Privacy Policy for
77hba Platform Users

1. Information We Collect

77hba collects personal data from players in the following three ways: information you provide directly during registration and account use; information generated automatically by your interaction with the platform; and information received from trusted third-party service providers such as payment processors and identity verification partners.

1.1 Information You Provide Directly

When you register an account with 77hba or use features of the platform, you may be asked to provide:

• Identity data: Full legal name, date of birth, gender, nationality, and a copy of your government-issued National ID (NID), passport, or driving licence for KYC purposes.
• Contact data: Mobile phone number (including the bKash, Nagad, or Rocket wallet number used for transactions), email address, and residential address in Bangladesh or elsewhere.
• Account credentials: Username and encrypted password chosen during registration.
• Financial data: Mobile banking numbers (bKash, Nagad, Rocket, Upay), card details for Visa or Mastercard transactions, deposit amounts, withdrawal requests, and transaction history.
• Communications data: Messages sent to the 77hba support team via live chat or email, including any documents or screenshots you attach to a support request.

1.2 Information Collected Automatically

When you access and use the 77hba platform, certain technical data is collected automatically through cookies, server logs, and similar technologies:

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and the mobile network or internet service provider you are using.
• Usage data: Pages and game sections visited, time spent on each section, games played, bet amounts, session durations, login timestamps, and navigation paths through the platform.
• Location data: Approximate geographic location derived from your IP address. 77hba does not collect precise GPS-level location data unless you explicitly grant permission through a mobile browser.
• Cookie data: Identifiers stored in cookies and similar tracking technologies on your device. See Section 5 of this policy for full details.

1.3 Information from Third Parties

77hba may receive supplementary personal data from authorised third-party sources, including:

• Identity verification and KYC service providers who confirm the authenticity of the documents you submit.
• Payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard) who confirm transaction status and flag suspicious payment activity.
• Fraud prevention and anti-money-laundering (AML) screening services that cross-reference your data against relevant watchlists.

2. How We Use Your Data

77hba uses the personal data collected for the following clearly defined purposes. We do not use your data for any purpose beyond those stated in this policy without first obtaining your explicit consent or establishing a separate legal basis under applicable data protection standards.

Purpose	Data Used	Legal Basis
Account registration and authentication	Identity data, contact data, credentials	Contractual necessity
Processing deposits and withdrawals	Financial data, identity data	Contractual necessity
Identity verification (KYC)	Identity data, contact data	Legal obligation
Fraud prevention and AML compliance	Financial data, device data, usage data	Legal obligation / Legitimate interest
Customer support and complaint resolution	Communications data, account data	Contractual necessity
Platform personalisation	Usage data, cookie data	Legitimate interest / Consent
Responsible gaming monitoring	Usage data, financial data	Legal obligation / Legitimate interest
Promotional communications (opt-in only)	Contact data, usage data	Consent
Platform analytics and improvement	Usage data, device data (anonymised)	Legitimate interest

2.1 Promotional Communications

77hba may send you marketing communications about bonuses, promotions, seasonal offers (such as Eid and Pohela Boishakh specials), BPL and IPL betting promotions, and new game releases — but only if you have opted in to receive such communications at the time of registration or via your account settings. You can opt out of marketing communications at any time by updating your notification preferences in your account dashboard or by contacting support at [email protected].

Opting out of marketing communications does not affect the delivery of transactional messages, which include deposit confirmations, withdrawal notifications, KYC verification updates, and security alerts. These messages are sent as part of the contractual service 77hba provides to you and cannot be disabled while your account is active.

3. Legal Basis for Processing

77hba processes personal data in accordance with internationally recognised data protection standards. For each category of data processing activity, 77hba relies on at least one of the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 77hba — i.e., to operate your account, process your deposits and withdrawals, and provide you with access to the games and features of the platform. Without this processing, 77hba could not deliver its core service.
• Legal Obligation: Certain processing activities are required by law. These include identity verification under Know Your Customer (KYC) requirements, transaction monitoring under Anti-Money Laundering (AML) regulations, and record-keeping obligations. 77hba has no discretion to opt out of these requirements.
• Legitimate Interest: 77hba processes some data based on its legitimate business interests, provided those interests are not overridden by your rights and interests. Examples include fraud prevention, platform security monitoring, responsible gaming analytics, and general platform improvement. 77hba always conducts a balancing assessment before relying on this basis.
• Consent: Where 77hba relies on your consent as the legal basis for processing — most notably for marketing communications and non-essential cookies — you have the right to withdraw that consent at any time without penalty. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

4. Data Sharing & Disclosure

77hba does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Your personal data is only shared in the following carefully controlled circumstances:

4.1 Service Providers

77hba engages trusted third-party service providers who process personal data on our behalf in order to support the operation of the platform. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, and Mastercard — to facilitate deposits and withdrawals.
• KYC and identity verification providers: To verify identity documents submitted during account verification.
• AML and fraud screening services: To screen transactions and player profiles against relevant databases.
• Cloud hosting and infrastructure providers: Who store platform data in secure, encrypted environments.
• Customer support software providers: Who provide the live chat infrastructure used by the 77hba support team.

