9777be Privacy Policy — How We Collect, Use, and Protect Your Data

1 Introduction

9777be ("we", "us", "our", "the Platform") is committed to protecting the privacy of all registered players and visitors. This Privacy Policy describes how 9777be collects, uses, discloses, stores, and protects personal data in connection with the operation of the 9777be online betting and casino platform, which serves players across Bangladesh.

This policy is written in clear, plain English to ensure that players understand their privacy rights and how their data is handled. Where this policy uses legal terminology, an explanation is provided in context. This Privacy Policy should be read alongside the 9777be Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

If you have questions about any aspect of this Privacy Policy or wish to exercise your data rights, please contact the 9777be data support team at any time using the contact details provided in Section 17 of this document.

2 Data Controller

For the purposes of this Privacy Policy, 9777be acts as the data controller in respect of personal data collected from registered players and visitors to the platform. As data controller, 9777be determines the purposes for which personal data is collected and the manner in which it is processed.

Where 9777be engages third-party service providers (such as payment processors, identity verification providers, game studios, and analytics platforms) to process personal data on 9777be's behalf, those providers act as data processors. 9777be enters into written data processing agreements with all third-party processors to ensure that player data is handled in a manner consistent with this Privacy Policy and applicable data protection standards.

3 Data We Collect

9777be collects the following categories of personal data from players and platform visitors:

3.1 Registration and Account Data

• Full legal name
• Date of birth (used to verify the 18+ age requirement)
• Residential address
• Email address
• Mobile phone number
• Chosen username and encrypted password
• Account currency preference (Bangladeshi Taka, BDT)

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (National ID Card, passport, or driver's licence)
• Proof of address documents (utility bills, bank statements, or mobile wallet statements)
• Proof of payment method ownership (screenshots or statements from bKash, Nagad, Rocket, or Upay accounts)
• Selfie or live photograph where enhanced verification is required

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references
• Mobile financial service account identifiers (bKash number, Nagad number, Rocket number, Upay number) — stored as references only, not as full credentials
• Bank account details provided for bank-transfer withdrawals
• Bonus and promotional credit records

3.4 Gaming and Betting Activity Data

• Betting history including sports markets, stake amounts, odds, and outcomes
• Casino game session records including game titles, session duration, wager amounts, and results
• Responsible gaming settings and limit history (deposit limits, session reminders, self-exclusion requests)

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Session start and end times
• Pages visited, features used, and click-path data within the platform
• Error logs and crash reports

3.6 Communications Data

• Customer support interactions (live chat transcripts, email correspondence)
• Complaints and dispute records
• Marketing communication preferences

4 How We Collect Your Data

9777be collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a promotional offer
• Automatically through platform use: Via cookies, session tracking technologies, server logs, and analytics tools as you browse and interact with the 9777be platform
• From payment providers: Transaction confirmation data shared by bKash, Nagad, Rocket, Upay, and partnered banks when you initiate a financial transaction
• From identity verification providers: Verification status and risk flags returned by third-party KYC service providers during the document review process
• From fraud prevention partners: Risk signals and device fingerprinting data used to detect account takeover attempts, bonus abuse, and financial fraud

5 Purposes of Processing

9777be processes your personal data for the following specific purposes:

Purpose	Data Categories Used
Account registration and management	Registration data, contact data
Age and identity verification (18+ compliance)	KYC documents, date of birth
Processing deposits and withdrawals	Financial data, payment method references
Providing sports betting and casino game services	Gaming activity data, account data
Fraud detection and anti-money laundering compliance	Financial data, technical data, KYC data
Responsible gaming monitoring and intervention	Gaming activity data, responsible gaming settings
Customer support and dispute resolution	Communications data, account data, transaction data
Platform improvement and analytics	Technical data, gaming activity data (aggregated)
Marketing communications (where consent given)	Contact data, marketing preferences
Legal compliance and regulatory reporting	All relevant categories as required by law

6 Legal Basis for Processing

9777be processes personal data on the following legal bases, depending on the specific processing activity:

• Contract performance: Processing necessary to fulfil the contractual relationship established when you register an account on 9777be, including delivering betting and gaming services, processing financial transactions, and managing your account
• Legal obligation: Processing required to comply with applicable legal obligations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) regulations, fraud prevention obligations, and responsible gaming duties
• Legitimate interests: Processing carried out for 9777be's legitimate business interests where those interests are not overridden by your privacy rights — including fraud detection, platform security, service improvement analytics, and abuse prevention
• Consent: Processing based on your freely given, specific consent — primarily in relation to marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing

