Privacy Policy — How 77xo Protects Your Data

1 Who We Are

This Privacy Policy is published by 77xo ("the Platform", "we", "us", "our"), the operator of the online casino and sports betting service available at https://77xo.io. 77xo provides gambling and gaming entertainment services to eligible players in Bangladesh and other permitted markets.

For the purposes of this Privacy Policy, 77xo acts as the data controller in respect of the personal data of registered players and website visitors. As data controller, 77xo determines the purposes and means by which your personal data is processed.

By registering an account, accessing the 77xo platform, or otherwise using any of our Services, you acknowledge 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 with this Privacy Policy, you must discontinue your use of the 77xo Services.

2 Data We Collect

77xo collects and processes the following categories of personal data in the course of operating the platform and delivering Services to players:

2.1 Registration & Identity Data

• Full legal name as it appears on your official identification document
• Date of birth (used to verify the mandatory 21+ age requirement)
• Gender (optional, where provided)
• Residential address, including city and postal code
• Email address
• Mobile phone number (used for account security and communications)
• Username and encrypted password (we do not store plaintext passwords)

2.2 Identity Verification Documents

• National Identity Card (NID) scan or photograph
• Passport data page
• Driving licence (where used as alternative proof of identity)
• Proof of address documents (utility bill, bank statement not older than three months)
• Selfie or facial photograph submitted as part of liveness verification

2.3 Financial & Transaction Data

• Payment method identifiers (e.g., bKash account number, Nagad account number, Rocket wallet number, Upay account number, bank account or card details where applicable)
• Deposit history: dates, amounts in Bangladeshi Taka (BDT), and payment method used
• Withdrawal history: dates, amounts, destination payment method
• Bonus credits received, wagering activity related to bonuses, and any forfeited amounts
• Net gaming position (aggregate wins and losses) for responsible gaming monitoring purposes

2.4 Gameplay & Activity Data

• Games accessed and played, including game provider (e.g., Pragmatic Play, Evolution Gaming, Spribe, Ezugi)
• Bet amounts, game outcomes, and session duration for each gameplay session
• Sports and cricket betting selections, including markets, odds accepted, and settlement outcomes
• Login timestamps, session lengths, and logout events
• Responsible gaming tool usage (e.g., deposit limit activations, self-exclusion requests, cooling-off periods)

2.5 Technical & Device Data

• IP address at the time of registration and each subsequent login
• Device type (desktop, mobile, tablet), operating system, and browser type and version
• Geolocation data derived from IP address (country and region level; we do not access precise GPS location)
• Cookie identifiers and session tokens
• Referral source (the URL or channel through which you arrived at 77xo.io)

2.6 Communications Data

• Content of support interactions submitted via the 77xo customer support channel ([email protected])
• Records of promotional emails and platform notifications sent to your registered address, and your engagement with those communications
• Formal complaints and dispute records

3 How We Collect Your Data

77xo collects personal data through the following means:

• Directly from you: When you complete the account registration form, submit identity verification documents, make a deposit or withdrawal request, contact customer support, or respond to a survey or promotional communication.
• Automatically: Through cookies, server logs, and tracking technologies that capture technical and device data each time you access the 77xo website or use any feature of the platform. See Section 9 for full details on cookies.
• From third-party verification services: 77xo works with identity verification and age-check service providers to cross-reference the information you provide during registration against authoritative data sources. These providers supply a verification result; they do not grant 77xo access to their underlying databases.
• From payment service providers: When you transact via bKash, Nagad, Rocket, Upay, or a banking partner, the relevant payment service may share transaction confirmation data with 77xo to facilitate deposit crediting and withdrawal processing.
• From fraud prevention and anti-money laundering (AML) screening tools: 77xo uses automated tools to screen player data against watchlists and sanctions lists as required by the platform's AML and counter-terrorism financing obligations.

4 Legal Bases for Processing

77xo processes your personal data on the following legal bases, depending on the specific processing activity:

Where 77xo relies on legitimate interests as a legal basis, those interests have been assessed against your rights and freedoms as a data subject. You may request further information about any such assessment by contacting 77xo at [email protected].

5 How We Use Your Data

The personal data collected by 77xo is used exclusively for the following purposes:

• Account administration: Creating, maintaining, and securing your 77xo account; enabling login and account recovery; enforcing the one-account-per-player rule.
• Transaction processing: Crediting deposits to your account balance; processing withdrawal requests to your registered bKash, Nagad, Rocket, Upay, or bank account; maintaining accurate financial records.
• Identity verification & compliance: Verifying that you meet the 21+ age requirement; conducting KYC checks; screening against AML and sanctions obligations; maintaining records as required for audit purposes.
• Fraud prevention & platform integrity: Detecting and investigating suspicious activity including multi-accounting, bonus abuse, and payment fraud; protecting the interests of all players on the platform.
• Responsible gaming: Monitoring gameplay patterns for signs of problem gambling; applying player-requested limits, cooling-off periods, and self-exclusions; suppressing promotional communications during self-exclusion periods.
• Customer support: Responding to your enquiries, complaints, and account-specific requests sent to [email protected]; maintaining records of support interactions for quality assurance and dispute resolution.
• Service communications: Sending transactional messages such as deposit confirmations, withdrawal status updates, security alerts, and policy change notifications to your registered email address or phone number.
• Marketing communications: Where you have provided consent, sending promotional offers, bonus notifications, and platform news. You may unsubscribe from marketing communications at any time via the unsubscribe link in the email or by contacting support.
• Platform analytics & improvement: Analysing aggregated, anonymised usage data to understand how players interact with the platform, identify technical issues, and improve the overall user experience.
• Legal compliance: Retaining records as required by applicable law; responding to lawful requests from regulatory or law enforcement authorities; defending or prosecuting legal claims.

