Your Privacy Matters
to 77up

Welcome to 77up. This Privacy Policy ("Policy") describes how 77up ("we", "us", "the Operator", "the Platform") collects, uses, stores, shares, and protects the personal information of individuals ("you", "the User", "the Player") who access or use the services available at https://77up.vu and any associated interfaces, subdomains, or mobile web experiences operated under the 77up brand.

This Policy is intended to be transparent and straightforward. We believe that you have a right to know precisely what information we hold about you, why we hold it, and what choices you have in relation to it. If any part of this Policy is unclear, we encourage you to contact our support team for clarification before providing any personal data.

This Privacy Policy forms part of the overall agreement between you and 77up and should be read in conjunction with our Terms & Conditions and our Responsible Gaming Policy. By creating an account or continuing to use the 77up platform, you confirm that you have read and agree to this Privacy Policy in its entirety.

This Policy applies specifically to personal data collected from registered and prospective players based in Bangladesh. The 77up platform serves players across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and all other regions of Bangladesh, and this Policy reflects the data practices applicable to all such users equally.

77up collects only the personal data that is necessary for the legitimate purposes described in Section 4 of this Policy. The categories of personal data we collect are set out in the table below:

We do not collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (beyond identity verification liveness checks where required), health data, or sexual orientation. We do not collect information about your social media accounts, browsing history outside the 77up platform, or any data from your device beyond what is generated through your direct interaction with our services.

77up collects personal data through the following channels:

• Direct provision: Data you enter yourself when registering an account, completing KYC verification, making a deposit or withdrawal request, using responsible gaming tools, or contacting our support team.
• Automated technical collection: Technical and usage data collected automatically when you access the platform, including your IP address, device identifiers, and session activity. This data is collected via server logs and first-party cookies (see Section 8).
• Payment provider data: When you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, the relevant payment provider confirms transaction status and the payment method identifier associated with the transaction. 77up does not receive full payment credentials — only the confirmation data necessary to credit or debit your 77up wallet.
• Identity verification services: Where 77up uses a third-party KYC verification partner to process identity documents, that partner may return a verification result and a risk score to 77up. Full document images are processed by the KYC partner and are subject to that partner's own privacy and data retention policies.
• Fraud and risk detection systems: Automated fraud detection tools may generate risk signals based on patterns in your account activity. These signals are used internally for account security purposes and do not involve the collection of any additional personal data beyond what is already listed in Section 2.

77up uses your personal data for the following purposes, each of which has a corresponding lawful basis:

• Account creation and management: To register your account, authenticate your identity at login, manage your account settings, and maintain your account lifecycle from registration to closure. Basis: Contract performance.
• Transaction processing: To process deposits and withdrawals in Bangladeshi Taka (৳) via your chosen payment method and to maintain accurate records of all financial activity on your account. Basis: Contract performance.
• Identity verification (KYC): To verify that you are who you say you are and that you meet the minimum age requirement of 21 years, and to comply with anti-money laundering (AML) obligations. Basis: Legal obligation and contract performance.
• Customer support: To respond to queries, resolve disputes, investigate complaints, and provide assistance via live chat and email. Basis: Contract performance and legitimate interest.
• Platform security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, multiple account creation, and other prohibited conduct as described in our Terms & Conditions. Basis: Legal obligation and legitimate interest.
• Responsible gaming compliance: To monitor account activity for signs of problem gambling, enforce deposit and loss limits you have set, process self-exclusion requests, and fulfil our duty of care obligations to players. Basis: Legal obligation and legitimate interest.
• Platform improvement: To analyse usage patterns, identify technical issues, improve the user experience, and develop new features. This analysis is performed on aggregated or pseudonymised data wherever possible. Basis: Legitimate interest.
• Promotional communications: To send you information about 77up bonuses, promotions, and new features via your registered contact details, but only where you have opted in to receive such communications. You may opt out at any time by contacting our support team. Basis: Consent.

77up will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a new lawful basis for the processing.

