77md Privacy Policy — Your Data, Your Rights

Introduction

77md ("we", "us", "our") is committed to protecting the privacy and personal data of every player who uses the 77md platform. This Privacy Policy applies to all personal data collected through the 77md website, mobile site, and any related services provided to players in Bangladesh and other jurisdictions where the Platform is accessible. This policy has been written in plain language to ensure it is clearly understandable. It sets out our obligations as a data controller and your rights as a data subject.

By registering an account or using the 77md Platform, you confirm that you have read this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this Privacy Policy, please do not register an account or use the Platform. Withdrawing consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

Our Privacy Commitments at a Glance

Six principles guide how 77md handles your personal data every day.

1. Information We Collect

77md collects personal data from you directly when you register an account, make a deposit or withdrawal, contact our support team, or use any feature of the Platform. We also collect certain technical data automatically when you visit the Platform. The categories of personal data we collect are described below.

2. How We Use Your Information

77md uses your personal data for the following specific purposes. We will not use your data for any purpose that is incompatible with those listed below without first obtaining your consent.

• 1To create and manage your account, verify your identity, process your deposits and withdrawals, and provide access to all features of the 77md Platform — including cricket betting, live casino, slots, crash games and fish shooting.
• 2To comply with anti-money-laundering (AML) obligations, KYC requirements and any other legal or regulatory requirement applicable to an online gaming and betting platform operating in Bangladesh and other accessible jurisdictions.
• 3To detect and prevent fraud, money laundering, collusion, bonus abuse, account takeover attempts and any other activity that may harm 77md, other players or third parties. We use a combination of automated monitoring and manual review for this purpose.
• 4To personalise your experience on the Platform, including displaying game recommendations based on your play history, sending you promotional communications about bonuses and tournaments that may be of interest to you (where you have consented to receive such communications), and tailoring responsible gaming alerts to your usage patterns.
• 5To operate, maintain, test, improve and develop the Platform, including diagnosing and fixing technical faults, conducting analytics to understand aggregate usage patterns, and planning future feature development. Where analytics data is used for development purposes it is aggregated and anonymised where possible.

3. Legal Basis for Processing

77md processes your personal data only where it has a lawful basis to do so. The primary legal bases on which we rely are as follows.

• 1Contract performance: the processing of your identity data, payment data and gaming data is necessary for us to fulfil our contractual obligations to you as a player on the 77md Platform — including operating your account, processing transactions and providing access to games and betting markets.
• 2Legal obligation: processing of your data for KYC, AML, fraud prevention and regulatory reporting purposes is required for 77md to comply with applicable legal obligations. This processing is non-optional and cannot be refused by the player as a condition of using the Platform.
• 3Legitimate interests: processing of technical data for fraud detection, security monitoring and platform analytics is carried out on the basis of 77md's legitimate interests in maintaining a safe and fair platform. Where we rely on legitimate interests, we have assessed that our interests are not overridden by your rights and freedoms.

4. Sharing Your Information

77md does not sell, rent or trade your personal data to any third party. We share your data only in the limited circumstances described below, and only to the extent necessary for the specified purpose.

5. Cookies and Tracking Technologies

77md uses cookies and similar tracking technologies to operate the Platform, ensure security and improve your experience. When you first access the 77md Platform, you will be presented with information about our use of cookies. The following types of cookies are used.

• 1Essential cookies: these are strictly necessary for the Platform to function and cannot be disabled. They are used for session management, login authentication, security token validation and fraud prevention. Without these cookies the Platform cannot operate.
• 2Analytics cookies: these collect anonymous data about how players use the Platform — including which pages are visited most frequently, how long sessions last and which games are most popular. This data is used in aggregate to improve Platform performance and content. These cookies do not identify you personally.
• 3Preference cookies: these remember your settings and preferences — such as your preferred language, display settings and previously viewed games — so that you do not have to reset them every time you visit. These cookies improve the convenience of your Platform experience.

You may manage cookie preferences through your device or browser settings. Please note that disabling essential cookies will prevent you from accessing the Platform.

6. Data Security

77md implements a range of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration or destruction. These measures include SSL/TLS encryption for all data in transit, encrypted storage of sensitive data at rest, access controls that restrict data access to authorised personnel only, regular security assessments and monitoring of Platform infrastructure, and multi-factor authentication requirements for administrative access.

No method of data transmission or storage is completely secure. While 77md takes all reasonable steps to protect your personal data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 77md will notify affected players without undue delay and take immediate remedial action.

7. Data Retention

77md retains your personal data for as long as your account remains active and for a period thereafter as required by applicable legal and regulatory obligations. Account data, transaction records and KYC documentation are typically retained for a minimum of five years following account closure, in accordance with anti-money-laundering record-keeping requirements. Gaming history and session logs are retained for a shorter period unless they are relevant to an open dispute, investigation or legal proceeding.

Where you have exercised your right to erasure, 77md will delete your personal data as promptly as possible subject to the retention periods required by law. Where data cannot be fully deleted due to legal retention obligations, it will be restricted so that it is no longer actively processed and is used only to fulfil the relevant legal obligation.

8. Your Rights

As a player on the 77md Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team at [email protected] with your account details and a clear description of your request. We will respond within a reasonable timeframe and at no charge.

You also have the right to lodge a complaint with the relevant data protection authority if you believe that 77md has processed your personal data in a manner that does not comply with applicable data protection law. 77md encourages you to contact us first so that we have the opportunity to address your concerns directly before a formal complaint is made.

9. Payments and Financial Data Privacy

77md handles all financial data with a high degree of care. When you make a deposit via bKash, Nagad, Rocket, Upay or any other approved payment method, the relevant transaction data is processed solely for the purpose of completing your transaction and maintaining the financial records required by law. We do not store your full mobile wallet PIN, full bank account credentials or full card details on our servers.

All withdrawal requests are subject to KYC verification to ensure that funds are returned to the verified account holder. This protects players against unauthorised withdrawal attempts and helps 77md meet its obligations under applicable financial regulations. Transaction records are retained for the legally required minimum period and are not used for any purpose other than account management, dispute resolution and regulatory compliance.

10. Children and Minors

The 77md Platform is strictly for adults aged 21 and above. 77md does not knowingly collect personal data from any person under the age of 21. If 77md becomes aware that it has inadvertently collected personal data from a minor, it will immediately delete all such data and close the associated account. If you believe that a minor has registered on the Platform, please notify us immediately at [email protected].

11. Third-Party Links and Game Providers

The 77md Platform may display content provided by third-party game providers — including Evolution Gaming, Pragmatic Play, Spribe, Ezugi, Microgaming and NetEnt. While these providers are bound by data processing agreements with 77md, they operate their own technology infrastructure and may collect certain technical data directly through their game clients (such as device type and session duration) for the purposes of delivering their game content. 77md is not responsible for the privacy practices of third-party game providers beyond the scope of our data processing agreements with them.

12. Changes to This Privacy Policy

77md may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements or the scope of the Platform's services. When we make material changes to this policy, we will notify you via the email address registered on your account or via a prominent notice displayed on the Platform prior to the changes taking effect. The date at the top of this page indicates when the policy was last updated.

Your continued use of the Platform after any updated Privacy Policy has taken effect constitutes your acceptance of the revised policy. If you do not agree to the revised Privacy Policy, you must cease using the Platform and may request closure of your account by contacting our support team.

13. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the way in which 77md processes your personal data, please contact our support team using the email address below. We aim to acknowledge all privacy-related enquiries within one business day and resolve them within two business days.