td77 Privacy Policy — How We Handle Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how td77 ("the Platform", "we", "us", "our") collects, uses, stores, and protects the personal data of individuals ("Player", "User", "you", "your") who access or use the td77 online betting and gaming platform available at td77.io.

td77 is an online betting platform built for players in Bangladesh, offering cricket betting, live casino games, slot titles, Hi-Lo, and associated services. As part of delivering these services, td77 is required to collect and process certain categories of personal data. This Policy sets out what data we collect, why we collect it, how long we keep it, and how we protect it.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which form part of the overall agreement between you and td77.

By completing the td77 registration process and continuing to use the platform, you confirm that you have read and understood this Privacy Policy in full and that you consent to the collection and processing of your personal data as described herein.

2. Data We Collect

2.1 Registration Data

When you create a td77 account, we collect the following information:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Residential address in Bangladesh (district, division, postal code)
• Mobile phone number (used for account authentication and SMS notifications)
• Email address (used for account communications and notifications)
• Username and hashed password

2.2 KYC Verification Data

To comply with anti-money laundering (AML) obligations and to verify player identity before processing withdrawals, td77 collects the following KYC documents:

• Government-issued photo identification (National ID card, passport, or driving licence)
• Proof of residential address (utility bill, bank statement dated within 90 days)
• Proof of payment method (screenshot or documentation of the bKash, Nagad, Rocket, or bank account used for deposits)
• Selfie photograph for identity matching purposes, where required

2.3 Financial Transaction Data

When you make deposits or request withdrawals, td77 records:

• Payment method type (bKash, Nagad, Rocket, Upay, bank transfer, Visa, Mastercard)
• Transaction amounts in Bangladeshi Taka (BDT)
• Transaction reference numbers and timestamps
• Account numbers or wallet identifiers associated with your payment method (partial, masked where possible)

2.4 Betting & Gaming Activity Data

td77 records all betting and gaming activity associated with your account, including:

• Bets placed, stakes, odds, and outcomes on cricket and other sports markets
• Casino game sessions, wager amounts, and results
• Slot and instant game play history
• Bonus claims and wagering progress

2.5 Technical & Device Data

When you access td77 via a web browser or mobile device, we automatically collect:

• IP address and approximate geographic location (country and city level)
• Browser type, version, and operating system
• Device type (desktop, mobile, tablet) and screen resolution
• Session timestamps, pages visited, and navigation paths within td77
• Referring URL (the site or link that directed you to td77)

2.6 Communications Data

When you contact td77 support via email or live chat, we retain records of those communications, including the content of your messages, your contact details, and the timestamps of all interactions. This data is used for quality assurance, compliance, and fraud prevention purposes.

3. How We Use Your Data

td77 uses your personal data for the following purposes:

Purpose	Data Categories Used
Account creation and management	Registration data, device data
Age and identity verification (KYC)	Registration data, KYC documents
Processing deposits and withdrawals	Financial transaction data, KYC data
Delivering betting and gaming services	Gaming activity data, registration data
Fraud detection and prevention	All categories, particularly device and financial data
Anti-money laundering (AML) compliance	Financial transaction data, KYC data
Responsible gaming monitoring	Gaming activity data, registration data
Customer support and complaints handling	Communications data, registration data
Platform analytics and improvement	Technical data, gaming activity data (anonymised where possible)
Marketing communications (where opted in)	Registration data, gaming activity data

td77 does not use your personal data for any purpose not listed above without first obtaining your explicit consent or unless required to do so by applicable law.

4. Legal Basis for Processing

td77 processes your personal data on the following legal grounds:

• Contract Performance: Processing your registration data, KYC documents, and financial transaction data is necessary to perform the contract between you and td77 — specifically, to provide you with access to the platform and to process your deposits and withdrawals.
• Legal Obligation: td77 is required to collect and retain certain data categories (particularly KYC and financial transaction data) to comply with anti-money laundering regulations, age verification obligations, and applicable financial reporting requirements.
• Legitimate Interests: td77 processes technical and device data to detect and prevent fraud, protect platform security, and improve service quality. These legitimate interests have been assessed and do not override your fundamental privacy rights.
• Consent: Where td77 processes your data for marketing communications or optional personalisation features, we do so only on the basis of your explicit, freely given consent. You may withdraw consent for marketing communications at any time by contacting support or using the opt-out mechanism in any marketing email.

