Your Privacy Is Our
Top Priority

Section 01

Introduction & Scope

This Privacy Policy ("Policy") describes how ef77 ("ef77", "we", "us", "our") collects, processes, stores, and protects the personal data of individuals ("you", "Player", "User") who access or use the ef77 online betting and casino platform, available at https://ef77.io and all associated subdomains, mobile interfaces, and applications (collectively, the "Platform").

ef77 is committed to protecting the privacy and personal data of all players, with particular attention to the standards expected by Bangladeshi users who form the primary audience of this Platform. This Policy has been drafted in clear, professional English and is binding upon all registered and unregistered visitors to the Platform.

By accessing the Platform, creating an account, or making a deposit, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. This Policy should be read in conjunction with ef77's Terms and Conditions and Responsible Gaming Policy, both of which are published on the Platform.

If you do not agree to the terms of this Policy, you must discontinue use of the Platform immediately and may request closure of your account by contacting our support team.

Section 02

Data We Collect

ef77 collects personal data through several channels in the ordinary course of operating the Platform. The categories of data we collect are as follows:

2.1 — Registration & Account Data

When you create an ef77 account, we collect the information you provide during the registration process, including:

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Residential address (including district, division, and postal code)
• Email address
• Mobile telephone number
• Preferred username and an encrypted record of your password

2.2 — Identity Verification (KYC) Data

To comply with age verification and anti-money-laundering obligations, ef77 may request:

• A copy of your National Identity Card (NID), Passport, or Driving Licence
• A recent proof of address document (bank statement, utility bill, or government correspondence)
• Proof of ownership of the payment account used to make deposits (e.g., a screenshot of your bKash or Nagad account registration)

2.3 — Financial Transaction Data

• Deposit and withdrawal amounts, dates, and transaction reference numbers
• Payment method identifiers (e.g., the registered mobile number associated with your bKash or Nagad account, masked card numbers for Visa/Mastercard transactions)
• Account balance history

2.4 — Gameplay & Betting Data

• Bet history, game round records, and wagering activity
• Casino game session data (game titles accessed, stakes, outcomes, session duration)
• Sports betting selections, odds accepted, and settlement records

2.5 — Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Unique device identifiers
• Session timestamps, login and logout records
• Referring URL and on-site navigation path data

2.6 — Communications Data

• Records of live chat and email support interactions
• Formal complaint records and their resolutions
• Responses to surveys or promotional competitions (where applicable)

Section 03

How We Use Your Data

ef77 uses the personal data we collect solely for legitimate, defined purposes. The table below summarises these purposes and the data categories involved:

ef77 does not use your personal data for automated decision-making that produces legal or similarly significant effects on your rights without human review. Where profiling is used for responsible gaming monitoring purposes, it operates only to identify patterns that may indicate problem gambling behaviour, and any action taken as a result is reviewed by a human member of our responsible gaming team.

Section 04

Legal Bases for Processing

ef77 processes your personal data on the following legal bases, depending on the purpose of the processing activity:

• Contractual Necessity: Processing your registration data, financial transaction data, and gameplay data is necessary to perform the contract between you and ef77 (i.e., to operate your account and deliver the services you have requested).
• Legal Obligation: Processing KYC documents, transaction records, and certain account data is required to comply with anti-money-laundering obligations, age verification requirements, and other applicable legal duties.
• Legitimate Interests: Processing technical and device data for fraud prevention, platform security monitoring, and performance analytics is carried out on the basis of ef77's legitimate interests in maintaining a secure and well-functioning platform — provided these interests are not overridden by your privacy rights.
• Consent: Processing your contact details for the purpose of sending promotional emails, SMS notifications, or WhatsApp marketing messages is based on your freely given, specific, and informed consent at the time of opt-in. You may withdraw this consent at any time.

Section 05

Cookies & Tracking Technologies

ef77 uses cookies and similar tracking technologies on the Platform to enable core functionality, improve your user experience, and gather anonymised analytics data. The types of cookies we use are described below:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable your login session to be maintained, your account preferences to be remembered, and security protections to operate correctly. These cookies cannot be disabled without materially impairing Platform functionality.
• Functional Cookies: These cookies remember your preferred language, display settings, and other personalisation choices to provide a more consistent experience across visits.
• Analytics Cookies: We use anonymised analytics data to understand how players navigate the Platform, which pages are most visited, and where technical issues arise. This data helps us improve the Platform experience for all users. Analytics data is aggregated and does not identify individual players.
• Security Cookies: These cookies support fraud detection and account security functions, such as identifying unusual login patterns or detecting access from Prohibited Territories.