6 Data Sharing & Disclosure

77xo shares your personal data with the following categories of third parties, solely to the extent necessary to fulfil the purposes described in this Privacy Policy:

6.1 Payment Service Providers

To process deposits and withdrawals, 77xo shares relevant transaction data with bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and other integrated payment partners. These providers receive only the data necessary to execute the specific transaction and are subject to their own data protection obligations as licensed financial service providers in Bangladesh.

6.2 Identity Verification Providers

77xo works with third-party KYC and age-verification service providers to validate player-submitted identity documents and perform liveness checks. These providers process the documents and return a verification result to 77xo. Document images may be stored by the verification provider for the period required by their own data retention obligations.

6.3 Game Studio Providers

When you launch a game provided by a third-party studio (such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, or Ezugi), a session token and your account identifier are shared with the game provider to initiate and authenticate the game session. Game providers are contractually prohibited from using this data for any purpose other than game session management.

6.4 IT Infrastructure & Cloud Service Providers

77xo utilises third-party cloud infrastructure and hosting services to operate the platform. These providers act as data processors under contractual data processing agreements and do not access or use player data for their own purposes.

6.5 Legal & Regulatory Authorities

77xo may disclose personal data to regulatory bodies, law enforcement agencies, or courts where required to do so by applicable law, court order, or legal process. Where permitted by law, 77xo will endeavour to notify you of such disclosure.

6.6 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of 77xo or its assets, player personal data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections being maintained by the recipient.

7 International Data Transfers

77xo operates a platform that serves players primarily in Bangladesh. Some of the third-party service providers with whom 77xo works — including cloud infrastructure providers and certain game studio partners — may process data on servers located outside of Bangladesh. Where such international transfers occur, 77xo takes steps to ensure that appropriate safeguards are in place to protect your personal data, including contractual data transfer agreements that incorporate internationally recognised data protection principles.

By using the 77xo Services and providing your personal data, you acknowledge that your data may be transferred to and processed in countries outside of Bangladesh. 77xo will not transfer your personal data to a jurisdiction unless it is satisfied that adequate protections are in place for that transfer.

8 Data Retention

77xo retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, and in accordance with applicable legal retention obligations. The following general retention periods apply:

After the applicable retention period has elapsed, personal data is securely deleted or anonymised in accordance with 77xo's internal data disposal procedures. Where data is anonymised rather than deleted, the resulting anonymised data sets are no longer personal data and fall outside the scope of this Privacy Policy.

9 Cookies & Tracking Technologies

77xo uses cookies and similar tracking technologies to ensure the proper functioning of the platform, to remember your preferences, and to understand how players use the site. This section explains what cookies we use and how you can manage them.

9.1 What Are Cookies?

Cookies are small text files that are placed on your device by a website when you visit it. They allow the website to recognise your device on subsequent visits and to remember certain information about your session or preferences. Cookies are widely used across the internet and are essential to the operation of most online platforms.

9.2 Categories of Cookies Used by 77xo

• Strictly Necessary Cookies: These cookies are essential for the operation of the 77xo platform. They enable core functions such as maintaining your logged-in session, securing account access, and remembering items in your account dashboard. The platform cannot function correctly without these cookies. They do not require your consent.
• Functional Cookies: These cookies remember your preferences and settings — for example, your preferred language, display settings, and responsible gaming tool configurations. They improve your experience on the platform but are not strictly required for it to operate.
• Analytics Cookies: 77xo uses analytics tools to collect aggregated, anonymised data about how visitors use the platform — including which pages are most visited, how long sessions last, and where technical errors occur. This data is used to improve the platform. Analytics cookies require your consent before being set.
• Security Cookies: These cookies support 77xo's fraud detection and account security systems. They help identify unusual login patterns and potential account compromise attempts.

9.3 Managing Your Cookie Preferences

You may manage your cookie preferences through your web browser settings. Most browsers allow you to block or delete cookies, or to be notified before a cookie is set. Please note that disabling strictly necessary cookies will impair the functionality of the 77xo platform and may prevent you from accessing certain features, including account login.

77xo does not use third-party advertising cookies, cross-site tracking pixels, or social media tracking technologies on the 77xo.io domain.

