Privacy Policy — ad77

Data Controller

ad77 operates as the data controller in respect of the personal information collected through its online casino and sports betting platform accessible at ad77.io. As data controller, ad77 determines the purposes and means by which your personal data is processed, and is responsible for ensuring that such processing is carried out in accordance with applicable data protection principles.

All queries, requests, and concerns relating to the processing of your personal data should be directed to the ad77 data protection contact (see Section 14 below). ad77 takes its obligations as a data controller seriously and has implemented appropriate technical and organisational measures to safeguard your information at all times.

What We Collect

ad77 collects a range of personal data categories in order to operate its platform, verify player identities, process transactions, and comply with applicable legal obligations. The categories of personal data we may collect include, but are not limited to, the following:

ad77 does not collect or process special categories of sensitive personal data (such as health data, biometric data, political opinions, or religious beliefs) unless legally required for responsible gaming or regulatory purposes, in which case your explicit consent will be obtained separately.

How We Collect Data

ad77 collects personal data through the following channels and mechanisms:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated Collection: Data collected automatically as you navigate and interact with the ad77 platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 9 for full details).
• Third-Party Sources: Data received from payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard), identity verification providers, fraud prevention services, and analytics partners — solely to the extent necessary to deliver and secure the platform.
• Public Sources: In limited circumstances, ad77 may verify information against publicly available records for the purposes of fraud detection or regulatory compliance.

How We Use Your Data

ad77 uses the personal data it collects for the following specific and legitimate purposes. We will not use your data for any purpose that is incompatible with those listed below without first notifying you and, where required, obtaining your consent.

• Account Creation and Management: To register your player account, maintain your profile, authenticate your identity on login, and manage your account settings and preferences.
• Identity and Age Verification: To verify that you are at least 21 years of age and that the information you have provided is accurate and genuine, in compliance with responsible gaming obligations.
• Payment Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and other supported payment channels. All financial data is handled via encrypted, PCI-compliant systems.
• Platform Delivery: To provide access to casino games (slots, live dealer, table games), sports betting markets (cricket BPL, T20 World Cup, IPL, football, kabaddi), and all other platform features.
• Customer Support: To respond to your queries, resolve disputes, process complaints, and provide ongoing support in English and Bengali, 24 hours a day, 7 days a week.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, multi-accounting, and any other conduct that violates our Terms & Conditions or applicable law.
• Responsible Gaming: To monitor gameplay patterns for indicators of problem gambling, enforce self-exclusion and deposit limit settings, and proactively reach out to players who may be exhibiting signs of gambling-related harm.
• Legal and Regulatory Compliance: To meet our obligations under applicable law, respond to lawful requests from authorities, and retain records as required by data retention laws.
• Platform Improvement: To analyse aggregated, anonymised usage data for the purpose of improving platform performance, expanding game selection, and enhancing the overall player experience.
• Marketing Communications: To send you relevant promotional offers, bonus notifications, and platform updates — but only where you have provided consent to receive such communications. You may withdraw consent at any time through your account settings or by contacting support.

Legal Basis for Processing

ad77 processes your personal data on one or more of the following legal bases, depending on the specific processing activity involved:

• Contractual Necessity: Processing that is necessary for the performance of the player account contract between you and ad77 — including account registration, payment processing, game delivery, and customer support.
• Legal Obligation: Processing that is necessary for ad77 to comply with applicable legal requirements — including identity verification (KYC), anti-money laundering (AML) checks, age verification, and data retention obligations.
• Legitimate Interests: Processing carried out in pursuit of ad77's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — principally in the context of marketing communications and non-essential cookies. You have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Sharing Your Data

ad77 does not sell, rent, or trade your personal data to third parties. We may, however, share your data with the following categories of trusted service partners and in the following circumstances, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and their associated network operators — to facilitate the processing of deposits and withdrawals from your account.
• Identity Verification Providers: Third-party KYC and AML service providers engaged to verify player identity, confirm age eligibility (21+), and screen against sanctions and politically exposed person (PEP) lists.
• Game Providers: Software providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and Habanero receive limited technical data (session tokens, game results) necessary to deliver their games on the ad77 platform. These providers do not receive your full identity or financial data.
• Analytics and Platform Infrastructure Providers: Cloud hosting, content delivery, and analytics services engaged to maintain and improve ad77's technical infrastructure. All such providers operate under strict data processing agreements.
• Legal and Regulatory Authorities: ad77 will disclose personal data to law enforcement, regulatory bodies, or courts where required by law, a court order, or a lawful regulatory demand — and only to the minimum extent required to satisfy the legal obligation.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained. You will be notified of any such transfer in advance.

In all cases of third-party data sharing, ad77 ensures that appropriate contractual safeguards are in place to protect the confidentiality and security of your personal data.

Data Retention

ad77 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active Accounts: Personal data associated with an active player account is retained for the duration of the account relationship and for a period of five (5) years following account closure, in compliance with applicable anti-money laundering and financial record-keeping obligations.
• KYC and Verification Documents: Identity and age verification documents are retained for a minimum of five (5) years following the end of the account relationship, or longer if required by applicable law.
• Transaction Records: Deposit and withdrawal records, including payment method references, are retained for a minimum of five (5) years from the date of the transaction.
• Support Communications: Customer support interactions are retained for a period of two (2) years from the date of the interaction, or longer if connected to an open dispute or legal matter.
• Marketing Consent Records: Records of your marketing communication preferences and consent history are retained for as long as your account is active plus one (1) year following account closure.
• Technical and Log Data: Automated log data and session data is typically retained for ninety (90) days for security and fraud investigation purposes, after which it is deleted or anonymised.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data is anonymised rather than deleted, it may be retained indefinitely for aggregated analytical purposes as it no longer constitutes personal data.