77up does not sell, rent, or trade your personal data to any third party. Your data may be shared with the following categories of recipient, and only to the extent strictly necessary for the purpose described:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, and Mastercard processing partners receive the minimum transaction data required to execute deposit and withdrawal instructions. These partners are contractually bound to handle your data securely and in accordance with applicable financial data protection standards.
• KYC and identity verification providers: Third-party identity verification services receive copies of the documents you submit during KYC verification. These providers are used solely for the purpose of verifying your identity and age and are contractually prohibited from using your data for any other purpose.
• Fraud detection and risk management providers: Specialist fraud detection platforms may process technical and behavioural data from your account activity to generate risk assessments. These providers act as data processors under our instruction and do not use your data independently.
• IT infrastructure and hosting providers: The technical infrastructure that supports the 77up platform is operated by contracted cloud hosting and technology partners. These providers have access to platform data only in the course of providing infrastructure services and are bound by strict data processing agreements.
• Legal and regulatory authorities: 77up will disclose personal data to law enforcement agencies, financial regulators, or other competent authorities if required to do so by applicable law, court order, or regulatory directive. 77up will notify you of such disclosures where legally permitted to do so.
• Professional advisers: Legal counsel, auditors, and compliance consultants may access personal data on a strictly need-to-know basis in the course of providing professional services to 77up. All such advisers are bound by professional confidentiality obligations.

In all cases of data sharing, 77up ensures that appropriate contractual safeguards are in place to protect your data and restrict its use to the stated purpose. We do not share data with advertising networks, data brokers, social media platforms, or marketing analytics services.

77up retains personal data only for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and financial record-keeping obligations. The following general retention periods apply:

• Active account data: Retained for the full duration of your account's active status on the 77up platform, plus a minimum of five (5) years following account closure. This retention period reflects standard financial services record-keeping requirements.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure in compliance with anti-money laundering record-keeping obligations.
• Transaction records: All deposit and withdrawal records are retained for a minimum of five (5) years following the date of the transaction, in line with standard financial record-keeping practice.
• Customer support communications: Live chat transcripts and email correspondence are retained for a period of two (2) years from the date of the interaction, or for the duration of any open dispute to which the communication relates, whichever is later.
• Technical and usage logs: Server logs containing IP addresses and session data are retained for a period of twelve (12) months from the date of collection and then deleted or anonymised.
• Self-exclusion records: Records of self-exclusion requests are retained for the full term of the exclusion plus five (5) years, to enable enforcement of re-registration restrictions.

When your data is no longer required for any of the purposes described above, it will be securely deleted or anonymised so that it can no longer be linked to you as an individual. We do not retain data in an identifiable form beyond the periods set out above except where required to do so by law.

77up employs a multi-layered approach to data security, combining technical controls, organisational measures, and staff training to protect your personal information against unauthorised access, loss, alteration, or disclosure.

Technical security measures in place at 77up include:

• 256-bit SSL/TLS encryption: All data in transit between your device and the 77up platform is encrypted using industry-standard 256-bit SSL/TLS protocols. This ensures that your login credentials, personal data, and financial information cannot be intercepted in transit.
• Encrypted data storage: Sensitive data stored in our databases — including identity documents, financial records, and KYC verification results — is stored in encrypted form. Encryption keys are managed separately from the encrypted data.
• Password hashing: Your account password is stored as a one-way cryptographic hash using a modern hashing algorithm. This means that neither 77up staff nor any third party can recover your original password from the stored hash. If you forget your password, a reset process is used — we cannot retrieve your existing password.
• Access controls: Access to personal data within 77up's systems is strictly limited to personnel who require it to perform their job functions. Role-based access controls are enforced, and all internal data access is logged for audit purposes.
• Regular security assessments: 77up conducts periodic reviews of its data security practices and technical infrastructure to identify and address vulnerabilities.

While 77up takes all reasonable precautions to protect your personal data, no internet-based system can guarantee absolute security. You play an important role in keeping your account secure by choosing a strong password, not sharing your login credentials with anyone, and contacting us immediately if you suspect unauthorised access to your account.

77up uses cookies and similar tracking technologies on the platform to enable core functionality, remember your preferences, and analyse how the platform is used. A cookie is a small text file placed on your device by your web browser when you visit a website. 77up uses only the following categories of cookies:

• Strictly necessary cookies: These cookies are essential for the platform to function. They enable you to stay logged in during a session, maintain your account settings, and use core features such as the betting interface and cashier. These cookies cannot be disabled without breaking the platform's functionality.
• Functional cookies: These cookies remember your preferences, such as your preferred language or display settings, to provide a more personalised experience. They are set only in response to actions you take on the platform.
• Analytics cookies: 77up uses first-party analytics tools to collect anonymised data about how users interact with the platform — for example, which pages are visited most frequently and where users experience technical issues. This information is used solely to improve platform performance and is not shared with third-party advertising networks.

77up does not use third-party advertising cookies, behavioural targeting cookies, social media tracking pixels, or any tracking technology designed to build a profile of your activity across websites outside of the 77up platform.

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies. However, blocking strictly necessary cookies will prevent you from logging in and using account features. Instructions for managing cookies can be found in your browser's help documentation.