7 Sharing Your Personal Data

9777be does not sell or rent your personal data to any third party. Your data may be shared with the following categories of recipients only where strictly necessary and for the purposes described in this Privacy Policy:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, and other participating financial institutions — shared to facilitate deposit and withdrawal transactions
• Identity verification providers: Third-party KYC platforms that process identity documents and return verification results on 9777be's behalf
• Game studio providers: Providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — limited technical session data is shared to deliver game functionality and record results
• Fraud prevention and security partners: Specialist providers that analyse transaction patterns and device signals to detect and prevent fraud, account takeover, and bonus abuse
• Legal and regulatory authorities: Where required by applicable law, court order, or regulatory direction, 9777be will disclose personal data to competent authorities including law enforcement agencies
• Professional advisers: Legal counsel, auditors, and compliance consultants acting under binding confidentiality obligations

8 Payment Data

When you make a deposit or request a withdrawal on 9777be, financial transaction data is shared with the relevant payment provider (bKash, Nagad, Rocket, Upay, or participating banks) to execute the transaction. 9777be stores transaction reference identifiers, amounts, timestamps, and the payment method type in your account transaction history for record-keeping and dispute resolution purposes.

9777be does not store complete mobile financial service PINs, full bank account credentials, or card security codes. Payment credentials are entered directly through the interfaces of the respective payment providers and are subject to those providers' own security standards and privacy policies. 9777be strongly recommends that you review the privacy policy of your chosen payment provider before initiating a transaction.

All financial transactions processed via the 9777be cashier are subject to anti-money laundering (AML) monitoring. Unusual transaction patterns may trigger an enhanced review process, during which additional verification information may be requested from the account holder.

9 KYC and Identity Verification Data

Identity documents and supporting KYC materials submitted to 9777be are processed solely for the purpose of verifying that you are who you claim to be, that you meet the 18+ age eligibility requirement, and that your payment methods are registered in your own name. KYC data is handled with the highest level of confidentiality.

Identity documents are reviewed by the 9777be compliance team and, where a third-party KYC platform is used, by that platform's authorised personnel under a data processing agreement. Documents are stored securely and are not shared with any party other than those described in Section 7 of this policy. KYC documents are retained for the period described in Section 11 (Data Retention) of this policy.

10 Cookies and Tracking Technologies

9777be uses cookies and similar technologies (including local storage, session storage, and pixel tags) to operate and improve the platform. The following categories of cookies are used:

Cookie Type	Purpose	Required?
Strictly Necessary	Maintain your login session, remember your basket/bet slip, and ensure the platform functions correctly	Yes — cannot be disabled
Functional	Remember your language preference, display settings, and responsible gaming reminder configurations	Optional
Analytics	Collect aggregated data on how players use the platform to guide product improvements; no individual player is identified in analytics reports	Optional
Security	Detect and prevent fraudulent login attempts, bot activity, and account takeover attacks	Yes — cannot be disabled

You can manage optional cookies through your browser settings. Disabling functional or analytics cookies will not prevent you from using the core betting and gaming features of 9777be, but may affect the personalisation of your experience. Strictly necessary and security cookies cannot be disabled as they are essential to the secure operation of the platform.

11 Data Retention

9777be retains personal data only for as long as is necessary to fulfil the purposes for which it was collected or to comply with applicable legal obligations. The following retention periods apply as a general guide:

• Account data: Retained for the duration of your active account and for a period of five years following account closure, to satisfy anti-money laundering record-keeping obligations
• KYC and identity documents: Retained for a minimum of five years from the date of verification, in compliance with AML and financial crime prevention requirements
• Transaction records: Retained for a minimum of five years from the date of each transaction for financial audit and AML compliance purposes
• Gaming activity records: Retained for a minimum of three years from the date of the gaming session
• Customer support communications: Retained for three years from the date of the last interaction
• Marketing consent records: Retained until consent is withdrawn, and for one year thereafter as evidence of prior consent status

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised or aggregated data may be retained indefinitely for statistical and analytical purposes.