All third-party service providers are bound by data processing agreements that require them to handle your data securely, use it only for the specific purpose for which it was shared, and not retain it beyond the period necessary to fulfil that purpose.

4.2 Legal and Regulatory Disclosure

77hba may disclose your personal data to law enforcement agencies, regulatory authorities, or courts where it is legally required to do so. Examples include responding to a valid court order, complying with an anti-money-laundering investigation, or reporting suspicious transactions as required under applicable law. In such cases, 77hba will disclose only the minimum data necessary to satisfy the legal requirement and will notify you of the disclosure where permitted by law.

4.3 Business Transfers

In the event that 77hba undergoes a merger, acquisition, or sale of all or part of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified by email before your data is transferred and becomes subject to a different privacy policy.

5. Cookies & Tracking Technologies

77hba uses cookies and similar tracking technologies (including local storage objects and session tokens) to provide a functional, secure, and personalised experience on the platform. A cookie is a small text file stored on your device by your browser when you visit a website.

5.1 Types of Cookies Used

Cookie Type	Purpose	Duration
Strictly Necessary	Maintain your login session, remember your language preference, and secure your account from cross-site request forgery (CSRF) attacks. These cannot be disabled without breaking core platform functionality.	Session / Up to 30 days
Functional	Remember your game preferences, bet size defaults, and display settings so you do not need to reconfigure them on every visit.	Up to 90 days
Analytics	Collect anonymised data about how players navigate the platform — which pages are visited most, where users exit, and how long sessions last. Used to improve the platform experience.	Up to 12 months
Security & Fraud Prevention	Identify unusual login patterns, detect device fingerprinting anomalies, and flag potentially fraudulent sessions for review by the 77hba security team.	Up to 6 months

5.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent core platform features — including login and account access — from functioning correctly. Instructions for managing cookies in major browsers (Chrome, Firefox, Safari, Edge) are available in each browser's help documentation.

77hba does not currently use third-party advertising cookies or sell cookie data to advertising networks.

6. Data Retention

77hba retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following retention schedule applies:

• Account and identity data (active accounts): Retained for the full duration of your account and for a minimum of 5 years following permanent account closure, to satisfy AML and record-keeping requirements.
• Transaction records: Retained for a minimum of 5 years from the date of the transaction, in line with standard financial record-keeping obligations.
• KYC documents: Retained for a minimum of 5 years following the completion of the KYC review or account closure, whichever is later.
• Customer support communications: Retained for 3 years from the date of the last communication in a support thread.
• Marketing consent records: Retained for 3 years from the date of consent or last opt-in confirmation, or until consent is withdrawn.
• Analytics data (anonymised): Retained indefinitely in fully anonymised form — no personal identifiers are linked to this data after the anonymisation process is complete.
• Security and fraud logs: Retained for up to 2 years from the date of the logged event.

When data reaches the end of its retention period, it is securely deleted or irreversibly anonymised. 77hba conducts regular data audits to ensure compliance with this retention schedule.

7. Your Privacy Rights

77hba respects your right to control your own personal data. Subject to applicable laws and the limitations described in this policy, you have the following rights with respect to the personal data 77hba holds about you:

• Right of Access: You have the right to request a copy of all personal data 77hba holds about you. This is sometimes called a Subject Access Request (SAR). 77hba will respond to valid access requests within 30 days.
• Right to Rectification: If any personal data 77hba holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Many data fields (such as contact details) can be updated directly through your account dashboard.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where it has been unlawfully processed. Note that this right is subject to legal retention obligations described in Section 6.
• Right to Restriction of Processing: In certain circumstances, you have the right to ask 77hba to restrict (but not delete) the processing of your personal data — for example, while a dispute about accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, you have the right to receive a copy of your personal data in a structured, machine-readable format so that you can transfer it to another provider.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interest, including profiling for responsible gaming monitoring purposes. 77hba will cease the processing unless it can demonstrate compelling legitimate grounds that override your rights.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications or analytics cookies), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact the 77hba data protection team at [email protected] with the subject line "Privacy Rights Request". Please include your registered username and the email address linked to your account so that we can verify your identity before processing your request. All requests are handled free of charge.

