77jaya Privacy Policy

This Privacy Policy ("Policy") describes how 77jaya ("we", "us", "our") collects, processes, stores, and shares personal information about you when you visit, register with, or use the 77jaya Platform at https://77jaya.bar and any associated mobile-optimised interfaces (collectively, the "Platform").

By creating a 77jaya account or by continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform immediately and request account closure.

This Policy forms part of the broader legal framework governing your use of the 77jaya Platform and should be read alongside our Terms and Conditions and Responsible Gaming Policy.

Privacy at a Glance

1 Personal Data We Collect

When you interact with the 77jaya Platform, we may collect the following categories of personal information:

• Full legal name as it appears on your government-issued identity document.
• Date of birth — used to verify that you are 21 years of age or older.
• Email address — used for account communications, security alerts, and promotional messages (where opted in).
• Mobile phone number — used for OTP-based two-factor authentication and account recovery.
• Residential address — used for identity verification and regulatory compliance purposes.
• National ID Card (NID) number or passport number — collected only during enhanced KYC verification and stored securely.

• bKash / Nagad / Rocket / Upay mobile wallet numbers associated with your deposit and withdrawal transactions.
• Bank account details (account number, bank name, branch) where bank transfer is the chosen payment method.
• Transaction history — a full record of all deposits, withdrawals, bonus credits, and adjustments to your account balance.
• We do not store full card numbers, CVV codes, or banking PINs at any point in our systems.

• IP address — collected at login and during gameplay for fraud detection and geolocation compliance.
• Device identifiers — operating system, browser type, device model, and screen resolution.
• Session logs — pages visited, time on page, click paths, and game session start and end times.
• Cookies and local storage — for session management, preference retention, and analytics (see Section 7).
• Gameplay records — bet history, game outcomes, wager amounts, and bonus wagering progress — stored indefinitely for dispute resolution and regulatory purposes.

2 How We Use Your Personal Data

77jaya processes your personal data only for legitimate, specified purposes. The table below summarises our primary processing activities and the legal basis under which each is conducted:

We do not use automated decision-making or profiling in a way that produces legal or similarly significant effects on players, except for real-time fraud screening during transactions. Where automated screening flags an account, a human review is conducted before any restriction is applied.

3 Data Sharing & Third-Party Disclosure

77jaya does not sell or rent your personal data to any third party. We may, however, share specific categories of data with carefully selected partners where it is necessary to operate the Platform or comply with our legal obligations:

• Payment processors and mobile wallet providers (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank): transaction details are shared only to the extent required to process your deposit or withdrawal.
• Identity verification service providers: document images and biographic data may be shared with KYC/AML technology partners operating under strict data-processing agreements that prohibit onward sharing.
• Game content providers (Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, Microgaming, Spribe): your player ID, session token, and gameplay data are shared with the relevant provider during an active game session. These providers operate their own privacy policies.
• Fraud and security platforms: IP address, device fingerprint, and behavioural data may be shared with anti-fraud technology partners to protect the integrity of the Platform.
• Legal and regulatory authorities: we are required by law to disclose certain data to relevant authorities upon receipt of a valid legal request. We will notify you of such a request where we are legally permitted to do so.
• Analytics service providers: anonymised or pseudonymised usage data may be shared with analytics platforms to help us understand how players use the Platform and improve the experience.

All third-party data processors engaged by 77jaya are bound by contractual data-processing agreements that require them to process your data only for the purposes we specify, to maintain appropriate security standards, and to delete or return data upon termination of the agreement.

4 Data Retention

We retain 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 and identity data: retained for the lifetime of the account plus a minimum of 5 years after account closure, to satisfy AML record-keeping requirements.
• Transaction records: retained for a minimum of 5 years from the date of the transaction, or longer if required by a specific regulatory obligation or active investigation.
• Gameplay logs and session records: retained for a minimum of 3 years to support dispute resolution and audit processes.
• Support correspondence: retained for 2 years from the date of the last communication in a support thread.
• Marketing preferences and consent records: retained for the lifetime of the account plus 1 year following account closure.
• Technical logs (IP logs, device logs): retained for 12 months on a rolling basis, unless a security incident requires extended retention.

When data is no longer required and no legal obligation mandates its continued retention, it is securely deleted or irreversibly anonymised. Anonymised data (which can no longer identify any individual) may be retained indefinitely for aggregate analytics and platform improvement purposes.

5 Cookies & Tracking Technologies

The 77jaya Platform uses cookies and similar tracking technologies (local storage, session storage, pixel tags) to provide a functional, personalised, and secure experience. The following cookie categories are in use:

• Strictly necessary cookies: essential for the Platform to function. These include session authentication tokens, security tokens, and load-balancing cookies. These cannot be disabled without breaking core functionality.
• Functional cookies: remember your preferences such as language, currency display (৳ BDT), and game lobby filters. These persist across sessions to improve your experience.
• Analytics cookies: collect anonymised data about how pages are used, which games are most popular, and where players encounter friction. This data helps us improve the Platform. No personally identifiable information is included in analytics payloads.
• Security and fraud-detection cookies: used to identify unusual access patterns, detect bot activity, and protect your account from unauthorised login attempts.

We do not use third-party advertising or retargeting cookies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform.

6 Data Security Measures

77jaya takes the security of your personal data seriously. We maintain a layered security architecture designed to protect against unauthorised access, disclosure, alteration, and destruction of data:

• Transport security: all communications between your browser or device and our servers are encrypted using TLS 1.2 or higher (256-bit SSL).
• Data at rest: sensitive fields in our databases (including identity document references, payment method identifiers, and authentication credentials) are encrypted using AES-256.
• Password storage: account passwords are never stored in plain text. We use a salted cryptographic hash function. Our support staff cannot view your password.
• Two-factor authentication (2FA): OTP-based 2FA is supported and strongly recommended for all accounts. Suspicious login attempts trigger automatic 2FA challenges.
• Access controls: only authorised personnel with a documented business need are granted access to production systems containing player data. Access is logged and audited.
• Penetration testing: we conduct periodic security assessments and vulnerability scans to identify and remediate weaknesses in our infrastructure.
• Incident response: in the event of a confirmed data breach that is likely to result in risk to your rights, we will notify affected players without undue delay.

7 Your Data Rights

As a player on the 77jaya Platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and we will respond within 48 hours Bangladesh Standard Time (BST, UTC+6):

Please note that certain rights are subject to legal limitations. For example, we cannot delete transaction records that we are required to retain under AML regulations, nor can we delete gameplay records that are the subject of an unresolved dispute.

8 Minors & Age Protection

The 77jaya Platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21. If we become aware that personal data has been submitted by or on behalf of a minor, we will immediately close the relevant account and securely delete all associated data.

Parents and guardians are encouraged to use internet content filtering tools to prevent minors from accessing online gambling platforms. If you believe a minor has accessed or registered on the 77jaya Platform, please notify us immediately at [email protected].

9 Updates to This Policy

77jaya reserves the right to amend this Privacy Policy at any time. The effective date of the most recent version is displayed at the top of this document. Where changes are material — meaning they meaningfully affect how we collect, use, or share your personal data — we will notify registered players via the email address linked to their account at least 7 days before the changes take effect.

Your continued use of the Platform after the revised Policy's effective date constitutes your acceptance of the updated terms. If you do not agree with any material change, you should stop using the Platform and request account closure before the change takes effect.

We recommend reviewing this Policy periodically to stay informed about how 77jaya protects your information. All previous versions of this Policy are available upon written request to [email protected].