Privacy Policy — 9777pp

1. Introduction & Scope

9777pp ("we", "us", "our") is committed to protecting the privacy and personal data of all players, visitors, and prospective users of the 9777pp platform (available at https://9777pp.ws, the "Platform"). This Privacy Policy explains what personal data we collect, why we collect it, how we use and store it, with whom we share it, and what rights you hold over it.

This Policy applies to all personal data collected through:

• Registration and account creation on the Platform;
• Deposits, withdrawals, and payment processing via bKash, Nagad, Rocket, Upay, Visa, or Mastercard;
• Identity verification (KYC) submissions;
• Use of any game, betting market, or feature on the Platform;
• Communications with our customer support team;
• Browsing the Platform, including data collected automatically via cookies and analytics tools.

By registering on or using the Platform you acknowledge that you have read this Privacy Policy and consent to the processing of your personal data as described herein. If you do not consent, you must not register for or use the Platform. This Policy should be read in conjunction with our Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

We collect the following categories of personal data:

2.1 Registration Data

• Full legal name;
• Date of birth (to verify you are 21 or older);
• Bangladesh mobile phone number;
• Email address;
• Username and encrypted password;
• City and district of residence (e.g., Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, Mymensingh).

2.2 Identity Verification (KYC) Data

• National ID card (NID) number and scanned copy;
• Passport number and scanned copy (where NID is unavailable);
• Selfie or facial photograph submitted for liveness verification;
• Proof of address documentation where required.

2.3 Financial & Transaction Data

• bKash, Nagad, Rocket, or Upay mobile wallet account numbers used for deposits and withdrawals;
• Visa or Mastercard card details (card number, expiry — we do not store full CVV numbers);
• Transaction amounts, timestamps, and reference numbers;
• Deposit and withdrawal history associated with your account.

2.4 Technical & Usage Data

• IP address and approximate geographic location at the time of login;
• Device type, operating system, and browser version;
• Session timestamps and duration;
• Pages visited, games played, bets placed, and betting patterns on the Platform;
• Cookie identifiers and first-party analytics data.

2.5 Communications Data

• The content of messages sent to our support team via email or live chat;
• Complaint and dispute records;
• Records of promotional offers accepted or declined.

3. How We Use Your Personal Data

9777pp uses your personal data for the following lawful purposes:

Purpose	Legal Basis
Creating and managing your player account	Contractual necessity
Processing deposits and withdrawals	Contractual necessity
Verifying your age and identity (KYC)	Legal obligation
Detecting and preventing fraud, money laundering, and abuse	Legal obligation / Legitimate interest
Providing responsible gaming tools and monitoring	Legal obligation / Legitimate interest
Responding to support queries and resolving disputes	Contractual necessity / Legitimate interest
Sending transactional notifications (deposit confirmed, withdrawal processed)	Contractual necessity
Sending promotional communications (bonuses, offers)	Consent (you may opt out at any time)
Improving Platform performance via analytics	Legitimate interest

4. Cookies & Tracking Technologies

9777pp uses the following types of cookies on the Platform:

• Strictly necessary cookies: These are required for the Platform to function. They maintain your login session, remember your preferences, and keep your shopping cart intact. You cannot opt out of these cookies while using the Platform.
• Performance & analytics cookies: First-party cookies that help us understand how players use the Platform — which game categories are most visited, where users drop off, and how load times can be improved. No personally identifiable information is shared with third-party analytics providers.
• Functional cookies: These remember your language preference, last-visited game category, and display settings to give you a more personalised experience on return visits.

9777pp does not use advertising cookies, retargeting pixels, or cross-site tracking scripts. You can delete or block cookies at any time through your browser settings; however, disabling strictly necessary cookies will impair the functionality of the Platform, including the ability to stay logged in.

5. Data Sharing & Third-Party Disclosure

9777pp does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:

• Payment processors: Transaction data is shared with bKash, Nagad, Rocket, Upay, Visa, and Mastercard solely to process your deposit or withdrawal. These providers operate under their own privacy policies and data-protection obligations.
• Game providers: When you play a game hosted by a third-party provider (Evolution Gaming, Pragmatic Play, Spribe, NetEnt, Microgaming, Ezugi), your player ID and session data are transmitted to that provider to load and operate the game. No additional personal data beyond a pseudonymous player identifier is shared.
• Identity verification services: KYC documents may be processed by a third-party identity verification provider to automate and securely verify your NID or passport. These providers are contractually bound to treat your documents as confidential and to use them only for verification purposes.
• Legal & regulatory authorities: Where required by applicable law, court order, or regulatory instruction, 9777pp may disclose personal data to relevant authorities. We will notify you of any such disclosure to the extent permitted by law.
• Fraud prevention: We may share limited data with fraud-prevention services and industry anti-fraud networks to detect multi-accounting, bonus abuse, and money laundering patterns across the industry.

All third parties with whom we share personal data are required to handle it securely and in accordance with applicable data-protection laws. 9777pp does not permit third parties to use your data for their own marketing or commercial purposes.

