Privacy Policy — 77jaya

This Privacy Policy applies to the 77jaya online gaming and sports betting platform, accessible at https://77jaya.bio, and to all associated pages, mobile-optimised interfaces, and services provided under the 77jaya brand (collectively, the "Platform"). This Policy governs how 77jaya collects, processes, stores, uses, and protects the personal data of all individuals who access or use the Platform, including registered players, prospective players who browse the Platform without registering, and individuals who contact our support team.

77jaya is committed to handling personal data with transparency, integrity, and respect for individual privacy. We recognise that players in Bangladesh and beyond entrust us with sensitive personal and financial information when they use our services, and we take that responsibility seriously. This Policy is written in plain, accessible English so that you can clearly understand your rights and our obligations.

This Privacy Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference. Together, these documents form the complete Agreement between you and 77jaya.

For the purposes of this Privacy Policy, 77jaya is the data controller responsible for the personal data collected through the Platform. As data controller, 77jaya determines the purposes and means by which your personal data is processed.

If you have any questions about how your personal data is handled, or if you wish to exercise any of the rights described in this Policy, you may contact the 77jaya Data Protection team through any of the support channels listed in Section 15 of this Policy. We aim to respond to all data-related enquiries within five business days.

77jaya collects the following categories of personal data from players and Platform users:

We do not collect special categories of sensitive personal data (such as health data, biometric data, or racial/ethnic origin data) unless you voluntarily disclose such information during a responsible gaming self-exclusion process or a support interaction. In such cases, the data is used solely for the purpose for which it was disclosed and is handled with heightened care.

77jaya collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically as you interact with the Platform, including through cookies, server logs, and similar tracking technologies. See Section 8 for more detail on cookies.
• Third-party sources: Identity and address verification data obtained from KYC verification service providers and fraud-screening partners in order to confirm the accuracy of the information you provide to us. We may also receive limited data from payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard) to confirm transaction status.

We do not purchase third-party marketing lists or obtain personal data from social media platforms without your explicit consent.

77jaya uses your personal data for the following purposes:

• Account management: Creating, maintaining, verifying, and administering your 77jaya account, including enforcing the one-account policy and handling account closure requests.
• Service delivery: Processing your deposits and withdrawals, settling wagers, crediting bonuses, and providing access to the games and betting markets available on the Platform.
• Identity and age verification (KYC): Confirming your identity, age, and eligibility to use the Platform in compliance with our anti-money-laundering obligations and minimum age requirements.
• Fraud prevention and security: Detecting and investigating suspicious activity, identifying multi-account abuse, and protecting the integrity of the Platform and its player community.
• Customer support: Responding to your enquiries, resolving disputes, and improving the quality of our support services based on interaction history.
• Responsible gaming: Monitoring betting patterns that may indicate problem gambling behaviour and proactively engaging with players who may benefit from responsible gaming tools or support.
• Legal compliance: Meeting our obligations under applicable anti-money-laundering, counter-terrorism financing, and data protection laws.
• Platform improvement: Analysing aggregated, anonymised usage data to understand how the Platform is used and to improve its design, features, and performance.
• Marketing communications: Sending you promotional offers, bonus notifications, and seasonal campaign messages where you have not opted out of such communications. You may opt out at any time by contacting our support team.

77jaya processes your personal data on the following legal grounds:

• Contractual necessity: Processing that is necessary to perform the contract between you and 77jaya (i.e., to provide the gaming and betting services you have registered to use), including account management, payment processing, and game settlement.
• Legal obligation: Processing required to comply with applicable laws and regulations, including KYC identity verification, anti-money-laundering checks, and the retention of financial transaction records.
• Legitimate interests: Processing carried out for 77jaya's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving the Platform's services — provided such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, informed consent, including the sending of marketing communications and the use of non-essential cookies. You may withdraw consent at any time by contacting our support team or adjusting your cookie preferences, and withdrawal of consent will not affect the lawfulness of processing carried out prior to withdrawal.

77jaya does not sell your personal data to third parties. We may share your 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 processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — solely to process your deposit and withdrawal transactions.
• KYC and identity verification providers: Third-party verification services used to confirm your identity and age in compliance with our anti-money-laundering obligations.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive limited technical session data (but not personally identifiable financial data) to facilitate game delivery and RNG certification.
• Fraud detection and security partners: Technology providers that assist 77jaya in identifying and preventing fraudulent activity, multi-account abuse, and bonus exploitation.
• Legal and regulatory authorities: Where required by applicable law, court order, or regulatory obligation, 77jaya may disclose personal data to law enforcement agencies, financial intelligence units, or other competent authorities.
• Professional advisers: Lawyers, auditors, and other professional advisers bound by confidentiality obligations, where disclosure is necessary for the purposes of obtaining professional advice.

All third-party service providers engaged by 77jaya are contractually required to process personal data only in accordance with 77jaya's instructions and this Privacy Policy, and to implement appropriate technical and organisational security measures.

