47c77 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1. Introduction

This Privacy Policy describes how 47c77 ("we", "us", "our") collects, uses, stores, and discloses personal information obtained from individuals ("you", "your", "the player") who access or use the 47c77 online betting and casino platform available at https://47c77.io and all associated sub-pages and services (collectively, the "Platform").

47c77 is committed to handling your personal data with transparency, integrity, and care. We recognise that players accessing the Platform from the Bangladesh market place significant trust in us when they share their personal information, and we take that responsibility seriously.

By registering an account or using the 47c77 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please discontinue use of the Platform and contact our support team to arrange account closure.

2. Data Controller

For the purposes of applicable data protection law, 47c77 acts as the data controller in respect of personal data collected through the Platform. As data controller, 47c77 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

All data protection enquiries, subject access requests, and complaints should be directed to the 47c77 support team using the contact details provided in Section 13 of this Policy.

3. Data We Collect

47c77 collects the following categories of personal data from players:

3.1 Identity & Registration Data

• Full legal name
• Date of birth
• Gender (where provided voluntarily)
• Nationality and country of residence
• Username selected during registration

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (city, district, postal code)

3.3 Identity Verification (KYC) Data

• Government-issued photo ID (National Identity Card, passport, or driving licence — including the document number, issue date, and expiry date)
• Proof of address documents (utility bills, bank statements dated within three months)
• Selfie or facial image submitted during enhanced verification

3.4 Financial & Transaction Data

• Mobile wallet numbers associated with bKash, Nagad, Rocket, and Upay transactions
• Card type (Visa/Mastercard) — no full card numbers are stored by 47c77
• Transaction amounts, dates, and references
• Deposit and withdrawal history
• Account balance information

3.5 Gaming & Betting Activity Data

• Bet history, wager amounts, selections, and outcomes
• Casino game session data including game titles played, session duration, and stakes
• Bonus and promotional activity
• Responsible gaming settings and self-exclusion records

3.6 Technical & Device Data

• IP address at the time of login and during active sessions
• Device type, operating system, and browser type
• Geolocation data (country/city level, derived from IP)
• Session timestamps and duration
• Cookie identifiers and similar tracking technologies (see Section 8)

3.7 Communication Data

• Records of customer support interactions (live chat transcripts, email correspondence)
• Feedback, complaints, and dispute records
• Marketing preferences and consent records

4. How We Collect Your Data

47c77 collects personal data through the following channels:

Collection Method	Examples
Direct submission	Account registration form, KYC document upload, customer support contact, deposit/withdrawal requests
Automated collection	Cookies, session logs, IP address capture, device fingerprinting during Platform use
Payment processors	Transaction confirmation data received from bKash, Nagad, Rocket, Upay, and card payment gateways
Identity verification partners	Confirmation results from KYC/AML screening services used to verify identity documents
Fraud prevention services	Risk scores and flagging data from fraud detection providers integrated with the Platform

5. Purposes & Legal Basis for Processing

47c77 processes your personal data for the following purposes, each supported by a defined legal basis:

5.1 Account Registration & Management

Purpose: To create and maintain your 47c77 player account, authenticate logins, and enable access to the Platform's full range of services.

Legal basis: Performance of a contract — processing is necessary to provide the services you have requested by registering an account.

5.2 Identity Verification & KYC Compliance

Purpose: To verify your identity, confirm your age (21+ requirement), and fulfil our anti-money-laundering (AML) and Know Your Customer (KYC) obligations.

Legal basis: Legal obligation — 47c77 is required to conduct identity verification as part of its compliance framework for operating an international betting platform.

5.3 Payment Processing

Purpose: To process BDT deposits via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to process withdrawal requests to your registered payment method.

Legal basis: Performance of a contract — payment processing is an essential component of the betting and casino service.

5.4 Fraud Prevention & Security

Purpose: To detect and prevent fraudulent account activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct described in the 47c77 Terms & Conditions.

Legal basis: Legitimate interests — 47c77 has a legitimate interest in protecting the integrity of the Platform, safeguarding other players, and preventing financial crime.

