77ed Privacy Policy – How We Collect, Use, and Safeguard Your Personal Data

1Who We Are and How to Contact Us

77ed is an offshore online betting and gaming platform operated under the brand name "77ed" and accessible at 77ed.io. We provide sports betting (with a particular focus on cricket markets including BPL, IPL, and Bangladesh Tigers fixtures), live casino games, slots, fishing games, and instant deposit services via Bangladeshi mobile wallet providers and selected bank partners.

For the purposes of this Privacy Policy, 77ed acts as the data controller in respect of personal data collected from players through the platform. As data controller, we determine the purposes and means by which your personal data is processed.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we handle your personal data, please contact our dedicated privacy support team at:

2Scope of This Privacy Policy

This Privacy Policy applies to all personal data collected by 77ed through the following touchpoints:

• The 77ed website at 77ed.io and all pages hosted under that domain.
• The account registration, KYC verification, and login processes.
• Deposit and withdrawal transactions processed through bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank.
• Customer support communications including email, live chat, and any support ticket system operated by 77ed.
• Promotional communications including bonus notifications, newsletters, and event-based alerts sent to players who have opted in to receive them.
• Technical data collected automatically through cookies, log files, and analytics tools when you access the platform.

This Policy does not apply to third-party websites, game studios, or payment processors that operate under their own separate privacy notices. Where our platform links to or integrates with third-party services — including game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — those parties' own privacy practices govern the data they independently collect.

3Personal Data We Collect

77ed collects personal data in two primary ways: data you provide directly to us, and data we collect automatically through your use of the platform. The categories of data we collect are set out below.

3.1 Data You Provide Directly

3.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type, screen resolution, and time zone setting.
• Usage Data: Pages visited, session duration, games played, bets placed, login timestamps, and navigation paths within the platform.
• Cookie Data: Session identifiers, preference cookies, analytics cookies, and performance cookies as detailed in Section 6 of this Policy.
• Transaction Metadata: Deposit and withdrawal timestamps, payment method identifiers, transaction reference numbers, and amounts in Bangladeshi Taka (৳).
• Responsible Gaming Data: Self-imposed deposit limits, session time reminders, cool-off period requests, and self-exclusion status — retained to enforce player-set restrictions.

4How We Use Your Personal Data

77ed uses the personal data we collect exclusively for the following defined purposes. We do not use your data for any purpose incompatible with those listed below without first obtaining your explicit consent or as required by law.

• Account Management: Creating, maintaining, and administering your registered 77ed account, including processing login requests and account profile updates.
• Identity Verification (KYC): Confirming that you meet the minimum age requirement of 21 years and verifying your identity in accordance with our anti-money laundering obligations.
• Payment Processing: Crediting your 77ed wallet with deposits received via bKash, Nagad, Rocket, Upay, and bank transfers, and processing withdrawal requests to your verified payment method.
• Platform Operation: Delivering the sports betting, live casino, slots, and fishing game services that form the core of the 77ed platform. This includes personalising game recommendations and odds displays based on your activity history.
• Customer Support: Responding to queries, resolving disputes, investigating complaints, and providing account assistance via email and live chat.
• Fraud Prevention and Security: Monitoring account activity for signs of prohibited conduct including multi-accounting, VPN usage, bonus abuse, match fixing, and money laundering.
• Responsible Gaming Enforcement: Implementing and enforcing player-requested deposit limits, self-exclusion periods, and session time controls in accordance with our Responsible Gaming Policy.
• Marketing Communications: Sending bonus notifications, promotional updates, and event-based alerts to players who have actively opted in to receive them. You may withdraw this consent at any time by contacting [email protected].
• Legal and Regulatory Compliance: Retaining records as required under applicable anti-money laundering, financial crime prevention, and data protection obligations.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the platform's design, game selection, payment flows, and customer support quality.

5Legal Basis for Processing

77ed processes personal data on one or more of the following legal grounds, depending on the specific purpose and context of processing:

• Performance of a Contract: Processing that is necessary to fulfil our contractual obligations to you as a registered player, including account creation, bet settlement, and payment processing.
• Legal Obligation: Processing required to comply with applicable legal requirements, including anti-money laundering regulations and identity verification obligations imposed on offshore gaming operators.
• Legitimate Interests: Processing carried out in pursuit of 77ed's legitimate business interests where those interests are not overridden by your fundamental rights and freedoms. This includes fraud prevention, security monitoring, and platform analytics.
• Consent: Where we rely on your consent — for example, for sending marketing communications or deploying non-essential cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6Cookies and Tracking Technologies

77ed uses cookies and similar tracking technologies to operate the platform, remember your session, and understand how players interact with the site. Cookies are small text files placed on your device when you visit a website. They do not execute programs or deliver viruses to your device.