Data Security

ad77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security framework includes the following:

• Encryption in Transit: All data transmitted between your device and the ad77 platform is protected by 256-bit SSL/TLS encryption. You can verify secure connection status via the padlock icon in your browser's address bar.
• Encryption at Rest: Sensitive personal data stored on ad77's infrastructure — including financial data and identity documents — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within ad77's internal systems is strictly limited to personnel who require it in the performance of their role. Role-based access controls and the principle of least privilege are enforced across all internal systems.
• Two-Factor Authentication (2FA): 2FA is available to all players at the account level and is enforced for all ad77 internal administrative accounts.
• Regular Security Audits: ad77's platform infrastructure undergoes periodic security reviews and penetration testing to identify and remediate vulnerabilities.
• Incident Response: ad77 maintains a documented data breach response procedure. In the event of a data breach that poses a risk to your rights and freedoms, affected players will be notified promptly in accordance with applicable requirements.

Cookies & Tracking Technologies

ad77 uses cookies and similar tracking technologies to enable the platform to function correctly, to remember your preferences, and to analyse platform performance. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the ad77 platform to operate. They enable core functions such as session management, login authentication, and security checks. These cookies cannot be disabled without disrupting the platform's fundamental operation.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred language and responsible gaming configuration — so that you do not need to re-enter them on every visit. They do not track activity across other websites.
• Performance and Analytics Cookies: These cookies collect aggregated, anonymised data about how players use the ad77 platform — which pages are visited most frequently, where users encounter errors, and how long sessions last. This information is used solely to improve the platform.
• Marketing Cookies: Where you have given consent, these cookies may be used to deliver promotional content relevant to your interests. You may withdraw consent to marketing cookies at any time.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies; however, disabling strictly necessary cookies will impair your ability to use the ad77 platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

In addition to cookies, ad77 may use web beacons (also known as pixel tags or clear GIFs) in emails and on the platform to track whether messages have been opened and to assess the effectiveness of communications. These technologies collect only aggregated, non-personally identifiable data.

Your Rights

As a player whose personal data is processed by ad77, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact ad77 support using the details provided in Section 14.

• Right of Access: You have the right to request a copy of the personal data that ad77 holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request that inaccurate or incomplete personal data be corrected or completed without undue delay.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right does not apply where ad77 is required to retain your data to comply with a legal obligation (e.g., AML record-keeping requirements).
• Right to Restriction of Processing: You have the right to request that ad77 restrict the processing of your personal data in specified circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on your consent or on a contract and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of ad77's legitimate interests. If you object, ad77 must stop processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• 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 before the withdrawal.

ad77 will respond to all verified data rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 60 days, in which case you will be informed of the extension and the reasons for it. All requests must be submitted in writing and will require identity verification to ensure the request is made by the account holder.

Protection of Minors

The ad77 platform is strictly intended for adults aged 21 and above. ad77 does not knowingly collect, process, or retain personal data from any individual under the age of 21. Age verification is a mandatory component of the account registration and KYC process, and accounts found to belong to underage users will be immediately closed and all associated data deleted to the extent permitted by applicable legal obligations.

If you believe that an individual under the age of 21 has registered an account or is accessing the ad77 platform, please contact us immediately at [email protected] (plain text — not a link). We will investigate and act without delay on any credible report of underage access.

We strongly recommend that parents and guardians use parental control tools and internet filtering software to prevent minors from accessing online gambling platforms. Resources for parental control software are widely available and can be found through internet safety organisations.

Third-Party Services

The ad77 platform integrates with third-party services to deliver the full range of its features — including payment processing, game delivery, identity verification, and platform analytics. While ad77 takes care to engage only reputable and security-conscious third-party partners, please be aware of the following:

• Third-party payment providers — including bKash, Nagad, Rocket, Upay, Visa, and Mastercard — operate under their own independent privacy policies. ad77 is not responsible for the data practices of these providers in respect of data they independently collect through their own platforms and applications.
• Game providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and Habanero — may receive limited technical data to facilitate game delivery. These providers are bound by contractual data protection obligations.
• The ad77 platform does not contain links to third-party websites outside of the ad77 ecosystem. This Privacy Policy applies solely to data processed by ad77 in connection with the ad77 platform.

All third parties with whom ad77 shares personal data are subject to written data processing agreements that require them to implement appropriate security measures and to process personal data only in accordance with ad77's instructions and applicable data protection law.

Changes to This Policy

ad77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, platform functionality, or data processing practices. When material changes are made to this policy, ad77 will notify registered players via the email address associated with their account and will publish the revised Privacy Policy on the platform with an updated effective date.

Your continued use of the ad77 platform following the publication of an updated Privacy Policy constitutes your acknowledgement of and agreement to the revised policy. If you do not agree with the changes, you should stop using the platform and close your account in accordance with our Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how ad77 handles your personal data. The version currently displayed on the platform is the version in force.

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way ad77 processes your personal data, please get in touch using the contact details below. Note that all email addresses are displayed as plain text and are not clickable links.

• Data Protection Enquiries (Email): [email protected] (plain text only — not a link)
• Subject Line for Data Rights Requests: "Data Rights Request"
• Subject Line for Privacy Policy Enquiries: "Privacy Policy Enquiry"
• Live Chat: Available directly on the ad77 platform, 24 hours a day, 7 days a week, in English and Bengali. Average response under 2 minutes.
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6)

ad77 is committed to resolving all privacy-related enquiries promptly and transparently. We will acknowledge all privacy enquiries within two (2) business days and provide a full response within thirty (30) days of receipt.