12 Security Measures

9777be implements a multi-layered approach to data security designed to protect player personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• TLS/SSL encryption: All data transmitted between your device and the 9777be platform is encrypted using industry-standard TLS protocols
• Encryption at rest: Sensitive data categories — including identity documents, payment references, and account credentials — are encrypted in storage using strong cryptographic algorithms
• Access controls: Access to systems containing personal data is restricted to authorised personnel based on the principle of least privilege. Access rights are reviewed regularly and revoked upon role change or departure
• Multi-factor authentication: Administrative access to production systems requires multi-factor authentication
• Security monitoring: Platform infrastructure is monitored continuously for anomalous activity, intrusion attempts, and data exfiltration indicators
• Penetration testing: 9777be conducts periodic security assessments and penetration tests to identify and remediate vulnerabilities
• Incident response: 9777be maintains a documented data breach response procedure. In the event of a security incident affecting player data, affected players will be notified in accordance with applicable legal requirements

13 Your Data Rights

As a registered player on 9777be, you have the following rights in respect of your personal data. To exercise any of these rights, please contact the 9777be support team using the details in Section 17:

• Right of access: You may request a copy of the personal data 9777be holds about you. We will provide this information within a reasonable timeframe and at no charge for standard requests.
• Right to rectification: If any personal data held by 9777be about you is inaccurate or incomplete, you may request that it be corrected. Where correction requires updated documentation, you may be asked to submit supporting evidence.
• Right to erasure: You may request deletion of your personal data. Note that this right is subject to 9777be's legal obligations — data that must be retained for AML compliance, fraud prevention, or legal proceedings cannot be deleted prior to the expiry of the applicable retention period.
• Right to restriction: You may request that 9777be restrict the processing of your data in certain circumstances, for example where you contest the accuracy of the data or where processing is unlawful but you prefer restriction over deletion.
• Right to data portability: Where processing is based on your consent or on contract performance and is carried out by automated means, you may request that your data be provided to you in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (such as for marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.
• Right to object: You may object to processing carried out on the basis of legitimate interests. 9777be will cease such processing unless compelling legitimate grounds can be demonstrated that override your interests, rights, and freedoms.

9777be aims to acknowledge all data rights requests within 5 business days and to fulfil requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days, and you will be informed of the extension and its reason.

14 Minors and Child Protection

9777be is strictly an adult platform. The platform is not directed at, and does not knowingly collect personal data from, individuals under the age of 18. If 9777be discovers that personal data has been collected from a minor — whether through misrepresentation of age during registration or any other means — that data will be deleted promptly, the associated account will be permanently closed, and any deposits made by the minor will be returned to the source payment method net of any winnings, which shall be forfeited.

Parents and guardians who have reason to believe that a minor has registered an account on 9777be should contact the support team immediately. 9777be will investigate and act on all such reports as a matter of priority. 9777be strongly recommends the use of parental control software by households where minors have access to internet-connected devices.

15 International Data Transfers

In the course of operating the 9777be platform and engaging third-party service providers, your personal data may be transferred to and processed in countries outside Bangladesh. Where such transfers occur, 9777be takes steps to ensure that your data receives an equivalent level of protection to that described in this Privacy Policy. These steps may include entering into standard contractual clauses with recipient parties or ensuring that recipients are subject to binding corporate rules or equivalent data protection frameworks.

By registering an account on 9777be and using the platform, you acknowledge that your personal data may be transferred internationally for the purposes described in this Privacy Policy, subject to the safeguards described above.

16 Changes to This Privacy Policy

9777be reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. When material changes are made to this policy, 9777be will notify registered players by email to their registered address, by an in-platform notification, or by publishing a prominent notice on the 9777be website. The date of the most recent revision is displayed at the top of this document.

Your continued use of the 9777be platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised policy. If you do not agree with any changes to this Privacy Policy, you should cease using the platform and may request account closure by contacting customer support. We encourage you to review this Privacy Policy periodically to stay informed about how your data is being protected.

17 Contact Us

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to report a privacy concern, please contact the 9777be data support team using the details below. All privacy-related enquiries should include your registered username and a clear description of your request to enable the team to locate your account and process your enquiry efficiently.

When submitting a data rights request, please specify clearly which right you wish to exercise (access, rectification, erasure, restriction, portability, objection, or consent withdrawal) and provide sufficient information for 9777be to verify your identity before acting on the request. Identity verification for data rights requests is conducted to protect against fraudulent requests made by third parties seeking to access another person's data.