5.5 Responsible Gaming Monitoring

Purpose: To monitor gaming behaviour for indicators of problem gambling, to enforce self-exclusion and deposit limit settings, and to provide timely interventions where harmful patterns are identified.

Legal basis: Legal obligation and legitimate interests — responsible gaming monitoring is both a compliance requirement and a genuine player welfare commitment.

5.6 Customer Support

Purpose: To respond to your enquiries, resolve disputes, process complaints, and provide technical assistance.

Legal basis: Performance of a contract and legitimate interests.

5.7 Platform Improvement & Analytics

Purpose: To analyse anonymised and aggregated usage data to improve Platform performance, user experience, game selection, and promotional offerings for Bangladesh players.

Legal basis: Legitimate interests — data used for this purpose is aggregated and does not identify individual players.

5.8 Marketing Communications

Purpose: To send you promotional offers, bonus notifications, and relevant product updates where you have given explicit consent.

Legal basis: Consent — you may withdraw marketing consent at any time by contacting support or updating your account communication preferences. Withdrawal of marketing consent does not affect the lawfulness of any prior processing.

6. Sharing Your Personal Data

47c77 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following limited circumstances:

6.1 Service Delivery Partners

We share data with trusted third-party service providers who assist in operating the 47c77 Platform, including:

• Payment processors — bKash, Nagad, Rocket, Upay, and card payment gateway operators, to process transactions on your behalf
• KYC and identity verification providers — to confirm the authenticity of submitted identity documents
• Fraud detection services — to screen transactions and account activity for risk indicators
• Cloud infrastructure and hosting providers — who store Platform data on secure, encrypted servers
• Game studios — Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and Play'n GO receive anonymised session data necessary to deliver their game products within the Platform

All service delivery partners are required to process personal data only under 47c77's instructions and subject to contractual data protection obligations. They may not use your data for their own independent purposes.

6.2 Legal & Regulatory Disclosure

47c77 may disclose personal data to law enforcement agencies, regulatory authorities, or financial intelligence units where we are legally required to do so, or where disclosure is necessary to investigate suspected financial crime, fraud, or other illegal activity.

6.3 Business Transfers

In the event that 47c77 undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity as part of that transaction. We will notify affected players of any such transfer and the implications for their data prior to the transfer taking effect.

7. Payment Data & Financial Security

The security of your financial data is of paramount importance to 47c77. The following specific measures govern how payment information is handled on the Platform:

• Full payment card numbers (PAN) are never stored on 47c77 servers. Card transactions are processed entirely by PCI-DSS Level 1 compliant payment gateways.
• Mobile wallet transactions via bKash, Nagad, Rocket, and Upay are processed using tokenised references. 47c77 retains only the masked wallet number and transaction reference — not the full account credentials of the payment method.
• All payment-related communications between your device and the 47c77 Platform are secured using 256-bit TLS encryption.
• Transaction records are retained for the period required by applicable AML regulations, after which they are securely purged from active systems.

8. Cookies & Tracking Technologies

The 47c77 Platform uses cookies and similar tracking technologies to ensure proper functionality, improve user experience, and support our analytics and security operations.

8.1 Types of Cookies Used

Cookie Type	Purpose	Duration
Essential	Session authentication, login state persistence, security tokens	Session / up to 30 days
Functional	Language preferences, game layout settings, account dashboard preferences	Up to 12 months
Analytics	Anonymised usage statistics, page performance, user journey analysis	Up to 24 months
Security	Fraud detection signals, bot prevention, IP reputation scoring	Session / up to 90 days

Essential and security cookies are strictly necessary for the operation of the Platform and cannot be disabled without disrupting core functionality. Functional and analytics cookies may be managed through your browser settings. Note that disabling functional cookies may affect your experience on the Platform.

9. Data Retention

47c77 retains personal data for as long as necessary to fulfil the specific purpose for which it was collected, subject to the following retention schedule:

• Active account data — retained for the lifetime of your account plus five years following closure, in accordance with standard AML record-keeping requirements
• KYC and identity documents — retained for a minimum of five years from the date of the last transaction, as required by applicable anti-money-laundering regulations
• Transaction and financial records — retained for five years from the transaction date
• Customer support records — retained for three years from the date of the interaction
• Marketing consent records — retained until consent is withdrawn, plus three years as evidence of compliance
• Technical and device logs — retained for 90 days from collection, after which they are aggregated or deleted

At the end of the applicable retention period, personal data is securely deleted from active systems or anonymised so that it can no longer be linked to an identifiable individual.