6. Data Retention

9777pp retains your personal data for as long as your account is active and for a defined period thereafter, as follows:

• Active account data: Retained for the full duration your account remains open plus a minimum of 5 years after account closure, to meet anti-money-laundering record-keeping requirements;
• KYC documents (NID, passport): Retained for a minimum of 5 years from the date of verification or account closure, whichever is later;
• Transaction records: Retained for a minimum of 5 years from the date of the transaction;
• Support communications: Retained for 3 years from the date of the communication;
• Cookie and analytics data: Retained for a maximum of 13 months from the date of collection, after which it is automatically deleted or anonymised.

Once the applicable retention period expires, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to an individual. We do not retain data beyond the periods described above unless we are subject to a specific legal obligation requiring longer retention.

7. Your Data Rights

As a registered player on 9777pp, you have the following rights in relation to your personal data:

• Right of access: You may request a copy of all personal data we hold about you. We will provide this within 30 days of receiving a valid request.
• Right of rectification: If any personal data we hold is inaccurate or incomplete, you have the right to have it corrected. You can update most information directly in your account dashboard; for KYC data, contact support.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected — subject to our legal retention obligations described in Section 6.
• Right to restrict processing: In certain circumstances, you may ask us to suspend the processing of your personal data while a query or correction request is resolved.
• Right to data portability: You may request your personal data in a structured, machine-readable format where processing is carried out by automated means on the basis of your consent or a contract.
• Right to withdraw consent: Where processing is based on your consent (such as receiving promotional emails), you may withdraw that consent at any time by updating your notification preferences in your account settings or by contacting [email protected].
• Right to object: You may object to processing carried out on the basis of legitimate interest, including direct marketing and profiling related to responsible gaming monitoring.

To exercise any of the above rights, please contact our Data Support team at [email protected] with the subject line "Data Rights Request" and include your registered username and a description of your request. We will acknowledge all requests within 5 business days and complete them within 30 days.

8. Data Security Measures

9777pp implements a layered security architecture to protect your personal data against unauthorised access, alteration, disclosure, or destruction:

• Transport security: All data in transit is encrypted using TLS 1.2 or higher (256-bit encryption). The Platform enforces HTTPS on every page and will not load over an unencrypted HTTP connection;
• Storage security: Data at rest is encrypted using AES-256. Database servers are not publicly accessible and operate behind multiple firewall layers;
• Access controls: Staff access to personal data is restricted to those with a specific operational need. Access is logged and reviewed regularly. All staff with access to sensitive data undergo background checks and sign confidentiality agreements;
• Password security: Player passwords are stored as salted cryptographic hashes — we cannot recover your plain-text password and will never ask you to share it;
• Incident response: In the event of a data breach that is likely to affect your rights and freedoms, 9777pp will notify affected players within 72 hours of becoming aware of the breach and will take immediate remedial action.

Despite these measures, no internet-based platform can guarantee absolute security. You also have a responsibility to protect your own account credentials — use a strong, unique password and never share your login details with anyone.

9. Minors & Age Restriction

The 9777pp Platform is strictly for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If you believe that a person under 21 has registered an account or submitted personal data to 9777pp, please contact us immediately at [email protected]. Upon verification, we will delete the account and all associated personal data without delay.

Age verification is a mandatory step in the KYC process for all players who request a withdrawal or reach the transaction thresholds defined in our anti-money-laundering procedures. Players who cannot satisfactorily verify their age will have their account suspended and any balance held pending resolution.

10. International Data Transfers

Some of our third-party service providers — including game providers such as Evolution Gaming, Pragmatic Play, Spribe, NetEnt, Microgaming, and Ezugi — may process data in jurisdictions outside Bangladesh. Where such transfers occur, 9777pp ensures that appropriate safeguards are in place, including contractual data-processing agreements that require the recipient to protect your data to a standard equivalent to this Privacy Policy.

9777pp does not transfer KYC documents or financial transaction data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual safeguards.

11. Changes to This Privacy Policy

9777pp reserves the right to update this Privacy Policy at any time to reflect changes in our data-processing practices, legal obligations, or Platform features. When material changes are made, the "Last updated" date at the top of this page will be revised. Where changes significantly affect how we process your personal data, we will notify you via your registered email address or a prominent notice on the Platform.

Continued use of the Platform after a Privacy Policy update constitutes acceptance of the revised policy. We encourage you to review this page periodically so you are always aware of how your data is being handled.

12. Contact & Data Queries

For any questions, concerns, or requests relating to this Privacy Policy or the personal data 9777pp holds about you, please contact our support team:

• Email: [email protected] — subject line: "Privacy Query" or "Data Rights Request"
• Support hours: 24 hours a day, 7 days a week (Bangladesh Standard Time, UTC+6)
• Response time: Acknowledgement within 5 business hours; full resolution within 30 days for data-rights requests

Please include your registered username, the nature of your query, and any relevant account or transaction references to help us assist you efficiently.