The categories of cookies used on the 77ed platform are as follows:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They maintain your login session, remember your language preference, and enable secure deposit and withdrawal flows. You cannot opt out of strictly necessary cookies without disabling the platform entirely.
• Performance and Analytics Cookies: These cookies collect anonymised data about how players use the platform — which pages are visited most frequently, how long sessions last, and where errors occur. This data is used solely to improve platform performance and is never linked to individually identifiable players.
• Functionality Cookies: These cookies remember your personal preferences, such as your preferred game categories, display settings, and responsible gaming controls, so that they persist across sessions.
• Marketing Cookies: Where you have opted in to receive promotional communications, marketing cookies help us measure the effectiveness of campaigns and tailor bonus offers to your activity profile. You may opt out of marketing cookies at any time through your account settings or by adjusting your browser's cookie preferences.

Most web browsers allow you to manage cookie settings through the browser's privacy or settings menu. Restricting or deleting cookies may impair certain platform functions, including the ability to remain logged in during a session.

7Sharing Your Personal Data

77ed does not sell, rent, or trade your personal data to third parties for commercial purposes. We share personal data only in the specific circumstances set out below, and only to the extent necessary for each stated purpose.

• Payment Processors: We share financial data (wallet numbers, transaction amounts, reference numbers) with bKash, Nagad, Rocket, Upay, and our bank transfer partners solely to process deposits and withdrawals to and from your 77ed wallet.
• KYC and Identity Verification Providers: Where 77ed employs a third-party identity verification service to assist with document authentication, your verification documents may be shared with that provider under a strict data processing agreement. The provider is prohibited from using your data for any purpose other than identity verification on 77ed's behalf.
• Game Technology Providers: Certain gameplay data (session identifiers, bet identifiers, game outcomes) is shared with game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi to enable real-time game delivery and dispute resolution. These providers do not receive your full identity or financial data.
• Fraud Prevention and Security Partners: Anonymised behavioural and technical data may be shared with specialist fraud detection services to identify prohibited activities including multi-accounting and bonus abuse.
• Legal and Regulatory Authorities: Where 77ed receives a valid legal request from a law enforcement agency, regulatory body, or court of competent jurisdiction, we will disclose the minimum personal data required to comply with that obligation. We will inform you of such a disclosure where we are legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 77ed's business, personal data held by 77ed may be transferred to the acquiring entity. Affected players will be notified prior to any such transfer and given the option to close their account if they do not consent to the transfer of their data.

8International Data Transfers

77ed operates as an offshore platform and, as a result, some of the personal data we collect may be stored or processed in countries outside Bangladesh. When personal data is transferred internationally, 77ed takes appropriate steps to ensure that the recipient of the data provides an adequate level of protection equivalent to the safeguards described in this Privacy Policy.

International data transfers by 77ed are governed by one or more of the following safeguards:

• Contractual clauses in our data processing agreements with international service providers that require them to protect personal data to a standard equivalent to this Privacy Policy.
• Technical security measures including end-to-end encryption during transmission and access-controlled storage at rest.
• Strict data minimisation practices ensuring that only the minimum data necessary for each cross-border processing purpose is transferred.

If you have questions about the safeguards applicable to any specific international data transfer, please contact us at [email protected].

9Data Retention

77ed retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or as required by applicable legal and regulatory obligations. The general retention periods applied by 77ed are set out below:

• Active Account Data: Identity, contact, and financial data is retained for the full duration of your registered account and for a minimum of five (5) years following permanent account closure, in compliance with anti-money laundering record-keeping requirements.
• KYC Verification Documents: Identity documents (NID scans, passport copies, selfies) are retained for a minimum of five (5) years from the date of verification or account closure, whichever is later.
• Transaction Records: All deposit and withdrawal records are retained for a minimum of five (5) years to satisfy financial record-keeping obligations.
• Support Communications: Email correspondence and live chat transcripts are retained for three (3) years from the date of the interaction to support dispute resolution and quality assurance.
• Analytics and Usage Data: Anonymised, aggregated analytics data may be retained indefinitely as it does not constitute personal data once individual identifiers have been removed.
• Marketing Preferences: Records of marketing opt-in and opt-out choices are retained for five (5) years to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 77ed's internal data destruction procedures. Where data cannot be immediately deleted due to technical constraints, it is isolated from active processing systems until deletion can be completed.

