77c Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 77c ("77c", "we", "us", "our") collects, uses, stores, and protects the personal data of individuals ("you", "Player", "User") who access or use the 77c online gaming platform available at https://77c.lol ("Platform"). This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during account registration, identity verification, payment processing, gameplay, and customer support interactions.

77c is committed to handling your personal data responsibly, transparently, and in accordance with applicable data protection principles. By registering an account on the Platform or otherwise using 77c's services, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read alongside 77c's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference. If you do not agree with any aspect of this Policy, you should not use the Platform and should contact support to close your account.

2. Data Controller

For the purposes of applicable data protection law, 77c acts as the data controller in respect of personal data collected through the Platform. As data controller, 77c determines the purposes for which and the means by which your personal data is processed.

All data protection enquiries, subject access requests, and complaints relating to 77c's handling of your personal data should be directed to our support team using the contact details set out in Section 16 of this Policy. 77c will respond to all data-related enquiries within a reasonable timeframe and in any event within the period required by applicable law.

3. Data We Collect

77c collects the following categories of personal data in connection with the provision of its services:

3.1 Identity Data

Full legal name, date of birth, nationality, and copies of government-issued identity documents (such as National ID Card or Passport) provided during account registration or KYC verification processes.

3.2 Contact Data

Residential address (including city — for example Dhaka, Chittagong, Sylhet, Khulna, or Rajshahi), email address, and mobile phone number. This data is used primarily to verify your account, deliver service communications, and provide customer support.

3.3 Financial Data

Payment method details including mobile banking account numbers (bKash, Nagad, Rocket, Upay), card details (Visa, Mastercard — partial numbers only, stored in tokenised form), deposit and withdrawal transaction records, and account balance history.

3.4 Technical Data

IP address, device type, device identifier, operating system version, browser type and version, time zone settings, geolocation data (at country and city level), and session duration logs.

3.5 Usage Data

Records of games played, bets placed, sports markets accessed, promotional offers redeemed, pages visited within the Platform, and timestamps associated with all account activity.

3.6 Communications Data

Records of your interactions with 77c's customer support team, including live chat transcripts, email correspondence, and any information you voluntarily provide when submitting a query or complaint.

4. How We Collect Data

77c collects personal data through the following channels:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated Technologies: Technical and usage data collected automatically as you navigate the Platform, including through server logs, session tracking, and device fingerprinting technologies.
• Payment Processors: Transaction confirmation data received from payment partners including bKash, Nagad, Rocket, Upay, Visa, and Mastercard in connection with deposits and withdrawals.
• Identity Verification Providers: Data returned by third-party KYC verification services engaged by 77c to validate the identity documents you submit.
• Fraud Prevention Services: Risk signals and device reputation data received from fraud detection partners to protect the integrity of the Platform and the security of player accounts.

5. How We Use Your Data

77c uses the personal data it collects for the following purposes:

• Account Creation and Management: To register your account, verify your identity, manage your profile, and administer your relationship with 77c.
• Service Delivery: To process deposits and withdrawals, settle bets and game winnings, apply bonuses, and provide access to all Platform features.
• Legal Compliance: To fulfil obligations under applicable law, including age verification, anti-money laundering (AML) checks, and Know Your Customer (KYC) requirements.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other security threats.
• Customer Support: To respond to your queries, resolve disputes, and improve the quality of support services provided to players.
• Responsible Gaming: To monitor gaming patterns and identify potential indicators of problem gambling, in order to implement protective measures where appropriate.
• Service Improvement: To analyse aggregated usage data, identify platform performance issues, and develop new features that improve the player experience.
• Communications: To send you transactional messages (such as deposit confirmations and withdrawal notifications) and, where you have opted in, promotional communications about 77c offers and events.

6. Legal Bases for Processing

77c processes your personal data under the following legal bases, as applicable to each processing activity:

• Contractual Necessity: Processing required to perform the contract between you and 77c, including account registration, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML obligations, age verification requirements, and responses to lawful requests from authorities.
• Legitimate Interests: Processing carried out in pursuit of 77c's legitimate business interests, including fraud prevention, platform security, and service analytics — provided those interests are not overridden by your rights and freedoms.
• Consent: Processing based on your explicit consent, such as the sending of promotional marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Sharing Your Data

77c does not sell or rent your personal data to third parties. However, we may share your data with carefully selected third parties in the following circumstances:

7.1 Payment Service Providers

We share necessary financial data with payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard) to facilitate deposits and withdrawals. These providers process data only as required to complete payment transactions and are bound by their own applicable data protection obligations.

7.2 Identity Verification Providers

We share identity documents and personal details with third-party KYC verification services to confirm the accuracy of the information you have provided during account registration. These providers are engaged under data processing agreements and are prohibited from using your data for any purpose other than KYC verification on 77c's behalf.

7.3 Fraud Prevention and Security Partners

Technical data including IP addresses, device identifiers, and session metadata may be shared with fraud detection and security service providers to protect the Platform and its players from malicious activity.

7.4 Legal and Regulatory Authorities

77c may disclose personal data to law enforcement agencies, regulatory bodies, or other public authorities where required by applicable law, a court order, or a legitimate legal obligation. 77c will not disclose data to authorities beyond what is strictly required to meet the relevant legal obligation.

7.5 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of 77c's assets, player data may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and the implications for their data prior to any change in data controller.

