77gaya Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") describes how 77gaya ("the Company", "we", "us", "our") collects, uses, stores, and discloses personal data relating to individuals ("you", "your") who access or use the 77gaya platform, including its website, mobile browser experience, games, sports betting services, and all associated features (collectively the "Services").

By registering an account or otherwise using the Services, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Services and contact us to arrange account closure.

77gaya reserves the right to update this Policy periodically. When material changes are made, we will revise the "Effective Date" above and notify registered users by email. Continued use of the Services following such notification constitutes acceptance of the revised Policy.

2 Data We Collect

Depending on how you interact with 77gaya, we may collect the following categories of personal data:

• Identity Data: Full name, date of birth, national identification number, passport number, or other government-issued identifier provided during registration or KYC verification.
• Contact Data: Email address, mobile phone number, and residential address (including city, district, and postal code within Bangladesh).
• Financial Data: Mobile financial service account identifiers (bKash number, Nagad number, Rocket number, Upay account), transaction history, deposit amounts, withdrawal amounts, and account balances.
• Technical Data: IP address, device type, operating system, browser type and version, mobile network operator, screen resolution, and session timestamps.
• Usage Data: Pages visited, games played, bets placed, session duration, click patterns, and navigation paths within the platform.
• Communications Data: Records of messages exchanged with our customer support team via live chat or email, including complaint submissions and their outcomes.
• Verification Documents: Scanned or photographed copies of identity documents submitted during the KYC process, including National ID cards and proof of address documents.

We do not knowingly collect personal data from individuals under the age of 21. If we become aware that a minor has provided us with personal data, we will delete that information immediately and close the associated account.

3 How We Use Your Data

77gaya processes personal data for the following purposes, each of which has a corresponding lawful basis:

• Account Registration and Management: To create and maintain your player account, verify your identity, and provide access to the Services.
• Payment Processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods, and to maintain accurate transaction records.
• KYC and Fraud Prevention: To verify your identity and source of funds, detect suspicious activity, prevent money laundering, and comply with our anti-fraud obligations.
• Customer Support: To respond to your enquiries, resolve disputes, and manage complaints effectively.
• Platform Improvement: To analyse usage patterns, diagnose technical issues, and develop new features that improve the player experience.
• Responsible Gaming: To monitor gaming behaviour, identify indicators of problem gambling, and administer self-exclusion, deposit limits, and other responsible gaming tools at your request.
• Marketing and Promotions: Where you have provided explicit consent, to send you details of relevant promotions, bonuses, and news about 77gaya. You may withdraw consent at any time by contacting support.
• Legal Compliance: To fulfil our obligations under applicable laws, respond to lawful requests from authorities, and enforce our Terms and Conditions.

4 Data Sharing and Disclosure

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

• Payment Service Providers: We share necessary financial data with bKash, Nagad, Rocket, Upay, and any other payment processor required to execute your transactions. These providers are contractually bound to use your data only for the stated purpose.
• Game Content Providers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive technical session data required to operate their games correctly. They do not receive your personally identifiable information beyond what is technically necessary.
• Identity Verification Services: We may share identity documents with accredited KYC verification partners to authenticate your identity and comply with anti-money-laundering requirements.
• Analytics Providers: Aggregated and anonymised usage data may be shared with analytics service providers to help us understand platform performance. No personally identifiable information is included in such datasets.
• Legal and Regulatory Authorities: We may disclose your data to law enforcement agencies, regulatory bodies, or courts if required by applicable law or in response to a valid legal order. We will notify you of such disclosures to the extent permitted by law.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of our business assets, your data may be transferred to the acquiring entity. We will notify affected users before any such transfer takes effect.

All third-party partners with whom we share data are required to maintain appropriate technical and organisational security measures consistent with the standards described in this Policy.

