adc77 Privacy Policy — How We Protect Your Personal Data

1 Introduction

adc77 is Bangladesh's trusted online cricket betting and casino platform, offering sports betting markets, live dealer games, slot titles, and related gaming services to eligible registered players. As part of delivering those Services, adc77 necessarily collects and processes certain personal data about the individuals who register and interact with the platform.

adc77 takes its obligations as a data processor seriously. This Privacy Policy sets out in plain, accessible English precisely what personal data adc77 collects, the purposes for which it is processed, the third parties with whom it may be shared, the security measures in place to protect it, how long it is retained, and the rights available to you as a data subject.

This Privacy Policy should be read together with the adc77 Terms & Conditions and Responsible Gaming Policy, which are published on the adc77 platform and are incorporated by reference. In the event of any conflict between this Privacy Policy and any other document, this Privacy Policy shall prevail with respect to data protection matters.

adc77 operates primarily in the Bangladesh market and designs its data practices to respect the reasonable privacy expectations of Bangladeshi players. All communications regarding privacy matters are conducted in English.

2 Definitions

For the purposes of this Privacy Policy, the following terms shall have the meanings set out below:

• "Personal Data" means any information that identifies or could reasonably be used to identify a living individual, directly or indirectly, including name, email address, mobile number, national identity number, IP address, and device identifiers.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, transmission, or deletion.
• "Data Subject" means the identified or identifiable natural person to whom Personal Data relates — in the context of this policy, this means you, the registered player.
• "Controller" means the entity that determines the purposes and means of processing Personal Data. For the purposes of this policy, adc77 acts as the Controller in respect of the data it collects about players.
• "Processor" means a third party that processes Personal Data on behalf of the Controller, under contractual instruction. adc77's payment providers and KYC partners act as Processors in relation to the data adc77 shares with them.
• "KYC" means Know Your Customer — the identity and age verification process applied to player accounts before certain Services (including withdrawals above defined thresholds) become available.
• "Cookies" means small text files stored on your device by the adc77 platform for the purpose of session management, preference retention, and analytics.

3 Personal Data We Collect

adc77 collects the following categories of Personal Data, depending on the nature of your interaction with the platform:

4 How We Collect Your Data

adc77 collects Personal Data through the following channels:

4.1 Directly from You

The majority of Personal Data adc77 holds is provided directly by you during the account registration process, identity verification, deposit and withdrawal requests, and any communications you initiate with the support team. You are under no obligation to provide this data, but failure to do so may mean that certain Services are unavailable to you.

4.2 Automatically During Platform Use

When you access the adc77 platform, Technical Data is collected automatically through server logs, cookies, and similar tracking technologies embedded in the platform. This data is collected to ensure the platform functions correctly, to maintain session security, and to identify and prevent fraudulent or suspicious access patterns.

4.3 From Third-Party Providers

adc77 may receive supplementary Personal Data from third-party identity verification providers engaged to assist with the KYC process, or from payment processors as part of transaction reconciliation. Such data is received under contractual data sharing arrangements and is used solely for the purpose for which it was shared.

5 Purposes of Processing

adc77 processes your Personal Data for the following purposes:

• Account Management: Creating, maintaining, and securing your adc77 account, including authentication, password reset, and account recovery processes.
• Service Delivery: Processing your deposits, withdrawals, bets, casino game sessions, and any bonus or promotional redemptions you request.
• Identity & Age Verification: Confirming that you are at least 21 years of age and are who you say you are, as required by our responsible gaming and fraud prevention obligations.
• Fraud Detection & Prevention: Monitoring account activity for patterns consistent with fraudulent behaviour, multi-accounting, money laundering, or match-fixing, and taking appropriate action where such patterns are identified.
• Responsible Gaming: Monitoring gameplay patterns for indicators of problem gambling, enforcing self-exclusion and deposit limit instructions, and reaching out proactively to players who may be experiencing difficulty.
• Customer Support: Responding to your support enquiries, resolving disputes, and improving the quality of our support services based on communication records.
• Platform Improvement: Analysing aggregated and anonymised usage data to understand how players interact with the platform and to prioritise technical improvements and new features.
• Legal & Compliance: Retaining records to satisfy internal audit requirements, responding to lawful requests from authorities, and maintaining documentation of player consent where required.
• Communications: Sending you service-related notifications such as deposit confirmations, withdrawal status updates, and material changes to our policies. Where you have opted in, we may also send promotional communications about bonuses or new game launches; you may withdraw this consent at any time.

6 Legal Basis for Processing

adc77 processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing required to perform the adc77 Terms & Conditions contract with you, including account management, bet settlement, and payment processing.
• Legitimate Interests: Processing necessary for adc77's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and business analytics, where those interests are not overridden by your rights and interests.
• Legal Obligation: Processing required to comply with applicable legal obligations, including identity verification, transaction record-keeping, and responding to lawful authority requests.
• Consent: Where no other legal basis applies — for example, in relation to optional marketing communications — adc77 will rely on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

7 Data Sharing & Third-Party Disclosure

adc77 does not sell, rent, or commercially transfer your Personal Data to third parties. adc77 may share your Personal Data with the following categories of recipient, strictly as necessary:

7.1 Payment Service Providers

To process your deposits and withdrawals, adc77 shares the minimum necessary transaction data with payment partners including bKash, Nagad, Rocket, Upay, and the card-processing networks supporting Visa and Mastercard transactions. These providers process your payment data under their own privacy policies and applicable financial services regulations.