As a 77up account holder, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our support team at [email protected] or via live chat. We will respond to all requests within 30 days of receipt.

• Right of access: You have the right to request a copy of all personal data that 77up holds about you. We will provide this information in a structured, commonly used format within 30 days.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Please contact our support team with the details of the correction required and any supporting documentation.
• Right to erasure ("right to be forgotten"): You have the right to request the deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose for which it was collected, or where you withdraw consent and there is no other lawful basis for processing. Please note that this right is subject to our legal obligation to retain financial and KYC records for the periods described in Section 6.
• Right to restriction of processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where processing is unlawful but you do not wish for the data to be erased.
• Right to data portability: You have the right to receive the personal data you have provided to 77up in a structured, machine-readable format and to request that this data be transferred to another service provider where technically feasible.
• Right to withdraw consent: Where 77up processes your data on the basis of your consent (for example, for promotional communications), you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.
• Right to object: You have the right to object to the processing of your personal data where that processing is based on legitimate interest. 77up will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

The 77up platform is strictly restricted to individuals who are at least 21 years of age. We do not knowingly collect personal data from anyone below the age of 21. Age verification is conducted at the point of registration and is reinforced at the KYC verification and first withdrawal stages.

If 77up discovers that personal data has been collected from an individual below the age of 21, the relevant account will be immediately suspended and permanently closed, all collected data will be securely deleted, and any deposited funds will be returned to the original payment source in accordance with our underage gambling policy as set out in our Terms & Conditions.

If you are a parent or guardian and believe that a minor in your care has attempted to register or use the 77up platform, please contact our support team immediately at [email protected]. We take underage access attempts seriously and will investigate all reports promptly.

We encourage parents and guardians to make use of parental control software and to discuss responsible internet use with children and young adults in their care. If you are concerned that someone you know may be developing a gambling problem, please visit our Responsible Gaming page for guidance.

77up's platform infrastructure and certain third-party service providers (including KYC verification and fraud detection partners) may be located in jurisdictions outside of Bangladesh. Where personal data is transferred to servers or service providers located outside Bangladesh, 77up takes appropriate steps to ensure that such transfers are carried out securely and that the receiving party is bound by contractual data protection obligations consistent with the standards applied by 77up.

In all cases of international data transfer, 77up requires that the recipient:

• Implements technical and organisational security measures equivalent to those described in Section 7 of this Policy.
• Processes transferred data only for the specific purpose for which it was shared, as described in Section 5 of this Policy.
• Does not further transfer the data to any additional party without 77up's prior written consent.
• Returns or securely deletes the transferred data upon the conclusion of the service relationship with 77up.

By using the 77up platform, you acknowledge that your personal data may be processed in jurisdictions outside Bangladesh and consent to such transfers subject to the safeguards described in this section.

77up reserves the right to update or amend this Privacy Policy at any time. The effective date displayed at the top of this document will be updated to reflect the date of the most recent revision. The current version of this Policy will always be accessible at https://77up.vu/privacy-policy.

Where changes to this Policy are material — meaning they significantly affect the way in which we collect or use your personal data, or affect the rights available to you — 77up will endeavour to notify registered account holders in advance of the changes taking effect. Such notification may be delivered by email to your registered address, by an in-platform notification upon login, or by a prominently placed notice on the website.

Your continued use of the 77up platform after the effective date of any amended Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with changes made to this Policy, you should stop using the platform and request account closure in accordance with Section 12 of the Terms & Conditions. Your data will continue to be held for the retention periods set out in Section 6 of this Policy even after account closure, as required by applicable law.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 77up holds about you, please contact our support team using the details below. We are committed to responding to all privacy-related enquiries promptly and transparently.

• Live chat: Available 24 hours a day, 7 days a week via the live chat interface on the 77up platform. This is the fastest channel for urgent privacy queries.
• Email: [email protected] (plain text — not a clickable link). For data subject access requests, erasure requests, or formal privacy complaints, please use the subject line "Privacy Request" to ensure your message reaches the correct team.
• Response time: Privacy-related requests submitted via email will be acknowledged within 3 business days and resolved within 30 calendar days of receipt, in line with standard data subject request handling timelines.

When submitting a data access or deletion request, please include your registered mobile number and account username so that our team can locate your account and process your request efficiently. We may ask for additional verification to confirm your identity before acting on any data subject request, to ensure that your personal data is not disclosed or deleted in response to a request from an unauthorised third party.

This Privacy Policy was last reviewed and updated on 1 January 2026. All prior versions of the Privacy Policy are superseded by this document from that effective date.