5 Cookies and Tracking Technologies

77gaya uses cookies and similar tracking technologies to operate the platform effectively and improve your experience. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. You cannot opt out of these without ceasing to use the Services.
• Performance and Analytics Cookies: Used to collect anonymised data about how visitors use the platform — for example, which pages are visited most frequently and where errors occur. This helps us improve site performance.
• Functionality Cookies: Store your preferences, such as language settings and game display options, so that they persist between sessions.
• Marketing Cookies: Used where you have consented to receive personalised promotional content. These cookies track browsing behaviour to serve relevant offers.

You can manage or disable non-essential cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of some features on the 77gaya platform. For guidance on managing cookies in popular browsers, refer to your browser's help documentation.

6 Data Retention

77gaya retains your personal data for as long as your account remains active and for a defined period thereafter, in accordance with the following retention schedule:

• Account and Identity Data: Retained for a minimum of 5 years following account closure, in compliance with anti-money-laundering record-keeping obligations.
• Transaction Records: Retained for a minimum of 5 years following the date of the transaction.
• Customer Support Communications: Retained for 3 years following the resolution of a support case, unless the matter is subject to ongoing legal proceedings.
• Marketing Preferences: Retained until you withdraw your consent, after which marketing communications will cease within 10 business days.
• Technical and Usage Data: Anonymised after 12 months and may be retained indefinitely in aggregate form for analytics purposes.

Where data is no longer required for any legitimate purpose, it will be securely deleted or anonymised in a manner that prevents reconstruction of the original personal information.

7 Data Security

We implement a range of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption of sensitive data fields (including payment identifiers and identity document references) at rest in our databases.
• Role-based access controls that restrict employee access to personal data on a strict need-to-know basis.
• Regular security audits and penetration testing conducted by qualified third-party security specialists.
• Multi-factor authentication requirements for staff accessing systems containing personal data.
• Automated alerting systems that flag unusual account activity for human review.

Despite these measures, no system is completely impervious to security threats. In the unlikely event of a data breach that poses a risk to your rights and freedoms, we will notify affected users without undue delay and take all reasonable steps to mitigate the impact.

8 Your Data Rights

As a 77gaya account holder, you have the following rights with respect to your personal data. Requests can be submitted by contacting our support team at [email protected]:

We will respond to all rights requests within the timeframes stated above. Where a request is complex or we receive a high volume of requests simultaneously, we may extend the response period by up to 30 additional days, in which case we will inform you promptly.

9 Children's Privacy

77gaya's Services are strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or store personal data from individuals below the age of 21. Age verification is performed as part of the account registration process and may be supplemented by documentary evidence at any stage.

If a parent or guardian becomes aware that their child has created an account or submitted personal data to 77gaya without authorisation, they should contact us immediately at [email protected]. We will investigate and, where confirmed, promptly close the account and delete all associated data.

10 International Data Transfers

77gaya primarily processes personal data within systems accessible to our operations team. Where data is processed by third-party service providers whose infrastructure is located outside Bangladesh, we take reasonable steps to ensure that appropriate safeguards are in place. This includes contractual data processing agreements that require overseas processors to maintain data protection standards equivalent to those described in this Policy.

By using the Services, you consent to your data being processed in locations outside Bangladesh where such processing is necessary to deliver the Services you have requested, subject to the safeguards described above.

11 Links to Third-Party Content

The 77gaya platform incorporates games and features provided by third-party content partners including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. While we take care to work only with reputable partners, 77gaya is not responsible for the privacy practices of these providers in relation to data they may collect independently through their own systems.

We recommend reviewing the privacy policies of any third-party service that you interact with, particularly where those services involve separate account creation or data submission processes outside the 77gaya platform.

12 Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how your personal data has been handled, please contact our Data Protection team:

• Email: [email protected]
• Response Time: We aim to acknowledge all privacy-related enquiries within 48 hours and provide a substantive response within 14 business days.

If you are dissatisfied with our response to a privacy complaint, you have the right to escalate the matter through appropriate legal channels available to you under applicable consumer protection and data protection laws.