des77 Privacy Policy — Your Data, Your Rights

This Privacy Policy ("Policy") describes how des77 ("the Company", "we", "us", "our") collects, uses, stores, and protects personal data provided by users ("you", "your") of the des77 website and mobile platform (collectively "the Platform"). By registering an account or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

This Policy applies to all personal data collected through the Platform, including data collected during registration, during gameplay, through customer support interactions, and through your use of our payment services. We encourage you to read this Policy carefully and to contact us if you have any questions about how your personal data is processed.

When you use the des77 Platform, we collect several categories of personal data. We collect only what is necessary for the legitimate operation of the Platform and no more. The categories of personal data we collect include:

• Identity data: full name, date of birth, gender, and a copy of a government-issued identity document where required for KYC verification.
• Contact data: email address, phone number (including your mobile number registered with bKash, Nagad, or Rocket), and residential address.
• Financial data: deposit and withdrawal transaction records, payment method identifiers (e.g. the last four digits of a card or a bKash wallet reference), and account balance history. We do not store full card numbers on our servers.
• Technical data: IP address, browser type and version, device type, operating system, time zone setting, and pages visited on the Platform (collected automatically via cookies and server logs).
• Gameplay and usage data: game history, bet amounts, win and loss records, session duration, and bonus usage. This data is used to operate the Platform, detect fraud, and fulfil responsible gaming obligations.

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data unless we are legally required to do so in a specific circumstance. Where we are required to collect such data, we will inform you separately at the point of collection.

des77 uses your personal data for the following purposes, each of which is either necessary to deliver the services you have requested or is otherwise legitimately required for Platform operation:

• Account management: to create, verify, maintain, and close your des77 account, including processing identity verification as required by our KYC procedures.
• Payment processing: to process your deposits and withdrawals via bKash, Nagad, Rocket, and other supported payment methods, and to maintain accurate financial records as required by applicable law.
• Service improvement and personalisation: to analyse how you use the Platform and to improve the features, game selection, and overall user experience we offer to players in Bangladesh.
• Fraud prevention and security: to monitor transactions and gameplay for unusual patterns that may indicate fraudulent activity, money laundering, or terms violations, and to take appropriate action when such patterns are detected.
• Responsible gaming: to monitor gameplay patterns that may indicate problem gambling behaviour and to apply responsible gaming tools (such as deposit limits and cooling-off periods) in line with our responsible gaming policy.

We process your personal data on one or more of the following legal grounds depending on the specific processing activity:

• Contractual necessity: processing that is necessary to perform our contract with you — for example, creating your account, processing deposits and withdrawals, and maintaining your game history.
• Legal obligation: processing that is required to comply with applicable law — for example, retaining financial transaction records, conducting KYC checks, and cooperating with lawful requests from regulatory or law enforcement authorities.
• Legitimate interests: processing that is necessary for our legitimate business interests — for example, fraud detection, security monitoring, and platform improvement — where those interests are not overridden by your fundamental rights.
• Consent: where we rely on your consent as the legal basis (for example, for optional marketing communications), you may withdraw that consent at any time by contacting us or updating your account preferences.

des77 does not sell your personal data. We may share your personal data with carefully selected third parties only in the following circumstances:

• Payment processors: your financial data is shared with payment service providers (such as bKash, Nagad, and Rocket) solely for the purpose of processing your transactions. These providers are contractually bound to process your data only as instructed and in accordance with applicable data protection requirements.
• Identity verification services: where required for KYC compliance, your identity documents may be shared with a third-party identity verification service provider. Such providers are engaged under strict data processing agreements.
• Legal and regulatory authorities: we may disclose your personal data to law enforcement agencies, financial intelligence units, or other regulatory bodies where we are legally required to do so or where we believe disclosure is necessary to protect the rights, property, or safety of des77, our players, or the public.
• Technology and infrastructure providers: we use third-party hosting, analytics, and security services whose systems may process your data as part of normal Platform operation. All such providers are required to implement appropriate technical and organisational security measures.

We do not share your personal data with any third party for their own marketing or commercial purposes. Any third party that processes your data on our behalf does so solely as a data processor acting on our instructions and is contractually prohibited from using your data for any other purpose.

The des77 Platform uses cookies and similar tracking technologies to provide core functionality and to improve the user experience. A cookie is a small text file placed on your device when you visit our Platform. Cookies allow us to recognise your browser, keep you signed in, remember your preferences, and gather analytics data about how the Platform is used.

We use the following categories of cookies:

• Strictly necessary cookies: these are required for the Platform to function. They include session management cookies that keep you logged in during your visit. These cannot be disabled without breaking core Platform functionality.
• Analytics cookies: these help us understand how visitors use the Platform — which pages are visited most, how long sessions last, and where users navigate to and from. Analytics data is aggregated and does not identify you personally.
• Preference cookies: these remember your settings and preferences (such as language or display settings) so you do not have to re-enter them on each visit.

des77 retains your personal data for as long as your account is active and for a reasonable period thereafter to satisfy our legal and regulatory obligations. The specific retention periods that apply to different categories of data are:

Account and identity data is retained for the duration of your account plus a minimum of 5 years after account closure to satisfy financial record-keeping and anti-money-laundering obligations. Financial transaction data is retained for a minimum of 5 years from the date of each transaction. Gameplay data is retained for 2 years from the date it was generated unless a longer retention period is required for fraud investigation or legal proceedings. Technical log data (IP logs, server logs) is typically retained for 90 days and then deleted. When personal data is no longer required for any lawful purpose, it is securely deleted or anonymised.

As a user of the des77 Platform, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our support team at [email protected] (plain text, not a clickable link):

• Right of access: you have the right to request a copy of the personal data we hold about you and to receive information about how we process it.
• Right of rectification: if any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or completed.
• Right of erasure: in certain circumstances, you have the right to request that we delete your personal data. This right is subject to any overriding legal obligations we have to retain your data (for example, financial record-keeping requirements).
• Right to restrict processing: you have the right to request that we restrict the processing of your personal data in certain circumstances, for example while you contest the accuracy of data we hold about you.
• Right to withdraw consent: where we process your data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

We will respond to all valid data rights requests within 30 days of receipt. In complex cases we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

des77 takes the security of your personal data seriously. We implement appropriate technical and organisational measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include SSL/TLS encryption for all data transmitted between your device and our servers, secure storage of personal data on access-controlled servers, regular security assessments and penetration testing, and strict internal access controls that limit employee access to personal data on a need-to-know basis.

While we take all reasonable steps to protect your personal data, no system is completely immune to security threats. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and any relevant authorities as required by applicable law.

The des77 Platform may contain links to third-party websites or services. These links are provided for your convenience only. des77 has no control over the content, privacy practices, or security of any third-party website. Once you leave the des77 Platform by following an external link, this Privacy Policy no longer applies. We encourage you to review the privacy policy of any third-party website you visit before providing any personal data to that site.

The des77 Platform is strictly for adults aged 21 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 collected from a person under the age of 21, we will delete that data immediately and close the associated account. If you are a parent or guardian and you believe that a minor has provided us with personal data or has accessed our Platform without authorisation, please contact us immediately at [email protected] so that we can take appropriate action.

des77 reserves the right to update or amend this Privacy Policy at any time. When we make material changes to this Policy, we will update the "Last updated" date at the top of this page and, where reasonably practicable, notify registered players by email or in-account notification. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way des77 handles your personal data, please contact our support team. Our support email address is [email protected] — this is plain text only and is not a clickable link. We aim to respond to all privacy-related enquiries within 48 hours Bangladesh Standard Time (BST, UTC+6).