7.2 Identity Verification Providers

To fulfil its KYC obligations, adc77 may engage third-party identity verification services to validate the authenticity of identity documents you submit. These providers receive only the data necessary to perform verification and are contractually prohibited from using it for any other purpose.

7.3 Game Content Providers

Third-party game studios — including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi — may receive a pseudonymous player identifier and session token to enable game session management. These providers do not receive your full name, contact details, or financial data.

7.4 Legal & Regulatory Bodies

adc77 may disclose Personal Data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law or by a valid legal process. adc77 will notify you of such disclosure where legally permitted to do so.

7.5 Business Transfers

In the event that adc77 undergoes a merger, acquisition, restructuring, or sale of assets, your Personal Data may be transferred to the successor entity as part of that transaction. You will be notified in advance of any such transfer where practicable, and the successor entity will be bound by the terms of this Privacy Policy or an equivalent standard.

8 Cookies & Tracking Technologies

The adc77 platform uses cookies and similar tracking technologies to deliver a functional, secure, and personalised user experience. The following types of cookies are used:

adc77 does not use third-party advertising or retargeting cookies. You may manage cookie preferences through your browser settings; however, disabling essential cookies will impair platform functionality and may prevent you from accessing your account.

9 Data Security

adc77 implements a layered security architecture to protect your Personal Data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Security measures in place include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and adc77 servers is encrypted in transit using industry-standard TLS protocols. The adc77 platform enforces HTTPS exclusively; unencrypted HTTP connections are automatically redirected.
• Encryption at Rest: Sensitive personal and financial data stored on adc77 infrastructure is encrypted at rest using AES-256 encryption. Backups are encrypted to the same standard.
• Access Controls: Internal access to Personal Data is granted on a strict need-to-know basis. Staff with data access are subject to background verification, confidentiality obligations, and regular security training. Access privileges are reviewed periodically and revoked immediately upon role change or departure.
• Infrastructure Security: adc77 servers are hosted in access-controlled data centre environments with physical security controls, network firewalls, intrusion detection systems, and 24/7 monitoring.
• Password Security: Player account passwords are stored as salted cryptographic hashes. adc77 staff cannot view your password in plain text. You are strongly encouraged to use a unique, complex password for your adc77 account and to enable two-factor authentication where available.
• Incident Response: adc77 maintains a data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights, adc77 will notify affected players as promptly as practicable and take immediate remedial action.

10 Data Retention

adc77 retains Personal Data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law and internal audit standards. The following retention periods apply:

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised. Anonymised data (from which no individual can be identified) may be retained indefinitely for statistical analysis and platform improvement purposes.

11 Your Data Rights

As a registered adc77 player, you hold the following rights in relation to your Personal Data. To exercise any of these rights, contact the adc77 support team at [email protected] with the subject line "Data Rights Request" and a description of your request. adc77 will acknowledge your request within 4 hours and provide a substantive response within 14 calendar days.

• Right of Access: You have the right to request a copy of the Personal Data that adc77 holds about you, together with information about how it is being used. adc77 will provide this in a structured, readable format.
• Right to Rectification: If any Personal Data held by adc77 is inaccurate or incomplete, you have the right to request that it be corrected. Basic account details such as your mobile number or email address can be updated directly from within your account settings.
• Right to Erasure: You have the right to request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent and no other legal basis applies, or where the data has been unlawfully processed. This right is subject to legal retention obligations, which may mean that certain data must be retained for a defined period even after your account is closed.
• Right to Restriction: You have the right to request that adc77 restricts its processing of your Personal Data while a dispute about its accuracy or the lawfulness of its processing is pending resolution.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and carried out by automated means, you have the right to receive your Personal Data in a structured, commonly used, machine-readable format and to transmit it to another controller.
• Right to Object: You have the right to object to processing based on adc77's legitimate interests, including profiling for fraud detection purposes, where you have grounds relating to your particular situation. adc77 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based solely on your consent (for example, for marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.

12 Children & Minors

If you believe that a minor has registered an adc77 account or provided Personal Data to adc77, please notify the support team immediately at [email protected]. adc77 takes underage gambling and the associated data protection concerns extremely seriously and will act without delay upon receipt of a credible report.

13 Third-Party Links

The adc77 platform does not contain links to third-party websites other than those necessary for payment processing. However, in the event that any third-party content or link appears on the platform, adc77 is not responsible for the privacy practices of those third parties. This Privacy Policy applies solely to data collected by adc77 through the adc77 platform. adc77 encourages you to review the privacy policies of any third-party services you interact with separately.

14 Amendments to This Policy

adc77 reserves the right to update this Privacy Policy at any time to reflect changes in its data processing practices, applicable law, or the Services offered on the platform. Where material changes are made, adc77 will notify registered players by email to the address associated with their account at least 7 days before the changes take effect, except where a shorter period is required to comply with a legal obligation.

The effective date at the top of this document will be updated each time the policy is revised. The most current version of this Privacy Policy will always be accessible at adc77.io/privacy-policy. Continued use of the adc77 platform after the effective date of a revised policy constitutes acceptance of the updated terms.

adc77 encourages you to review this Privacy Policy periodically. If you have any questions or concerns about a proposed or recent change, please contact the support team before the effective date so that your concerns can be addressed.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way adc77 processes your Personal Data, please contact the adc77 data support team using the details below. All privacy-related communications are handled in English.

adc77 aims to resolve all privacy-related enquiries promptly and fairly. If you are not satisfied with the response you receive, you may escalate your concern in writing to the adc77 senior compliance team at the same email address, clearly marked "Escalation — Privacy Complaint".