10. Security Measures

47c77 implements a multi-layered security framework to protect your personal data against unauthorised access, alteration, disclosure, or destruction:

• 256-bit TLS/SSL encryption — all data in transit between your browser and our servers is encrypted
• AES-256 encryption at rest — sensitive data fields stored in our databases are encrypted at the storage layer
• Access controls — personal data is accessible only to 47c77 personnel who require it for their specific operational role, subject to role-based access controls and audit logging
• Intrusion detection — automated monitoring systems scan for anomalous access patterns and potential data breach indicators on a 24/7 basis
• Regular security assessments — our infrastructure undergoes periodic vulnerability assessments and penetration testing
• Two-factor authentication — available for player accounts to add an additional layer of login security

11. Your Data Rights

As a player whose personal data is processed by 47c77, you hold the following rights in relation to your personal information:

11.1 Right of Access

You have the right to request a copy of all personal data that 47c77 holds about you. We will respond to verified access requests within 30 days of receipt. The first copy is provided free of charge; subsequent requests for the same data within a 12-month period may incur a reasonable administrative fee.

11.2 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. For account-level data such as your registered email address or contact number, corrections can be made directly through your account settings. For KYC data, submit a rectification request to support with supporting documentation.

11.3 Right to Erasure

You may request the deletion of your personal data where: the data is no longer necessary for the purpose for which it was collected; you withdraw consent and there is no other legal basis for processing; or the data has been processed unlawfully. Note that erasure requests may be partially declined where retention is required by law — for example, AML regulations mandate that certain financial records are retained for a minimum of five years regardless of erasure requests.

11.4 Right to Data Portability

Where processing is based on consent or contract, you have the right to receive a structured, machine-readable copy of the personal data you have provided to 47c77, for the purpose of transferring it to another service provider.

11.5 Right to Object

You have the right to object to processing carried out on the basis of legitimate interests, including profiling for fraud prevention purposes. We will assess your objection and cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests.

11.6 Right to Withdraw Marketing Consent

Where you have provided consent to receive marketing communications from 47c77, you may withdraw that consent at any time by contacting our support team or updating your account notification preferences. Withdrawal of marketing consent does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise any of the rights listed above, contact the 47c77 support team using the details in Section 13. We may need to verify your identity before processing a rights request to protect against fraudulent access to another player's data.

12. Minors & Age Policy

The 47c77 Platform is strictly intended for adults aged 21 years or older. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately suspend the relevant account, refuse all associated transactions, and delete or return the personal data collected.

Parents and guardians who have reason to believe that a minor has registered an account on the 47c77 Platform should contact our support team immediately using the contact details in Section 13. We will investigate and take appropriate action within 24 hours of receiving such a report.

13. Contact & Complaints

For all privacy-related enquiries, data rights requests, or complaints regarding how 47c77 handles your personal data, please contact our support team using the following details:

• Email: support@47c77.io  (plain text — not a clickable link)
• Live Chat: Available 24/7 via the support widget on the Platform
• Response time: Privacy and data rights requests are responded to within 30 days. General support queries are typically addressed within 24 hours (Bangladesh Standard Time, UTC+6).

If you are not satisfied with our response to a data rights request or privacy complaint, you have the right to escalate the matter to the relevant data protection authority or regulatory body in your jurisdiction.

14. Changes to This Privacy Policy

47c77 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or Platform functionality. The "Last updated" date at the top of this document will be revised whenever a material change is made.

Where changes are significant — for example, introducing a new category of data collection or a new third-party sharing arrangement — we will notify registered players via their registered email address prior to the changes taking effect. For minor editorial or clarificatory updates, the revised Policy will be published on this page without individual notification.

Continued use of the 47c77 Platform after any revision to this Privacy Policy constitutes acceptance of the updated Policy. If you do not agree with the changes, please discontinue use of the Platform and contact support to arrange account closure in accordance with the Terms & Conditions.