Privacy Policy — 1777ba

1. Introduction

1.1 This Privacy Policy ("Policy") describes how 1777ba ("the Platform", "we", "us", "our") collects, uses, stores, and protects the personal data of individuals ("you", "your", "the Player") who access or use the 1777ba website and associated services, including casino games, sports betting markets, and the player account management system.

1.2 1777ba is committed to handling personal data with the highest standards of care, transparency, and security. This Policy is intended to give you a clear, honest account of our data practices so that you can make informed decisions about your use of the 1777ba platform.

1.3 By registering an account on 1777ba, by depositing funds, or by continuing to use the platform after this Policy has been made available to you, you acknowledge that you have read and understood the data practices described herein.

1.4 This Policy must be read alongside the 1777ba Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and the Terms & Conditions regarding data matters, this Policy shall prevail.

2. Personal Data We Collect

2.1 1777ba collects the following categories of personal data in the course of providing its services to players based in Bangladesh:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, national ID or passport number, photograph	Account registration & KYC verification
Contact Data	Email address, mobile phone number, residential address (district, city)	Account registration & ongoing correspondence
Financial Data	bKash / Nagad / Rocket / Upay account numbers, bank account details, transaction history, deposit and withdrawal records in BDT (৳)	Deposits, withdrawals, and payment verification
Account Data	Username, encrypted password, account balance, bonus balances, wagering history, game session logs	Ongoing platform use
Technical Data	IP address, device type and model, operating system, browser type and version, time-zone (BST, UTC+6), session timestamps	Automatically on each visit or login
Usage Data	Pages visited, games played, bet amounts, win/loss records, features used, search queries within the platform	Automatically during platform use
Communications Data	Support ticket content, live chat transcripts, email correspondence, complaint records	When you contact 1777ba support
Responsible Gaming Data	Self-exclusion elections, deposit limit settings, time-out period records, cooling-off requests	When you activate responsible gaming tools

2.2 We do not collect sensitive special-category personal data such as racial or ethnic origin, religious beliefs, or health information unless it is volunteered by you in the context of a responsible gaming support request, in which case it is handled with enhanced confidentiality and used solely to provide the relevant support.

3. How We Collect Your Data

3.1 1777ba collects personal data through the following channels:

• Direct submission: Information you provide when completing the account registration form, submitting identity verification documents, contacting support, or updating your account profile;
• Automated collection: Technical and usage data gathered automatically when you access the 1777ba platform, via server logs, cookies, and similar tracking technologies (see Section 7);
• Payment processors: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, and other supported payment partners when you initiate a deposit or withdrawal;
• Identity verification providers: Where 1777ba engages a third-party KYC verification service to validate government-issued identity documents, that provider may return verification results (pass/fail status and document validity confirmation) to 1777ba;
• Anti-fraud and AML systems: Automated risk-scoring data generated by 1777ba's internal anti-money-laundering and fraud-detection processes, derived from your account activity patterns.

4. Purpose of Processing

4.1 1777ba processes your personal data only for the purposes described below. We do not process personal data for any purpose that is incompatible with those originally stated at the time of collection.

• Account administration: Creating, maintaining, securing, and closing your 1777ba player account;
• Identity verification (KYC): Confirming that you are who you say you are, that you are at least 18 years of age, and that your payment methods belong to you;
• Transaction processing: Accepting deposits in BDT (৳) and processing approved withdrawal requests to your nominated payment account;
• Regulatory compliance: Meeting anti-money-laundering (AML), counter-terrorism-financing (CTF), and responsible gaming obligations, including retaining transaction records for the legally required minimum period;
• Platform improvement: Analysing aggregated, anonymised usage patterns to improve game selection, platform performance, and the overall player experience;
• Customer support: Handling your queries, complaints, and responsible gaming requests promptly and accurately;
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, account takeover attempts, and bonus abuse;
• Marketing communications: Sending you personalised promotional offers and platform updates via email or in-platform notification — only where you have provided explicit consent, which you may withdraw at any time.

5. Legal Basis for Processing

5.1 1777ba processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform the player account agreement with you, including account creation, payment processing, and game provision;
• Legal obligation: Processing required to comply with AML, KYC, and responsible gaming regulatory requirements;
• Legitimate interests: Processing undertaken to prevent fraud, protect platform security, and improve service quality, where those interests are not overridden by your rights;
• Consent: Processing for optional purposes such as direct marketing communications, where your prior, freely-given consent has been obtained and can be withdrawn at any time without affecting your ability to use the platform.

6. Data Sharing & Disclosure

6.1 1777ba does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data with the following categories of recipients strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment service providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Sonali Bank, and Islami Bank — solely for the purpose of processing your financial transactions;
• KYC and identity verification partners: Third-party identity verification providers engaged to validate your government-issued documents as part of the account verification process;
• Game technology providers: Studio providers such as Pragmatic Play, Evolution Gaming, Ezugi, Microgaming, NetEnt, and Spribe may receive your Player ID and session tokens necessary to deliver licensed game content — they do not receive your full identity or financial data;
• Fraud prevention and AML services: Specialist third-party providers that help 1777ba detect and prevent fraudulent transactions and money laundering activity;
• Legal and regulatory authorities: Where required by applicable law, court order, or a request from a competent regulatory authority, 1777ba may disclose personal data to law enforcement or other government bodies;
• Professional advisers: Lawyers, auditors, and accountants who require access to data in the course of providing professional services to 1777ba, subject to confidentiality obligations.

