77hba Privacy Policy — How We Protect Your Data

1 Introduction

This Privacy Policy describes how 77hba collects, processes, stores, shares, and protects the personal data of individuals who visit, register on, or otherwise interact with the 77hba platform at https://77hba.io. It applies to all registered players, prospective players who browse the platform without registering, and any individual who contacts 77hba through any communication channel.

77hba is an online entertainment platform providing casino games and sports betting services, designed primarily for adult players based in Bangladesh. All services are delivered in English and all transactions are processed in Bangladeshi Taka (৳). The platform is operated and maintained by the 77hba team, which acts as the data controller in respect of all personal data processed under this policy.

This Privacy Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference. In any conflict between those documents and this Privacy Policy on matters of data handling, this Privacy Policy takes precedence.

We review this Privacy Policy regularly to ensure it remains accurate and current. The version number and last-reviewed date in the Table of Contents reflect the most recent revision. Continued use of the 77hba platform following any revision constitutes acceptance of the updated policy.

2 Information We Collect

77hba collects personal data across several categories depending on how you interact with the platform. The following table summarises the categories of data we collect, the specific data points within each category, and the primary source of that data.

We do not collect special categories of sensitive personal data (such as racial or ethnic origin, religious beliefs, health information, or political opinions) unless you voluntarily disclose such information in a communication with our support team, in which case it will be used solely to resolve your query.

3 How We Use Your Data

77hba processes your personal data only for specific, legitimate purposes that are directly connected to operating a safe, fair, and legally compliant gaming platform for Bangladeshi players. The following list sets out all purposes for which your data may be used:

• Account creation and management: To register your account, verify your identity, and maintain your player profile throughout your relationship with 77hba.
• Identity verification (KYC): To confirm that you meet the age requirement of 21 years or above and that the personal details provided are genuine, in accordance with our anti-money-laundering obligations.
• Payment processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, and BRAC Bank, and to maintain accurate transaction records in Bangladeshi Taka.
• Game delivery and personalisation: To provide access to casino games (slots, live dealer, crash games, table games) and sports betting markets (including cricket — BPL, IPL, T20, Bangladesh Tigers), and to present content relevant to your preferences.
• Responsible gaming monitoring: To track gameplay patterns that may indicate problem gambling behaviour, to apply player-requested limits and cooling-off periods, and to intervene proactively where necessary under our responsible gaming obligations.
• Fraud and security prevention: To detect and prevent fraudulent account activity, money laundering, bonus abuse, multi-accounting, and unauthorised access attempts.
• Customer support: To respond to your queries, resolve disputes, process complaints, and maintain records of our communications for quality assurance.
• Legal and compliance obligations: To meet our obligations under applicable laws, including anti-money-laundering requirements, and to respond to lawful requests from competent authorities.
• Marketing communications (with consent): To send you promotional offers, bonus notifications, tournament announcements, and platform updates via email or SMS, where you have opted in to receive such communications.
• Platform improvement: To analyse aggregated, anonymised usage data for the purpose of improving platform performance, game selection, and user experience.

77hba does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review. Where automated systems flag an account for investigation (e.g., a fraud detection algorithm), a trained compliance officer reviews the flagged account before any consequential action is taken.

4 Legal Basis for Processing

77hba processes your personal data under one or more of the following legal bases, depending on the purpose of the processing:

• Contractual necessity: Processing is necessary to perform our obligations under the Terms & Conditions to which you are a party. This covers account management, KYC, payment processing, game delivery, and customer support.
• Legal obligation: Processing is necessary to comply with applicable legal requirements, including anti-money-laundering obligations, age verification requirements, and responses to lawful authority requests.
• Legitimate interests: Processing is necessary for 77hba's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — provided those interests are not overridden by your rights and freedoms.
• Consent: Where we process data for marketing purposes or for any other non-essential purpose not covered by the bases above, we will obtain your explicit consent first. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

5 Data Sharing & Disclosure

77hba does not sell your personal data to any third party. We share personal data only in the limited, specific circumstances described below, and only with parties who are contractually obligated to handle your data in a manner consistent with this Privacy Policy.

• Payment processors: When you make a deposit or withdrawal, your financial details are shared with the relevant payment service provider (e.g., bKash, Nagad, Rocket, Upay, Visa/Mastercard networks, Dutch-Bangla Bank, BRAC Bank) solely to process the transaction. These processors operate under their own privacy frameworks.
• Game providers: Technical session data (such as player session tokens) is shared with third-party game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others) to the extent necessary to deliver their games within the 77hba platform. These studios do not receive your full name, contact details, or financial data.
• KYC and fraud verification services: Identity documents and personal details may be shared with specialist KYC verification partners who assist in confirming the authenticity of documents and cross-checking against fraud and sanction databases.
• Legal and regulatory authorities: 77hba will disclose personal data to law enforcement agencies, regulators, or courts when required to do so by a valid legal obligation or court order. We will notify you of such disclosure where we are legally permitted to do so.
• Internal operations: Personal data is accessible within the 77hba team on a strict need-to-know basis. Support agents, compliance officers, and payment processing staff access only the data categories relevant to their specific role.

6 Cookies & Tracking Technologies

77hba uses cookies and similar tracking technologies (such as local storage objects and session identifiers) to maintain the functionality of the platform, to keep you securely logged in during your session, and to gather aggregated analytics data that helps us improve the platform experience.

