as detailed in Section 8).
• Right to Restriction of Processing: You may request that 77com restrict processing of your data in certain circumstances, such as where you contest the accuracy of the data or have objected to processing based on legitimate interests.
• Right to Data Portability: You may request an export of your personal data in a structured, commonly used, machine-readable format (CSV or JSON) covering data you have directly provided to 77com.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes at any time. Where you object to direct marketing, we will cease processing for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

77com implements a layered security architecture designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our key security measures include:

• Encryption in transit: All data transmitted between your device and 77com's servers is encrypted using TLS 1.2 or higher. Our Platform is served exclusively over HTTPS.
• Encryption at rest: Sensitive personal and financial data stored in 77com's databases is encrypted using AES-256 symmetric encryption.
• Access controls: Access to production systems containing personal data is restricted to authorised personnel on a role-based, need-to-know basis. Multi-factor authentication is required for all administrative access.
• Penetration testing: 77com conducts periodic security assessments and penetration tests of its Platform infrastructure. Identified vulnerabilities are remediated according to a risk-prioritised schedule.
• Incident response: In the event of a data breach affecting your personal data, 77com will notify affected players without undue delay and will take all reasonable steps to contain, investigate, and remediate the breach.

While 77com takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials and for notifying 77com immediately at [email protected] if you suspect any unauthorised access to your account.

The 77com Platform is strictly intended for adults aged 21 years and above. 77com does not knowingly collect or process personal data from individuals under the age of 21. If we become aware that an account has been registered by or on behalf of a person under 21, we will immediately suspend the account, void any associated transactions, and securely delete the personal data collected.

If you are a parent or guardian and believe that a minor has registered on the 77com Platform without your knowledge, please contact our support team immediately at [email protected]. We take all such reports seriously and will act promptly upon receipt.

77com reserves the right to update or amend this Privacy Policy at any time. The most current version will always be published at https://77com.io/privacy-policy. The "Effective Date" displayed at the top of this page will be updated to reflect the date of the most recent revision.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — 77com will notify registered players by email to the address held on file at least 7 days before the changes take effect. For minor or clarificatory changes, we may update the Policy without advance notice beyond the updated effective date.

Your continued use of the Platform following publication of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with a material change, you may close your account by contacting [email protected] prior to the effective date of the change.

If you have any questions, concerns, or complaints about this Privacy Policy or about how 77com processes your personal data, please contact our support team using the details below. We are committed to resolving all privacy-related queries promptly and transparently.

• Email: [email protected]
• Subject line for data requests: "Data Rights Request" or "Privacy Complaint"
• Support availability: 24 hours a day, 7 days a week, 365 days a year
• Response time: Acknowledgement within 48 hours; substantive response within 14 business days (Bangladesh Standard Time, UTC+6)

When submitting a privacy-related request or complaint, please include your registered username, the email address associated with your account, and a clear description of your request or concern. This will help our team locate your records and respond as efficiently as possible.