6.2 Any third party with whom 1777ba shares personal data is required to process that data only for the specified purpose and in accordance with data protection standards at least equivalent to those applied by 1777ba.

7. Cookies & Tracking Technologies

7.1 The 1777ba platform uses cookies and similar tracking technologies to ensure the platform functions correctly and to enhance your experience. The types of cookies used are as follows:

• Strictly necessary cookies: Essential for the platform to operate. These include session authentication cookies that keep you logged in securely. They cannot be disabled without breaking core functionality;
• Functional cookies: Used to remember your preferences, such as your preferred language setting and responsible gaming display options;
• Performance and analytics cookies: Used to collect anonymised data about how players navigate the platform, which pages are visited most, and where technical errors occur. This data helps us improve the platform;
• Security cookies: Used to detect and prevent fraudulent login attempts, session hijacking, and other security threats.

7.2 You may manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging into your 1777ba account. 1777ba does not currently use third-party advertising or cross-site tracking cookies.

8. Data Retention

8.1 1777ba retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or accounting obligations. The general retention periods applied by 1777ba are as follows:

• Account and identity data: Retained for the duration of your active account, and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Support and communications records: Retained for three (3) years from the date of the last interaction;
• Technical and usage logs: Retained for up to twelve (12) months in identifiable form, after which they are anonymised or deleted;
• Marketing consent records: Retained for the duration of consent and for one (1) year following withdrawal of consent to evidence compliance.

8.2 When personal data is no longer required and the applicable retention period has expired, 1777ba will securely delete or anonymise it so that it can no longer be linked to an individual.

9. Data Security

9.1 1777ba implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 1777ba platform;
• Encryption of sensitive data fields (including financial data and identity documents) at rest on secured servers;
• Role-based access controls ensuring that only authorised 1777ba personnel can access personal data, and only to the extent required for their specific job function;
• Regular penetration testing and security audits conducted by independent cybersecurity professionals;
• Automated intrusion detection and real-time threat monitoring systems;
• Multi-factor authentication requirements for platform administrative access.

9.2 While 1777ba takes all reasonable precautions to protect your data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights or freedoms, 1777ba will notify you promptly and take all available remedial steps without undue delay.

10. Your Data Rights

10.1 As a player on the 1777ba platform, you hold the following rights with respect to your personal data. To exercise any of these rights, please submit a written request to [email protected], including your registered account username and a clear description of your request. We will respond within thirty (30) days of receipt.

• Right of access: You may request a copy of the personal data 1777ba holds about you and information about how it is being processed;
• Right to rectification: You may request that inaccurate or incomplete personal data held about you be corrected or completed without undue delay;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the original processing purpose, subject to overriding legal or regulatory retention obligations;
• Right to restriction: You may request that processing of your data be restricted in certain circumstances, for example while the accuracy of data is disputed;
• Right to data portability: Where processing is based on your consent or on contractual necessity, you may request a machine-readable copy of your personal data for transfer to another provider;
• Right to object: You may object to processing carried out on the basis of 1777ba's legitimate interests, including profiling for direct marketing purposes. Such objections will be honoured unless 1777ba can demonstrate compelling legitimate grounds that override your interests;
• Right to withdraw consent: Where processing is based on your consent (e.g., for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

10.2 1777ba will not charge a fee for processing data rights requests made in good faith. Where a request is manifestly unfounded or excessive, 1777ba reserves the right to charge a reasonable administrative fee or to decline the request, providing written reasons for any refusal.

11. Children's Privacy

11.1 The 1777ba platform is strictly intended for adults aged 18 years and above. 1777ba does not knowingly collect or process personal data from individuals under the age of 18. If we become aware that personal data has been submitted by or on behalf of a person under 18, we will delete that data immediately and close the associated account.

11.2 Parents and guardians who believe that a minor may have registered an account on 1777ba are urged to contact [email protected] immediately so that the account can be reviewed and closed without delay. 1777ba takes its responsibilities regarding the protection of minors extremely seriously and operates age verification checks as part of the KYC process.

12. Third-Party Services & Links

12.1 The 1777ba platform integrates third-party services including game content providers (such as Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, Microgaming, and Spribe) and payment partners. These third parties operate under their own privacy policies and data practices. 1777ba is not responsible for the privacy practices of third-party service providers beyond the contractual data protection obligations we impose on them.

12.2 The 1777ba platform does not contain links to external third-party websites for general browsing purposes. Where integration with a payment provider's interface is required to complete a transaction (for example, a bKash or Nagad payment confirmation screen), that interaction is governed by the respective payment provider's privacy policy.

13. Amendments to This Policy

13.1 1777ba reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. The effective date at the top of this document indicates when the most recent revision was made.

13.2 Where changes to this Policy are material — meaning they significantly affect how your data is processed or your rights in relation to that data — 1777ba will notify you via the email address registered to your account at least fourteen (14) days before the changes take effect. For non-material clarifications or updates, the revised Policy will be published on the platform without individual notification.

13.3 Continued use of the 1777ba platform following notification of a material change constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised Policy, you must cease using the platform and contact [email protected] to arrange account closure.

14. Contact Us

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 1777ba handles your personal data, please contact us using the details below. All data-related correspondence should be submitted in English to ensure accurate and timely handling:

• Email: [email protected]
• Response Time: Within 30 calendar days for formal data rights requests; within 24 hours for general privacy enquiries
• Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)
• Coverage: All players across Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, Mymensingh, and all other regions of Bangladesh