By continuing to use the Platform after being presented with our cookie notice, you consent to our use of cookies as described in this section. You may update your cookie preferences at any time via your browser settings.

Section 06

Third-Party Data Sharing

ef77 does not sell your personal data to any third party. We share personal data with third parties only in the following defined circumstances, and only to the extent necessary for the stated purpose:

• Payment Processors: To process your bKash, Nagad, Rocket, Upay, Visa, Mastercard, and bank transfer transactions, we share the minimum required financial and identity data with our authorised payment processing partners. These partners operate under strict data processing agreements and are required to maintain the security and confidentiality of your data.
• Game Studio Providers: When you access casino games or live dealer products powered by third-party studios (including Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, Microgaming, and Spribe), a session token and anonymised player identifier are passed to the relevant game server to facilitate your gameplay. Game providers do not receive your full name, contact details, or financial data.
• Identity Verification Services: Where ef77 uses a third-party KYC verification service to confirm the authenticity of your submitted identity documents, your document images and basic registration data are shared with that provider solely for verification purposes.
• Legal and Regulatory Authorities: ef77 may disclose personal data to law enforcement agencies, regulatory bodies, or government authorities where required to do so by applicable law, court order, or in connection with the investigation of fraud, money laundering, or other criminal activity.
• Corporate Successors: In the event of a merger, acquisition, or sale of ef77's business or assets, player data may be transferred to the successor entity, subject to equivalent privacy protections being maintained. Affected players will be notified in advance.

All third-party service providers who receive personal data from ef77 are bound by contractual obligations to process that data only for the stated purpose, to maintain appropriate technical and organisational security measures, and to comply with applicable data protection standards.

Section 07

Payment Data & Financial Security

ef77 applies a heightened level of protection to all financial and payment-related data. The following security measures and data handling practices apply to payment information:

• ef77 does not store full payment card numbers on its own servers. Card transactions are processed through a PCI-DSS-compliant payment gateway, and only a masked card reference (e.g., the last four digits) is retained for your transaction history.
• Mobile financial service transaction data (bKash, Nagad, Rocket, Upay) is stored in encrypted form. Only the registered mobile number associated with the payment account is retained as a transaction identifier.
• Bank account details submitted for withdrawal purposes are encrypted at rest and are accessible only to authorised members of ef77's finance team for the purpose of processing the specific withdrawal request.
• All financial transaction records are retained in encrypted format for a minimum retention period required for AML compliance and audit purposes (see Section 08 — Data Retention).

Section 08

Data Retention

ef77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or compliance obligations. The following retention guidelines apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard data destruction methods. Where data is anonymised rather than deleted, it may be retained indefinitely for aggregate analytical purposes as it can no longer be linked to any identifiable individual.

If you request deletion of your data (see Section 09 — Your Rights), ef77 will action that request promptly, subject to any legal retention obligations that prevent immediate deletion of specific data categories.

Section 09

Your Rights

As a data subject whose personal data is processed by ef77, you hold the following rights in relation to your personal data. ef77 is committed to honouring these rights promptly and without undue friction:

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Rights Request — [Your Account Username]". ef77 will acknowledge your request within 48 hours and provide a substantive response within 10 business days. In some cases, we may need to verify your identity before actioning a rights request in order to protect the security of your account data.

Section 10

Children & Minors

ef77 is a real-money gambling platform intended exclusively for adults. Access to the Platform is strictly prohibited for any person under the age of 21. ef77 does not knowingly collect, store, or process the personal data of individuals under the age of 21.

During registration, all applicants are required to confirm that they are aged 21 or above and to provide a date of birth. Where ef77 has reasonable grounds to suspect that a registered player may be under the age of 21, we reserve the right to suspend that account immediately and request identity verification documents to confirm the player's age. If verification confirms that the account holder is a minor, the account will be permanently closed, any funds deposited will be returned to the originating payment method, and all associated personal data will be securely deleted.

Parents and guardians are encouraged to make use of parental control software to prevent minors from accessing online gambling platforms. ef77 supports and endorses responsible use of such tools as part of our broader commitment to player safety.

