77b2b Privacy Policy — How We Handle Your Personal Data

In this Policy, the following definitions apply unless context requires otherwise:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to names, contact details, financial information, device identifiers, and behavioural data collected in connection with use of the Platform.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transmission, erasure, or destruction.
• "Data Controller" means the entity that determines the purposes and means of Processing Personal Data — in this context, 77b2b.
• "Data Processor" means a third party that Processes Personal Data on behalf of 77b2b in accordance with documented instructions and appropriate data processing agreements.
• "KYC" means Know Your Customer identity and age verification procedures mandated by responsible gaming obligations and anti-money-laundering (AML) compliance requirements.
• "Cookies" means small text files placed on your device by the Platform for the purposes of session management, preference retention, analytics, and security.
• "BST" means Bangladesh Standard Time, UTC+6, the reference time zone for all time-sensitive provisions of this Policy.
• "Business Day" means any calendar day in Bangladesh excluding public holidays gazetted by the Government of Bangladesh.

77b2b is the Data Controller responsible for Personal Data collected through the Platform. All data rights requests, complaints, and privacy-related enquiries should be directed to our dedicated privacy contact point:

• Platform: https://77b2b.io
• Support email (plain text — not a link): [email protected]
• Support hours: 24 hours per day, 7 days per week, Bangladesh Standard Time (UTC+6)

Where 77b2b engages third-party Data Processors — such as payment gateway operators, game studios, or KYC verification service providers — those processors act under binding data processing agreements that restrict their use of your Personal Data to the specific tasks for which they have been engaged. 77b2b retains full responsibility as Data Controller for ensuring those processors comply with obligations equivalent to those described in this Policy.

77b2b collects Personal Data across several categories, depending on how you interact with the Platform. The following table summarises the categories of data collected, the specific data items within each category, and the context in which they are gathered:

77b2b does not knowingly collect sensitive categories of Personal Data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) except where a photographic NID or passport scan is submitted as part of KYC, in which case any biometric characteristics incidentally present in those documents are processed solely for identity verification and are not separately analysed or stored in a biometric database.

77b2b processes Personal Data for the following specific, documented purposes:

• Account management: Creating, maintaining, authenticating, and supporting your 77b2b account throughout its lifecycle, including processing password resets, contact detail updates, and voluntary account closures.
• Age and identity verification (KYC): Confirming that you are aged 21 or over and that the identity you have registered matches the payment methods linked to your account. This is a non-negotiable operational requirement.
• Payment processing: Executing deposits from and withdrawals to your verified Bangladeshi payment accounts (bKash, Nagad, Rocket, Upay, bank transfer, Visa, Mastercard) accurately and securely.
• Fraud prevention and AML compliance: Detecting and investigating suspicious account activity, identifying patterns consistent with money laundering, match-fixing, bonus abuse, or multi-accounting, and fulfilling any mandatory reporting obligations.
• Responsible gaming monitoring: Tracking gaming behaviour patterns to identify signs of problem gambling, enforcing self-imposed limits and exclusions, and intervening proactively where required.
• Platform improvement and analytics: Analysing aggregated, anonymised usage data to improve game selection, site performance, user interface design, and promotional relevance for Bangladeshi players.
• Customer support: Responding to your enquiries, resolving account disputes, and processing complaints submitted through any support channel.
• Marketing communications: Sending promotional emails, SMS notifications, and in-platform messages about bonuses, seasonal promotions (e.g., Eid specials, BPL cricket offers, Pohela Boishakh promotions), and new game releases — but only where you have given explicit consent and have not subsequently withdrawn it.
• Legal and regulatory compliance: Retaining records as required by applicable law and responding to lawful requests from competent authorities.