5. Data Sharing & Disclosure

td77 does not sell or rent your personal data to any third party. We share your personal data only in the following limited circumstances:

5.1 Payment Service Providers

When you make a deposit or request a withdrawal, td77 shares the minimum necessary transaction data with the relevant payment service provider (such as bKash, Nagad, Rocket, Upay, or the applicable bank or card network). This sharing is strictly necessary to process the financial transaction and is governed by the service provider's own privacy policy and applicable payment industry regulations.

5.2 KYC and Identity Verification Partners

Where td77 uses a third-party identity verification service to assist with KYC document checks, your submitted KYC documents may be processed by that service provider under strict confidentiality and data processing agreements with td77. These providers act as data processors on our behalf and are prohibited from using your data for their own purposes.

5.3 Game Studios and Content Providers

When you play casino games provided by third-party game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi, limited session and account data may be shared with those studios solely to facilitate gameplay and resolve game-related disputes. These studios do not receive your full identity or financial data.

5.4 Legal and Regulatory Authorities

td77 will disclose personal data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, in response to a lawful request or legal process, or where td77 reasonably believes that disclosure is necessary to prevent or investigate fraud, money laundering, or other criminal activity.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of td77's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the applicable privacy terms governing your data following the transaction.

6. Cookies & Tracking Technologies

td77 uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies used by td77 are described below:

• Essential Cookies: Required for the platform to function. These cookies maintain your login session, remember your account preferences, and ensure secure navigation. Essential cookies cannot be disabled without preventing you from using td77.
• Analytics Cookies: Used to collect anonymised data on how players navigate and interact with td77, which pages are most visited, and where technical errors occur. This data is used exclusively to improve platform performance and user experience.
• Fraud Prevention Cookies: td77 uses device fingerprinting and session cookies to detect suspicious login activity, identify duplicate account attempts, and flag unusual betting patterns consistent with fraud or bonus abuse.
• Preference Cookies: Store non-essential player preferences such as language settings, display options, and notification preferences to personalise your td77 experience.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the td77 platform. td77 does not use third-party advertising cookies or cross-site tracking cookies.

7. Data Retention

td77 retains your personal data for the periods described below. After these retention periods expire, data is securely deleted or irreversibly anonymised:

• Active Account Data: Retained for the full duration of your td77 account registration and for a period of five (5) years following permanent account closure, in order to satisfy legal, regulatory, and dispute resolution obligations.
• KYC Documents: Retained for a minimum of five (5) years following the date of submission, in compliance with anti-money laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with standard financial record-keeping obligations.
• Betting and Gaming Activity Logs: Retained for five (5) years for compliance and dispute resolution purposes, after which they are anonymised and retained in aggregated form for statistical analysis only.
• Customer Support Communications: Retained for three (3) years from the date of the most recent communication in a given support thread.
• Technical and Device Logs: Retained for up to twelve (12) months, after which they are purged unless flagged in connection with a specific fraud or security investigation.

8. Data Security

td77 implements robust technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser or device and the td77 platform
• AES-256 encryption for personal and financial data stored in td77's databases
• One-way salted hashing for all stored passwords — td77 staff cannot view your password in plain text
• Role-based access control (RBAC) ensuring that td77 employees can only access data necessary for their specific job function
• Regular third-party security audits and penetration testing of the td77 platform infrastructure
• Intrusion detection systems and 24/7 security monitoring of platform servers
• Mandatory two-factor authentication for all td77 internal staff accounts with access to player data

Despite these measures, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a significant risk to affected players, td77 will notify impacted players and relevant authorities as required by applicable data protection obligations.

9. Your Rights

As a td77 player, you hold the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected]. td77 will respond to all data rights requests within 30 calendar days of receipt.