The following categories of cookies are used on the 77hba platform:

• Strictly necessary cookies: These cookies are essential for the platform to function. They maintain your login session, preserve your game state, and ensure secure communication between your device and our servers. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies: These cookies remember your preferences — such as your preferred language (English), currency display (৳), and notification settings — so that you do not have to reset them each time you visit.
• Analytics cookies: Aggregated, anonymised data about how players navigate the platform (e.g., which game categories are most accessed, which pages have the highest exit rates) is collected to inform product improvements. Individual players are not identified in this data set.
• Security cookies: Short-lived cookies are used to detect and prevent cross-site request forgery (CSRF) and other session-hijacking attacks.

77hba does not use third-party advertising cookies or behavioural tracking cookies that follow you across other websites. Our cookie use is limited to what is necessary to operate the platform securely and to improve it based on aggregated usage patterns.

You can manage cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent you from logging into the platform. Blocking functional or analytics cookies will not prevent access but may reduce personalisation quality.

7 Data Retention

77hba retains personal data only for as long as it is necessary for the purposes described in this policy, or as required by applicable legal and compliance obligations. The following retention periods apply to the main categories of personal data we hold:

When the applicable retention period expires, personal data is either securely deleted or irreversibly anonymised so that it can no longer be associated with any individual. Anonymised, aggregated data may be retained indefinitely for statistical analysis purposes.

If you request account closure, your personal data will be retained for the post-closure retention periods specified above. You will not receive marketing communications after account closure unless you subsequently re-register and opt in again.

8 Data Security

77hba implements a multi-layered security architecture to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. The specific measures in place include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and our servers, including login sessions, payment flows, and KYC document uploads.
• Password hashing using modern one-way cryptographic algorithms. Your password is never stored in plain text and is not accessible to any 77hba staff member.
• Role-based access controls ensuring that internal staff can access only the data categories required for their specific operational role. Database access is logged and audited regularly.
• Intrusion detection systems that monitor platform traffic for anomalous patterns associated with brute-force attacks, credential stuffing, and session hijacking.
• Regular security assessments conducted by our internal security team to identify and remediate vulnerabilities before they can be exploited.
• Secure document storage for KYC files, with access restricted to the compliance team and encrypted at rest using industry-standard algorithms.

Despite these measures, no internet-based platform can guarantee absolute security. In the unlikely event of a data breach that poses a material risk to your rights and freedoms, 77hba will notify affected players without undue delay and will provide clear information about the nature of the breach, the data affected, the steps we have taken to address it, and any recommended actions on your part.

9 Your Data Rights

As a data subject, you hold the following rights in respect of the personal data that 77hba holds about you. These rights apply regardless of whether your account is currently active, suspended, or closed.

To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request — [Your Account Username]". We will respond within 30 days of receipt, or within 60 days for complex requests (we will notify you if an extension is required). Identity verification may be required before we can action a request, to ensure we do not disclose or delete data at the request of an unauthorised person.

Please note that some rights are subject to exceptions. For example, the right to erasure does not apply where retention is required to meet a legal obligation (such as the financial record-keeping periods described in Section 7). Where a right cannot be exercised in full, we will explain which specific data is affected and why.

10 Children & Minors

The 77hba platform is strictly restricted to individuals aged 21 years or above. We do not knowingly collect personal data from anyone under the age of 21. If you are under 21, you must not attempt to register for or use the 77hba platform.

If 77hba discovers that an account has been registered by, or on behalf of, an individual under the age of 21, we will immediately suspend the account, delete all associated personal data (subject to any mandatory retention obligations arising from financial transactions that may already have taken place), and report the incident to our compliance team for further action.

11 Third-Party Links & Services

The 77hba platform may contain references to third-party game providers and payment services. When you interact with a third-party service embedded within or linked from the 77hba platform — such as a game delivered by Pragmatic Play or Evolution Gaming, or a payment flow processed through bKash or Nagad — that interaction may be governed in part by the third party's own privacy policy.

77hba is not responsible for the privacy practices of third-party game providers or payment processors. We recommend reviewing the privacy policies of any third-party service you interact with. Our data sharing arrangements with these parties are limited to what is strictly necessary for service delivery, as described in Section 5.

The 77hba platform does not embed third-party advertising networks, social media tracking pixels, or external analytics services that would allow third parties to track your browsing behaviour across other websites. Any analytics data collected on the 77hba platform is processed internally and is not shared with external advertising or data platforms.

12 Changes to This Privacy Policy

77hba reserves the right to update or amend this Privacy Policy at any time. When material changes are made — that is, changes that meaningfully affect how your personal data is collected, used, or shared — we will notify registered players by email to the address held on their account at least 14 days before the changes take effect.

Minor clarifications, formatting updates, or corrections that do not alter the substantive scope of data processing will be applied immediately and reflected in the version number and last-reviewed date at the top of the Table of Contents, without individual notification.

Your continued use of the 77hba platform after the effective date of any material update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you should cease using the platform and may request account closure before the updated policy takes effect.

All previous versions of this Privacy Policy are archived and available upon written request to [email protected].

13 Contact & Data Requests

If you have any questions about this Privacy Policy, wish to exercise your data rights, want to report a suspected data breach, or need to raise a privacy concern of any kind, please contact the 77hba Data Protection team using the details below.

Support email (plain text — not a clickable link):

We aim to acknowledge all privacy-related correspondence within 2 business days (Bangladesh Standard Time, UTC+6) and to provide a substantive response or resolution within 30 days. For complex data rights requests, we may require up to 60 days, in which case we will notify you of the extension and the reason for it.

All formal data rights requests must be submitted in writing (by email) and will require identity verification before any data is disclosed, amended, or deleted. This step exists to protect your data from being accessed or modified by unauthorised parties — it is not a barrier to exercising your rights.