Privacy Policy — 77ee

77ee ("77ee", "we", "us", "our") is committed to protecting the privacy and personal data of all users of its platform. This Privacy Policy sets out how 77ee collects, processes, stores, shares, and protects personal information provided by or collected from players who use the 77ee website and related services. By creating an account on 77ee or by continuing to use the 77ee platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.

1 Information We Collect

77ee collects personal information from players in order to operate the platform, verify identity, process financial transactions, provide customer support, and comply with applicable legal and regulatory requirements. The categories of personal information we collect, and the context in which we collect them, are set out in the table below.

77ee does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information, except where such information is incidentally disclosed during identity verification and is necessary for the specific purpose of that verification. Any such data disclosed incidentally is not retained beyond the immediate verification purpose.

2 How We Use Your Information

77ee uses the personal data we collect strictly for the following purposes. We do not use your data for any purpose that is incompatible with those listed below, and we do not repurpose data for commercial activities unrelated to the operation of the 77ee platform.

• To create and manage your 77ee account, including processing your registration, verifying your identity and age, and maintaining accurate account records.
• To process financial transactions, including deposits made via bKash, Nagad, Rocket, or Upay, and withdrawals to your registered payment method.
• To provide customer support and respond to enquiries, disputes, or complaints submitted by you to the 77ee support team.
• To comply with legal and regulatory obligations, including anti-money-laundering checks, age verification requirements, and any reporting obligations imposed by applicable law.
• To detect, investigate, and prevent fraudulent activity, account abuse, or any prohibited activity as defined in the 77ee Terms and Conditions.
• To send account-related communications such as deposit confirmations, withdrawal notifications, and security alerts. These communications are necessary for account operation and cannot be opted out of while your account is active.

77ee does not use personal data for automated decision-making processes that produce significant legal effects on players, beyond the automated fraud-detection and eligibility-check systems that are necessary for secure platform operation.

3 Legal Basis for Processing

77ee processes personal data on the basis of the following legal grounds, applied on a purpose-by-purpose basis:

• Contractual necessity: Processing your account data, payment data, and game activity data is necessary to perform the contract between you and 77ee — specifically, to allow you to register, deposit, play, and withdraw.
• Legal obligation: Processing identity verification data, transaction records, and audit logs is required to comply with applicable law, including anti-money-laundering obligations.
• Legitimate interests: Processing technical data such as IP addresses and device identifiers to detect fraud, prevent account abuse, and maintain platform security is in the legitimate interests of 77ee and its player community.
• Consent: Where 77ee sends you optional promotional messages or uses non-essential cookies, this processing is based on your consent, which you may withdraw at any time from your account settings or browser preferences.

4 Sharing of Your Information

77ee does not sell personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and only to the extent necessary for the stated purpose:

• Payment service providers: bKash, Nagad, Rocket, and Upay receive only the transaction data necessary to process your deposits and withdrawals. These providers have their own privacy policies governing the use of your data in connection with their services.
• Technology and infrastructure providers: 77ee works with vetted technology partners who host and maintain platform infrastructure. These partners process data on behalf of 77ee under strict data processing agreements and are not permitted to use player data for their own purposes.
• Regulatory and law enforcement authorities: 77ee may be required to disclose personal data to competent regulatory bodies, financial intelligence units, or law enforcement authorities in Bangladesh where disclosure is required by applicable law or by a valid legal order.
• Fraud prevention and security partners: Where 77ee uses third-party fraud detection or identity verification services, those providers receive only the data necessary to perform the specific check and are contractually prohibited from retaining or repurposing that data.

77ee does not share your personal data with any advertising networks, data brokers, social media platforms, or analytics companies that would use your data to build advertising profiles or target you with advertisements on other platforms.

5 Payment Data and Financial Information

When you make a deposit or request a withdrawal on 77ee using bKash, Nagad, Rocket, or Upay, the relevant transaction details — including the mobile wallet number associated with the transaction and the transaction reference number — are recorded by 77ee for the purposes of processing the transaction, reconciling accounts, and maintaining financial records as required by applicable law. 77ee does not store full mobile banking PINs, one-time passwords, or any authentication credentials associated with your mobile banking accounts.

Transaction records are retained for a minimum of five years from the date of the transaction, in accordance with applicable financial record-keeping requirements. After the retention period expires, transaction data is securely deleted or anonymised. Players may request a summary of their transaction history at any time by contacting 77ee support.