8. Cookies & Tracking Technologies

77c uses cookies and similar tracking technologies to enhance platform functionality, maintain session integrity, and gather analytical insights. The following types of cookies are used on the Platform:

• Essential Cookies: Required for the Platform to function correctly. These include session management cookies that keep you logged in and security cookies that protect your account. These cookies cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect anonymised data about how players interact with the Platform, including pages visited and features used. This data helps 77c identify and address performance issues and improve the user experience.
• Preference Cookies: Used to remember your account settings and display preferences so that you receive a consistent, personalised experience each time you log in.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot traffic and suspicious login attempts, by analysing device and session characteristics.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the Platform. 77c does not use third-party advertising cookies or share cookie data with advertising networks.

9. Data Retention

77c retains personal data for as long as is necessary to fulfil the purposes outlined in this Policy, or as required by applicable legal and regulatory obligations. The following general retention guidelines apply:

• Account Data: Retained for the duration of your active account relationship with 77c, and for a period of five years following account closure, to comply with anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five years from the date of the transaction to satisfy legal and regulatory requirements.
• KYC Documents: Identity verification documents are retained for the period required by applicable law, typically five years following account closure or the completion of a relevant transaction.
• Customer Support Records: Communications records are retained for two years from the date of the interaction, or longer where the interaction relates to an unresolved dispute.
• Technical Logs: Server and session logs are retained for up to 12 months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to an individual player.

10. Data Security

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

• 256-bit SSL/TLS encryption for all data in transit between your device and 77c's servers.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls ensuring that 77c staff can access personal data only to the extent required by their specific job function.
• Regular independent security assessments and penetration testing of the Platform infrastructure.
• Automated intrusion detection systems and real-time security monitoring.
• Strict data processing agreements with all third-party service providers who handle personal data on 77c's behalf.

Notwithstanding these measures, no internet-based service can provide an absolute guarantee of security. You are responsible for maintaining the confidentiality of your account credentials and for notifying 77c immediately if you suspect any unauthorised access to your account.

11. Your Rights

Subject to applicable law, you hold the following rights in respect of the personal data 77c processes about you:

• Right of Access: You have the right to request a copy of the personal data 77c holds about you, along with information about how it is used and shared.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to Restriction: You have the right to request that 77c restricts the processing of your personal data in certain circumstances, such as while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to processing of your personal data where that processing is based on 77c's legitimate interests, including profiling for marketing purposes.
• 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 before withdrawal.

To exercise any of the above rights, please contact 77c's support team via live chat or at the email address provided in Section 16. 77c will respond to your request within 30 days of receipt. In cases of complexity or high volume of requests, this period may be extended by a further 30 days, in which case you will be informed of the extension and the reasons for it.

12. Children's Privacy

The 77c Platform is intended exclusively for adults aged 18 years and over. 77c does not knowingly collect, store, or process personal data relating to individuals under the age of 18. The Platform employs age verification mechanisms at the point of registration to screen out underage applicants.

If 77c becomes aware that personal data has been collected from an individual under the age of 18, that data will be deleted immediately, the associated account will be closed, and any transactions carried out on the account will be voided. If you believe that 77c may have inadvertently collected data from an underage individual, please contact our support team immediately using the details in Section 16.

13. Third-Party Links

The 77c Platform may contain references to game providers and payment partners (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, bKash, and Nagad). While these partners provide services integrated into the 77c Platform, their own privacy practices are governed by their respective privacy policies. 77c is not responsible for the data handling practices of third-party service providers beyond the scope of contractual data processing obligations imposed on them by 77c.

77c does not include links to external websites for the purpose of advertising or affiliate traffic, and this Policy does not extend to any third-party websites that may be accessible from outside the Platform environment.

14. International Data Transfers

77c's primary operations and player base are centred on Bangladesh. Where personal data is transferred to or processed by service providers located outside Bangladesh (for example, cloud infrastructure providers or KYC verification services), 77c takes steps to ensure that appropriate safeguards are in place to protect your data, including contractual protections equivalent to those applicable under relevant data protection law.

By registering an account and providing personal data to 77c, you acknowledge that your data may be processed outside your country of residence and consent to such transfer where necessary for the provision of 77c's services, subject to the safeguards described in this section.

15. Changes to This Policy

77c reserves the right to update or amend this Privacy Policy at any time. Where changes are material — for example where a new category of data is collected or a new purpose for processing is introduced — 77c will notify registered players via the Platform or by email to the address registered on your account, providing reasonable advance notice before the changes take effect.

The effective date at the top of this page will always reflect the date of the most recent revision. Minor changes (such as typographical corrections or clarifications that do not alter the substance of the Policy) may be made without specific prior notice. We encourage you to review this page periodically to remain informed of how 77c protects your personal data.

16. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to 77c's handling of your personal data, please contact our support team through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week, directly on the Platform after logging in to your account. Live chat is the fastest way to reach our team for privacy-related queries.
• Email: [email protected] — please include "Privacy Request" in the subject line along with your registered account username so that we can locate your records efficiently.
• WhatsApp: Available after login via your account settings for players who prefer messaging-based support.

77c aims to acknowledge all privacy-related enquiries within 24 hours (Bangladesh Standard Time, UTC+6) and to resolve them fully within 30 calendar days of receipt. Where a request is particularly complex or we have received a high volume of requests, we will inform you of any necessary extension to this timeframe.