8. Data Security

77hba takes the security of your personal data extremely seriously. We implement a layered security architecture combining technical, organisational, and procedural safeguards designed to protect your data against unauthorised access, accidental loss, destruction, or disclosure.

8.1 Technical Safeguards

• 256-bit SSL/TLS encryption on all data in transit between your device and the 77hba platform.
• Encryption at rest for all sensitive personal data and financial records stored in 77hba databases.
• Hashed passwords — 77hba never stores your password in plain text. Passwords are stored as one-way cryptographic hashes.
• Two-factor authentication (2FA) via SMS OTP, available to all account holders and strongly recommended.
• Automated intrusion detection systems that monitor platform traffic for anomalous patterns in real time.
• Regular penetration testing conducted by independent security specialists to identify and remediate vulnerabilities.

8.2 Organisational Safeguards

• Access to personal data is granted on a strict need-to-know basis. 77hba staff members can only access the data necessary for their specific job function.
• All staff who handle personal data receive regular training on data protection obligations and security best practices.
• Third-party service providers who process data on behalf of 77hba are subject to rigorous security assessments before onboarding and periodic reviews thereafter.

8.3 Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, 77hba will notify affected players as promptly as practicable and provide clear guidance on protective actions you can take. 77hba maintains a documented incident response plan for data breach scenarios, which is reviewed and tested annually.

9. Third-Party Services

The 77hba platform integrates with licensed third-party game studios and service providers to deliver the full range of products available to players. These providers include Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, among others. When you play a game hosted by one of these providers, certain technical data (such as your session token, bet history, and game result data) is transmitted to the relevant provider's systems in order to deliver the game experience.

Each third-party game studio operates under its own privacy practices and is bound by contractual obligations with 77hba to handle player data securely and in accordance with applicable standards. 77hba does not share your full personal profile (name, NID, address) with game studios — only the minimum session-level data necessary to run the game is transmitted.

9.1 Payment Partners

When you make a deposit or withdrawal using bKash, Nagad, Rocket, Upay, Visa, or Mastercard, your transaction data is processed directly by the respective payment provider. Each of these providers operates under its own privacy policy and applicable financial regulations. 77hba shares only the transaction details necessary to complete your payment — we do not share browsing history, game activity, or unrelated personal data with payment partners.

9.2 Analytics Providers

77hba may use privacy-respecting analytics tools to understand aggregate platform usage patterns. Where such tools are used, data is anonymised or pseudonymised before processing, and 77hba does not permit analytics providers to use player data for their own independent purposes or to share it with other clients.

10. Children's Privacy

The 77hba platform is strictly intended for adults aged 18 years and above. 77hba does not knowingly collect personal data from individuals under the age of 18. Registration on the platform requires confirmation that the user is at least 18 years old, and all accounts are subject to age verification as part of the KYC process.

If 77hba becomes aware that personal data has been collected from a person under the age of 18, that account will be suspended immediately, all associated funds will be reviewed in line with the 77hba Terms & Conditions, and the personal data will be deleted as promptly as legally permissible. If you have reason to believe that a minor has registered an account on the 77hba platform, please notify us immediately at [email protected].

Parents and guardians are encouraged to make use of parental control software to prevent minors from accessing online gambling platforms. 77hba also supports the use of responsible gaming tools including self-exclusion. For more information, please visit the Responsible Gaming page.

11. Updates to This Policy

77hba reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect updates to the platform's features, new legal or regulatory requirements, changes in data processing practices, or feedback from players.

The most current version of this Privacy Policy is always published at 77hba.app/privacy-policy. The "Last updated" date displayed at the top of this document will be revised whenever a material change is made. Where a change significantly affects your rights or the way 77hba processes your personal data, we will endeavour to notify registered players by email at least 7 days before the change takes effect.

Your continued use of the 77hba platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated policy, you should cease using the platform and may request account closure by contacting our support team.

12. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 77hba handles your personal data, please contact our dedicated data protection team using the details below. All privacy-related enquiries are handled with strict confidentiality and responded to within 30 days.

• Email: [email protected] — use the subject line "Privacy Enquiry" or "Privacy Rights Request" as appropriate.
• Live Chat: Available 24/7 through the 77hba platform support channel for urgent queries.
• Postal address: Correspondence relating to data protection matters may also be submitted in writing; please contact us via email first to obtain the current postal address for your jurisdiction.

When submitting a privacy rights request, please include your registered username and the email address associated with your 77hba account so that we can verify your identity before processing the request. This verification step is necessary to protect your data from unauthorised access requests by third parties.

77hba is committed to resolving all privacy-related concerns fairly and transparently. If you are not satisfied with our response to your complaint, you have the right to escalate the matter to the relevant data protection authority in your jurisdiction.