6 Cookies and Tracking Technologies

77ee uses cookies and similar browser-based technologies to operate the platform and improve your experience. Cookies are small text files placed on your device when you access the 77ee website. The following categories of cookies are used by 77ee:

• Strictly necessary cookies: These cookies are essential for the 77ee platform to function. They maintain your login session, remember your language preference, and enable core platform features such as the betting slip and wallet balance display. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies: These cookies remember your preferences and settings to personalise your experience on 77ee — for example, remembering your preferred sports or game categories. These cookies can be disabled from your browser settings, although doing so may reduce the personalisation of your experience.
• Analytics cookies: 77ee uses limited, privacy-respecting analytics to understand aggregate platform usage patterns — such as which sections of the site are most visited and average session durations. This data is processed in aggregated, anonymised form and is not linked to individual player identities.

You can manage or delete cookies at any time through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging into your 77ee account. For instructions on managing cookies in your specific browser, refer to your browser's help documentation. 77ee does not use cross-site tracking cookies or retargeting pixels that follow you to other websites.

7 Data Retention

77ee retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply: account data is retained for the duration of the account's active life and for a minimum of five years after account closure; transaction records are retained for a minimum of five years; identity verification documents are retained for a minimum of five years from the date of verification. Technical log data such as IP addresses and session records are typically retained for no longer than twelve months.

When personal data is no longer required for any legitimate purpose and the applicable retention period has expired, 77ee will securely delete or anonymise that data. Players who close their 77ee account may request confirmation that their personal data has been deleted, subject to any overriding legal retention obligations. Some data may be retained in anonymised aggregate form for statistical purposes even after the individual-level data is deleted.

8 Security of Your Data

77ee takes the security of player data seriously and implements a range of technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. Our key security measures include:

• SSL/TLS encryption for all data in transit between your device and 77ee's servers, ensuring that your login credentials, personal information, and financial data cannot be intercepted during transmission.
• Encrypted storage of sensitive account data at rest. Passwords are stored using industry-standard one-way hashing algorithms and are never stored in plaintext. 77ee staff cannot retrieve your password — only a password reset is possible.
• Access controls limiting internal access to player personal data to only those staff members who require that access to perform their job functions. All internal access to personal data is logged and subject to periodic audit.
• Regular security reviews and vulnerability assessments of the 77ee platform infrastructure to identify and remediate potential security weaknesses before they can be exploited.

While 77ee takes all reasonable steps to protect your personal data, no system connected to the internet can be guaranteed to be completely immune from attack or unauthorised access. In the event of a personal data breach that is likely to result in a risk to your rights and interests, 77ee will notify affected players as promptly as is practicable under the circumstances.

9 Your Rights Over Your Personal Data

As a registered player on 77ee, you have the following rights in relation to your personal data. To exercise any of these rights, please contact 77ee support at [email protected] with a clear description of your request and proof of your identity.

• Right of access: You may request a copy of the personal data 77ee holds about you. 77ee will provide this within a reasonable period and in a commonly used electronic format.
• Right to rectification: If you believe any personal data 77ee holds about you is inaccurate or incomplete, you may request that we correct or update it.
• Right to erasure: You may request deletion of your personal data in circumstances where the data is no longer necessary for the purpose for which it was collected, or where you withdraw consent (where consent is the legal basis for processing). This right is subject to any overriding legal obligations that require 77ee to retain your data.
• Right to restriction: You may request that 77ee restricts the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to object: You may object to the processing of your personal data where 77ee relies on legitimate interests as the legal basis for processing. 77ee will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.

77ee will respond to all data rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 60 days, in which case 77ee will inform you of the extension and the reason for it within the initial 30-day period. 77ee will not charge a fee for handling data rights requests unless a request is manifestly unfounded or excessive.

10 Children and Underage Users

The 77ee platform is strictly intended for adults aged 21 and above. 77ee does not knowingly collect personal data from individuals under the age of 21. If 77ee becomes aware that personal data has been collected from a person under the age of 21, that data will be deleted immediately and the associated account will be closed without notice.

11 Third-Party Links

The 77ee platform does not contain links to third-party websites, applications, or services that are outside of 77ee's control. If third-party content is ever referenced in a promotional or informational context on the 77ee platform, 77ee is not responsible for the privacy practices of any such third party, and players should review the privacy policies of those third parties independently. 77ee's Privacy Policy applies only to information collected directly through the 77ee platform.

12 Changes to This Privacy Policy

77ee reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, changes in applicable law, or improvements to the 77ee platform. When material changes are made to this Privacy Policy, 77ee will update the "Last updated" date at the top of this page and, where appropriate, notify registered players by posting a notice on the platform.

Your continued use of the 77ee platform following the posting of any changes to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with any revised Privacy Policy, you must cease using the 77ee platform and may request account closure by contacting 77ee support.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 77ee handles your personal data, please contact the 77ee privacy team at [email protected]. We aim to respond to all privacy-related enquiries within 5 business days.