10 Security Measures

77xo implements a multi-layered approach to data security, incorporating both technical and organisational controls designed to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. The principal security measures in place include:

• TLS/SSL Encryption in Transit: All data transmitted between your device and the 77xo platform is encrypted using Transport Layer Security (TLS). The padlock icon visible in your browser's address bar when visiting 77xo.io confirms that an encrypted connection is active.
• Encryption at Rest: Sensitive personal data stored in 77xo's databases — including identity documents, financial data, and account credentials — is encrypted using industry-standard algorithms.
• Access Controls: Access to systems containing player personal data is restricted to 77xo staff and authorised personnel who require that access in the course of their duties. Access is governed by role-based permission controls and logged for audit purposes.
• Firewalls & Intrusion Detection: 77xo's infrastructure is protected by enterprise-grade firewalls and intrusion detection systems that monitor for suspicious traffic patterns and attempted breaches.
• Vulnerability Management: 77xo conducts regular security assessments and vulnerability scans of its platform infrastructure. Identified vulnerabilities are remediated in accordance with a risk-prioritised patching schedule.
• Staff Training: All 77xo staff who handle personal data receive data protection and information security training as part of their onboarding and on an ongoing basis.

11 Your Rights as a Data Subject

As a player whose personal data is processed by 77xo, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact 77xo at [email protected] with your registered username and a clear description of your request. 77xo will respond within 30 calendar days of receiving a verifiable request.

• Right of Access: You may request a copy of the personal data that 77xo holds about you, along with information about how it is being processed. This is sometimes referred to as a Subject Access Request (SAR).
• Right to Rectification: If any personal data that 77xo holds about you is inaccurate or incomplete, you may request that it be corrected or updated. For certain data points (such as your registered email address or phone number), you may be able to update them directly via your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where: it is no longer necessary for the purposes for which it was collected; you withdraw consent and no other legal basis applies; or the data has been unlawfully processed. Please note that this right is subject to overriding legal obligations — for example, financial transaction records may need to be retained for a period after account closure regardless of an erasure request.
• Right to Restriction of Processing: You may request that 77xo restrict the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested, or while an objection to processing is being assessed.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, and is carried out by automated means, you may request that 77xo provide your personal data to you in a structured, commonly used, and machine-readable format.
• Right to Object: You may object to the processing of your personal data where that processing is based on 77xo's legitimate interests. You have an unconditional right to object to processing of your data for direct marketing purposes at any time.
• Rights Related to Automated Decision-Making: Where 77xo makes decisions about you solely by automated means — for example, automated fraud scoring — and those decisions produce significant effects, you have the right to request human review of such decisions, to express your point of view, and to contest the outcome.

77xo will not charge a fee for handling data subject rights requests unless a request is manifestly unfounded or excessive. In such cases, 77xo may charge a reasonable administrative fee or decline to act, with written reasons provided.

12 Children & Minors

The 77xo platform is strictly intended for adults aged 21 years and above. 77xo does not knowingly collect, process, or store personal data belonging to any individual under the age of 21. The minimum age requirement is enforced through the account registration process, which requires players to declare their date of birth, and through the KYC identity verification process.

If 77xo discovers or is informed that an account has been registered by a person under the age of 21, the account will be immediately suspended, all associated data will be reviewed, and the account will be permanently closed. Any balance held in the account will be handled in accordance with 77xo's underage gambling policy. Where a deposit has been made by an underage player, 77xo will endeavour to return the funds to the originating payment method after completing its investigation.

13 Third-Party Links

The 77xo platform may contain references to or integrations with third-party services, including game studio interfaces. While 77xo takes care to partner only with reputable service providers, 77xo is not responsible for the privacy practices of third-party platforms or services that operate independently of the 77xo domain.

When you interact with a third-party game interface embedded within the 77xo platform, that interaction may be subject to the game provider's own privacy policy in addition to this Privacy Policy. Players are encouraged to review the privacy policies of individual game providers if they have concerns about how their data is handled within a specific game environment. Game provider names are displayed within each game interface for reference.

14 Changes to This Privacy Policy

77xo reserves the right to update or revise this Privacy Policy at any time to reflect changes in the Services, applicable law, or data processing practices. When material changes are made — meaning changes that significantly affect how your personal data is used or your rights as a data subject — 77xo will notify registered players by email to their registered address and will display a prominent notice on the 77xo.io homepage for a period of at least 14 days prior to the changes taking effect.

The "Last Updated" date displayed at the top of this Privacy Policy document will be revised each time a change is made. Your continued use of the 77xo Services after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Privacy Policy, you must close your account and cease using the Services.

77xo encourages all players to review this Privacy Policy periodically to stay informed about how their personal data is being protected. A current version of the Privacy Policy is always available at https://77xo.io/privacy-policy.

15 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to 77xo's data processing practices, please contact the 77xo Data Protection team using the details below. All privacy-related correspondence should be submitted in English to ensure timely processing.

77xo aims to resolve all privacy-related enquiries and data subject rights requests within 30 calendar days of receipt. Where a request is complex or voluminous, 77xo may extend this period by a further 60 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day window.

If you are dissatisfied with 77xo's response to a privacy complaint or data subject rights request, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction. 77xo is committed to cooperating fully with any such authority in the resolution of complaints relating to the processing of personal data.