Section 11

Responsible Gaming & Data

ef77 takes responsible gaming seriously and uses certain personal data — specifically gameplay history, deposit frequency, session duration, and wagering patterns — to monitor for signs of problem gambling behaviour. This monitoring is conducted in the interests of player safety and welfare and forms part of our responsible gaming obligations.

Where our responsible gaming systems identify a pattern of behaviour that may indicate harmful gambling, a member of our dedicated responsible gaming team may proactively contact the affected player via email or live chat to offer support, information, and access to self-management tools, including deposit limits, session time limits, cooling-off periods, and self-exclusion.

Data collected and processed for responsible gaming purposes is handled with the strictest confidentiality. It is not shared with third parties except where required by law, and it is never used for marketing or commercial profiling purposes. Self-exclusion records are retained for the duration of the exclusion period plus five years to ensure compliance and prevent inadvertent re-registration.

For more information about ef77's responsible gaming tools and support resources, please visit our Responsible Gaming page.

Section 12

International Data Transfers

ef77 operates a platform that serves players primarily based in Bangladesh. However, certain of our technology infrastructure components, third-party game providers, and payment processing partners operate servers or data centres located outside Bangladesh. As a result, your personal data may be transferred to, stored in, or processed in countries other than Bangladesh.

Where such international data transfers occur, ef77 takes appropriate steps to ensure that your personal data receives an equivalent level of protection to that afforded under applicable data protection standards. These steps may include:

• Executing data processing agreements with all third-party recipients that include binding data protection obligations
• Transferring data only to service providers who maintain internationally recognised security certifications (such as ISO 27001 or SOC 2 compliance)
• Applying encryption to data in transit and at rest, regardless of the jurisdiction in which processing occurs

By using the ef77 Platform and submitting your personal data, you acknowledge and consent to such international transfers taking place as described in this section.

Section 13

Security Measures

ef77 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our key security measures include:

• SSL/TLS Encryption: All data transmitted between your browser or device and ef77's servers is encrypted using industry-standard SSL/TLS protocols. Look for the padlock icon and "https://" prefix in your browser's address bar when using the Platform.
• Encrypted Data Storage: Sensitive personal data, including identity documents and financial records, is stored in encrypted database systems. Encryption keys are managed under strict access control policies.
• Access Controls: Access to personal data within ef77's internal systems is restricted to authorised personnel on a strictly need-to-know basis. All staff with access to personal data receive regular data protection training and are bound by confidentiality obligations.
• Two-Factor Authentication: ef77 supports and encourages players to enable two-factor authentication (2FA) on their accounts as an additional layer of protection against unauthorised access.
• Fraud Detection Systems: Automated monitoring systems operate continuously to detect and flag unusual account activity, including atypical login patterns, unusual transaction volumes, and potential account takeover attempts.
• Regular Security Reviews: ef77 conducts periodic internal security assessments to identify and remediate vulnerabilities in our Platform and data handling practices.

In the unlikely event of a data breach that poses a risk to your personal data, ef77 will notify affected players promptly and take all necessary steps to contain the breach, assess its impact, and prevent recurrence.

Section 14

Changes to This Policy

ef77 reserves the right to update, revise, or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or business operations. When material changes are made to this Policy, ef77 will take the following steps to ensure players are informed:

• The updated Policy will be published on the Platform with a revised "Last Updated" date at the top of the document.
• A notice will be displayed on the Platform's homepage or login page alerting players to the fact that the Privacy Policy has been updated.
• Where changes are particularly significant — such as new categories of data being collected or a material change in how data is shared with third parties — ef77 will send a direct notification to all registered players via email prior to the changes taking effect.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should discontinue use of the Platform and may request closure of your account by contacting our support team.

ef77 recommends that players review this Policy periodically to stay informed of how their personal data is being handled. The version history of this Policy is maintained internally and is available upon request.

Section 15

Contact & Data Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way ef77 handles your personal data, please do not hesitate to contact our support team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: Use "Privacy Enquiry — [Your Account Username]" or "Data Rights Request — [Your Account Username]" as applicable.
• WhatsApp: +880 1700 000000 (plain text — not a clickable link)
• Support Hours: 24 hours a day, 7 days a week, 365 days a year.
• Response Time: ef77 aims to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive written response within 10 business days.

ef77 values the trust our players place in us to handle their personal data responsibly. We are committed to maintaining the highest standards of data protection and to being transparent, responsive, and accountable in all matters relating to your privacy.