10Security Measures

77ed implements a multi-layered security framework to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include but are not limited to:

• SSL/TLS Encryption: All data transmitted between your device and the 77ed platform is encrypted using industry-standard SSL/TLS protocols, protecting it from interception during transit.
• Encrypted Storage: Sensitive personal data — including identity documents and financial account details — is stored in encrypted form at rest using AES-256 or equivalent encryption standards.
• Access Controls: Access to personal data within 77ed's systems is restricted on a strictly need-to-know basis. Staff members are granted access only to the categories of data required for their specific role.
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their accounts to provide an additional security layer beyond username and password credentials.
• Regular Security Audits: 77ed conducts periodic reviews of its data security systems to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: In the event of a data security incident that affects player personal data, 77ed will take immediate steps to contain the breach, assess its impact, and notify affected players as soon as reasonably practicable.

11Your Rights as a Data Subject

As a player whose personal data is processed by 77ed, you hold the following rights in relation to that data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request – [Your Account Username]". We will respond within ten (10) business days of receiving a verified request.

• Right of Access: You may request a copy of all personal data 77ed holds about you, including the categories of data, the purposes for which it is processed, and any third parties to whom it has been disclosed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or update it. Identity-related corrections may require re-submission of KYC documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations. Data required for AML compliance cannot be deleted before the statutory minimum retention period expires.
• Right to Restrict Processing: In certain circumstances, you may request that we restrict the processing of your personal data — for example, while a dispute regarding data accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request that we provide your personal data in a commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests at any time. Where your objection relates to direct marketing, we will cease processing for that purpose immediately upon receipt of your request.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

12Children and Minors

The 77ed platform is strictly for individuals who are 21 years of age or older. We do not knowingly collect personal data from anyone below the age of 21. This age threshold reflects our commitment to protecting younger adults in the Bangladesh market and aligns with the responsible gaming obligations set out in our Responsible Gaming Policy.

During account registration, all applicants are required to declare their date of birth. KYC verification further confirms that the account holder meets the minimum age requirement before any withdrawal is processed. Where 77ed discovers that personal data has been collected from an individual below the age of 21 — whether due to a false age declaration during registration or any other reason — the account will be suspended immediately, all bonuses and winnings will be forfeited, and all personal data associated with the account will be securely deleted without undue delay.

If you believe that a minor may have created an account on 77ed using false information, please report it immediately to [email protected] so that we can investigate and take appropriate action.

13Third-Party Links and Services

The 77ed platform may contain references to or integrations with third-party services, including game providers, payment processors, and responsible gaming information resources. While we take care to work only with reputable partners, 77ed is not responsible for the privacy practices of any third-party service. Each third party operates under its own privacy notice, and we encourage you to review those notices before interacting with third-party services.

Game studios integrated into the 77ed platform — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — may collect certain gameplay data directly through their game clients. 77ed does not control and is not responsible for the data practices of these studios. Please refer to the individual studio's privacy notice for information on how they handle gameplay data.

Payment providers including bKash, Nagad, Rocket, and Upay process transaction data under their own privacy frameworks regulated by the Bangladesh Bank. 77ed shares only the minimum data necessary to complete each transaction and does not have access to your full mobile banking credentials.

14Changes to This Privacy Policy

77ed reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable legal requirements, or platform functionality. The effective date at the top of this document will be updated each time a material revision is published.

Where changes are material — for example, involving a new category of personal data, a new purpose for processing, or a new category of third-party recipient — we will notify registered players via email or a prominent in-platform notification at least fourteen (14) days before the revised Policy takes effect. Minor editorial corrections or clarifications may be implemented without advance notice.

Your continued use of the 77ed platform after the revised Privacy Policy takes effect constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must stop using the platform and contact us to arrange account closure and data deletion in accordance with Section 11 of this document.