77b2b processes your Personal Data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing that is necessary to perform the contract between you and 77b2b — i.e., to operate your account, process your transactions, and deliver gaming services. Without this processing, the Platform cannot function for you.
• Legitimate interests: Processing carried out to further 77b2b's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and analytics — provided those interests are not overridden by your fundamental privacy rights.
• Legal obligation: Processing required to comply with applicable legal obligations, including anti-money-laundering (AML) record-keeping requirements, identity verification mandates, and responses to lawful authority requests.
• Consent: Processing that relies on your freely given, specific, informed, and unambiguous consent — primarily marketing communications. You may withdraw consent for marketing at any time by contacting [email protected] or adjusting your account notification settings. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

The 77b2b Platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure user experience. The following categories of cookies are in use:

• Strictly necessary cookies: Essential for the Platform to operate. These include session authentication tokens, CSRF protection tokens, and load-balancing cookies. These cookies cannot be disabled without rendering the Platform non-functional.
• Functional cookies: Remember your preferences such as language setting, display preferences, and responsible gaming tool configurations so you do not need to re-enter them on each visit.
• Analytics cookies: Collect aggregated, anonymised data about how Players navigate the Platform — pages visited, session duration, error occurrences — to help 77b2b identify and fix usability problems. No individual-level behavioural profiling is conducted via analytics cookies.
• Security cookies: Assist in detecting and preventing fraudulent login attempts, bot activity, and suspicious account access patterns.

77b2b does not use third-party advertising cookies, behavioural retargeting cookies, or cross-site tracking technologies. No cookie data collected on the 77b2b Platform is shared with advertising networks for commercial targeting purposes.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair or prevent your ability to log in and use the Platform. A cookie preference centre is available within your account settings for functional and analytics cookies.

77b2b shares Personal Data with third parties only to the extent strictly necessary for the purposes listed in Clause 4. The following categories of third parties may receive your Personal Data under binding contractual obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank (DBBL), BRAC Bank, City Bank, Islami Bank Bangladesh, Sonali Bank, Visa, and Mastercard — for the sole purpose of executing your deposit and withdrawal instructions.
• KYC and identity verification providers: Third-party verification service providers used to confirm the authenticity of identity documents submitted during the KYC process. These providers are contractually bound to use your data only for verification and not to retain it beyond the period required to complete verification.
• Game studio partners: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, Habanero, Play'n GO, and other certified game providers receive the minimum technical data (e.g., session tokens, bet amounts) necessary to deliver game rounds and return results to the Platform. They do not receive your full identity profile.
• Fraud prevention and AML services: Specialist third-party services used to screen transactions and account behaviour for indicators of financial crime. These services process transactional data under strict data processing agreements and applicable law.
• Legal and regulatory authorities: Competent government authorities, law enforcement agencies, or courts where 77b2b is required by law to disclose information, or where disclosure is necessary to protect the rights, property, or safety of 77b2b, its players, or the public.

77b2b does not share Personal Data with social media platforms, advertising networks, data brokers, or any commercial entity whose primary business is the sale or monetisation of consumer data. No cross-border transfers of Personal Data are made to jurisdictions that do not offer an adequate level of data protection without appropriate safeguards being in place.

77b2b retains Personal Data for no longer than is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following retention schedule applies:

At the end of the applicable retention period, Personal Data is either securely deleted using industry-standard data destruction methods or irreversibly anonymised so that it can no longer be attributed to any identified or identifiable individual. Anonymised data may be retained indefinitely for aggregate statistical purposes.

77b2b implements a layered security architecture to protect Personal Data against unauthorised access, accidental loss, destruction, or disclosure. The following technical and organisational measures are in place:

• Encryption in transit: All data transmitted between your device and the 77b2b Platform is encrypted using TLS 1.2 or higher. The Platform enforces HTTPS for all connections; plain HTTP connections are automatically redirected.
• Encryption at rest: Sensitive Personal Data stored in 77b2b databases — including identity documents, financial account references, and authentication credentials — is encrypted using AES-256 or equivalent standards.
• Access controls: Access to Personal Data within 77b2b's systems is governed by role-based access controls (RBAC). Staff members access only the data necessary for their specific job function. All internal access is logged and subject to periodic audit.
• Password hashing: Account passwords are never stored in plaintext. They are processed using a cryptographic hashing algorithm with salting to protect against credential-exposure attacks.
• Two-factor authentication (2FA): 2FA is available to all account holders and is strongly recommended. Internal 77b2b staff with access to production systems are required to use 2FA without exception.
• Security monitoring: 77b2b operates continuous monitoring for anomalous access patterns, login attempts from unrecognised locations, and other indicators of potential data breach activity.
• Incident response: In the event of a confirmed Personal Data breach that poses a risk to affected individuals, 77b2b will notify affected Players promptly and take all reasonable steps to contain and remediate the breach.