77jaya uses cookies and similar technologies (including local storage and session tokens) to operate the Platform effectively and enhance your experience. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cookies maintain your login session, prevent cross-site request forgery, and ensure secure data transmission. They cannot be disabled without impairing your ability to use the Platform.
• Functional cookies: Used to remember your preferences, such as language settings and display preferences, so that you do not need to re-enter them on each visit.
• Performance and analytics cookies: Used to collect anonymised data about how players navigate and interact with the Platform, enabling 77jaya to identify and fix technical issues and optimise the user experience. No personally identifiable information is included in analytics data.

77jaya does not use third-party advertising or retargeting cookies. We do not participate in cross-site tracking networks or ad exchange programmes.

You may control or disable non-essential cookies through your browser settings. Note that disabling functional cookies may affect the performance of certain Platform features. Strictly necessary cookies cannot be disabled as they are integral to Platform security and operation.

77jaya retains your personal data for the following periods:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised aggregate data may be retained indefinitely for statistical and business intelligence purposes, as it can no longer be associated with any identifiable individual.

77jaya implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security infrastructure includes:

• 256-bit SSL/TLS encryption on all data transmissions between your device and 77jaya's servers, ensuring that data in transit cannot be intercepted or read by unauthorised parties.
• Encryption at rest for all sensitive personal and financial data stored in our databases, including payment method details and KYC documents.
• Role-based access control (RBAC) ensuring that 77jaya personnel can only access personal data that is directly relevant to their job function. Access logs are maintained and reviewed regularly.
• Multi-factor authentication (MFA) for all 77jaya administrative systems and internal tools that have access to player data.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists to identify and remediate potential weaknesses in the Platform's infrastructure.
• Intrusion detection systems (IDS) that monitor Platform traffic in real time and automatically flag anomalous activity for immediate investigation.
• Secure data centre facilities with physical access controls, environmental monitoring, and redundant backup systems.

Despite these measures, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, 77jaya will notify affected players without undue delay and take all reasonable steps to contain and remediate the breach.

Subject to applicable law, you have the following rights in relation to your personal data held by 77jaya:

• Right of access: You may request a copy of the personal data we hold about you. We will provide this within a reasonable timeframe at no charge for the first request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or update it. You can update basic account information (such as contact details) directly from your account settings panel.
• 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, where you have withdrawn consent, or where processing is unlawful. Note that erasure requests may be limited where retention is required by law (e.g., AML record-keeping obligations).
• Right to restriction of processing: You may request that we restrict the processing of your personal data in certain circumstances, such as where you contest its accuracy or object to its processing, pending our verification or review.
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON) so that you can transfer it to another service provider.
• Right to object: You may object to the processing of your personal data where we rely on legitimate interests as our legal basis. You have an absolute right to object to the use of your data for direct marketing purposes, including profiling for marketing.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact the 77jaya support team via 24/7 live chat or at the email address listed in Section 15. We will acknowledge your request within 48 hours and aim to resolve it within 30 days. In complex cases, this period may be extended by a further 30 days, in which case we will inform you of the extension and the reason.

We may need to verify your identity before processing certain requests, in order to protect against fraudulent access to another player's data.

The 77jaya Platform is strictly for individuals aged 18 years or older. We do not knowingly collect personal data from persons under the age of 18. If you are under 18, you must not register an account, deposit funds, or participate in any gaming activity on the Platform.

Where 77jaya discovers or has reasonable grounds to suspect that a registered account belongs to a person under the age of 18, the account will be immediately suspended pending age verification. If underage use is confirmed, the account will be permanently closed, all funds will be returned to the deposit source after deducting any bonuses, and the incident may be reported to the relevant authorities.

If you believe that a minor has registered an account on 77jaya using false information, please contact us immediately via live chat so that we can investigate and take appropriate action.

The 77jaya Platform does not contain links to third-party websites for advertising or affiliate purposes. Any references to third-party services within this Privacy Policy (such as payment processors or game studios) are provided solely for informational purposes and do not constitute an endorsement of those services or their privacy practices.

77jaya accepts no responsibility for the privacy practices of any third-party service providers. When interacting directly with a payment processor (such as when using the bKash or Nagad app to initiate a deposit), you are subject to that provider's own privacy policy and terms of service.

77jaya reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When material changes are made, we will notify registered players by posting a prominent notice on the Platform homepage and, where appropriate, by sending a notification to the email address associated with your account.

The "Last Updated" date displayed in the hero section at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed of how 77jaya protects your data.

Your continued use of the Platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy. If you disagree with the revised Policy, please discontinue use of the Platform and contact us to request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 77jaya handles your personal data, please contact our Data Protection team through any of the following channels:

• 24/7 Live Chat: Available on every page of the 77jaya Platform — the fastest channel for urgent data or security matters.
• Email: [email protected] (plain text — not a clickable link). Include "Privacy Request" in your subject line for faster routing to the Data Protection team.
• WhatsApp: +880 1700-000000, available 08:00–24:00 BST.

We aim to acknowledge all privacy-related enquiries within 48 hours and to provide a full response within 30 days. For requests relating to data deletion, access, or portability, identity verification may be required before we can action the request.