While 77b2b employs all reasonable and technically appropriate security measures, no system connected to the internet can guarantee absolute security. You play an important role in keeping your account secure by maintaining a strong, unique password and enabling 2FA. If you suspect your account credentials have been compromised, contact [email protected] immediately.

As a Player on the 77b2b Platform, you hold the following rights in respect of your Personal Data. All rights may be exercised free of charge by submitting a written request to [email protected]. 77b2b will acknowledge your request within 2 Business Days and provide a substantive response within 10 Business Days:

• Right of Access: You may request a copy of all Personal Data that 77b2b holds about you, together with information about how it is being used, where it is stored, and with whom it has been shared.
• Right to Rectification: If any Personal Data held about you is inaccurate or incomplete, you may request that it be corrected or completed without undue delay.
• Right to Erasure ("Right to Be Forgotten"): You may request the deletion of your Personal Data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where processing is unlawful. This right is subject to overriding legal retention obligations — for example, AML laws may require 77b2b to retain certain records for a defined period regardless of an erasure request.
• Right to Restriction of Processing: You may request that 77b2b restrict the Processing of your Personal Data in certain circumstances, such as while the accuracy of the data is being contested or while an objection to processing is being considered.
• Right to Data Portability: You may request a machine-readable copy of the Personal Data you provided to 77b2b in a structured, commonly used format (such as JSON or CSV), suitable for transmission to another service provider.
• Right to Object: You may object at any time to the Processing of your Personal Data on the basis of legitimate interests, including profiling. 77b2b will cease such Processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where Processing is based on consent (primarily marketing communications), you may withdraw that consent at any time without penalty. Withdrawal does not affect the lawfulness of Processing carried out prior to withdrawal.

77b2b will not discriminate against you — by reducing service quality, restricting account features, or applying unfavourable terms — for exercising any of the rights listed above.

The 77b2b Platform is strictly intended for adults aged 21 years and over. 77b2b does not knowingly collect, process, or retain Personal Data from any individual under the age of 21. Age verification is a mandatory step in the account registration and KYC process, and any account found to belong to an individual under the age of 21 will be immediately suspended and all balances held pending return of verified deposits.

If you have reason to believe that a person under the age of 21 has registered an account on the Platform or has submitted Personal Data through any part of the registration or KYC process, please report this immediately to [email protected]. Upon confirmation, 77b2b will delete all Personal Data associated with the underage account without delay and take appropriate steps to prevent recurrence.

Parents and guardians are encouraged to use parental control software and device-level access restrictions to prevent minors from accessing online gambling platforms. 77b2b supports responsible parenting measures and will cooperate fully with any verifiable parental or guardian concern regarding underage access.

77b2b reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When material changes are made — defined as changes that significantly alter your rights or how your Personal Data is used — 77b2b will provide at least 14 days' advance notice by publishing the revised Policy on this page with an updated effective date and, where reasonably practicable, by sending a notification to your registered email address.

For minor revisions — such as typographical corrections, clarifications that do not alter the substance of the Policy, or formatting improvements — 77b2b may update this page without advance notice. The effective date displayed in the banner at the top of this page will always reflect the date of the most recently published version.

Continued use of the Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not accept a revised Privacy Policy, you must cease using the Platform and request account closure by contacting [email protected] before the revised Policy takes effect. Any Personal Data collected prior to your closure request will be handled in accordance with the Policy version in effect at the time of collection, subject to any overriding legal retention requirements.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 77b2b handles your Personal Data, please contact our privacy team using the details below. All communications should be in English for the fastest possible response:

• Email (plain text — not a link): [email protected]
• Subject line recommended: "Privacy Request — [Your Account Username]"
• Support hours: 24 hours per day, 7 days per week, Bangladesh Standard Time (UTC+6)
• Response commitment: Acknowledgement within 2 Business Days; substantive response within 10 Business Days

If you are not satisfied with 77b2b's response to your privacy concern after following the above process, you have the right to escalate your complaint through any available legal or regulatory channel applicable in your jurisdiction. 77b2b will cooperate fully with any such escalation and will provide all relevant records upon lawful request.

This Privacy Policy is written in English and represents the authoritative version. In the event of any discrepancy between this English version and any translation, the English version prevails in all respects.