pa77 Privacy Policy
At pa77, protecting the personal data of every player in Bangladesh is a responsibility we take seriously. This Privacy Policy explains exactly what information we collect, why we collect it, how we use and protect it, and what rights you hold over your own data.
How pa77 Handles Your Data
The following six principles summarise pa77's approach to data privacy. They reflect the standards we hold ourselves to for every player across Bangladesh — from Dhaka to Cox's Bazar.
Minimal Data Collection
pa77 collects only the personal data that is strictly necessary to operate your Account, process transactions, fulfil identity verification requirements, and communicate with you. We do not collect data speculatively or for purposes unrelated to the provision of our gaming services.
No Sale of Personal Data
pa77 will never sell, rent, or trade your personal information to third parties for commercial marketing purposes. Your data is used exclusively to operate your Account and improve the pa77 experience. This is an absolute commitment — not a preference that changes with business conditions.
Enterprise-Grade Security
All personal data transmitted between your device and the pa77 platform is protected by 256-bit SSL encryption. Stored data is held on secured servers with access restricted to authorised personnel only. pa77 conducts rolling security audits to identify and address vulnerabilities before they can be exploited.
Your Rights, Respected
Every pa77 player holds clear rights over their personal data, including the right to access, correct, restrict processing of, and request deletion of their data. These rights can be exercised at any time by contacting pa77 support. Requests are acknowledged within 48 hours and resolved within 30 days.
Full Transparency
This Privacy Policy is written in plain English so that every player can understand how their data is handled. We do not obscure important provisions in technical language. If any part of this policy is unclear, pa77 support is available 24 hours a day to provide clarification.
Defined Retention Periods
pa77 retains personal data only for as long as it is required to fulfil the purpose for which it was collected, or as long as required by applicable law. Account data is retained for a minimum of five years following Account closure to satisfy financial record-keeping obligations. Data no longer required is securely deleted or anonymised.
Table of Contents
- Definitions and Scope
- Data Controller Information
- Personal Data We Collect
- How We Collect Your Data
- Legal Basis for Processing
- How We Use Your Personal Data
- Data Sharing and Disclosure
- Cookies and Tracking Technologies
- Data Security
- Data Retention
- Your Privacy Rights
- Children and Minors
- Third-Party Links
- Changes to This Policy
- Contact and Complaints
1 Definitions and Scope
In this Privacy Policy, the following definitions apply:
- "pa77", "we", "us", or "our" refers to the pa77 platform and its operating entity, accessible at https://pa77.io.
- "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, including name, date of birth, email address, mobile number, payment details, and IP address.
- "Player", "you", or "your" means any individual who accesses, registers on, or uses the pa77 Platform.
- "Processing" means any operation performed on Personal Data, including collection, storage, use, transmission, and deletion.
- "Third Party" means any entity other than pa77 and the Player.
- "Account" means the registered player account held on the pa77 Platform.
This Privacy Policy applies to all Personal Data collected by pa77 through the pa77 website at pa77.io, any mobile-optimised version of the Platform, and all associated services and communications. It applies to all players located in Bangladesh and to any individual whose data is processed in connection with the Platform, regardless of location.
Note: By registering an Account or continuing to use the pa77 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your Personal Data as described herein.
2 Data Controller Information
pa77 acts as the Data Controller in respect of all Personal Data collected through the Platform. This means pa77 determines the purposes and means by which your Personal Data is processed.
For all privacy-related enquiries, data subject requests, or complaints, you may contact the pa77 Data Protection point of contact using the following details:
- Email: [email protected]
- Platform: https://pa77.io
- Support Hours: 24 hours a day, 7 days a week
- Response Commitment: Acknowledgement within 48 hours; resolution within 30 calendar days
All correspondence regarding data privacy matters should reference "Privacy Request" in the subject line or opening message to ensure prompt routing to the appropriate team.
3 Personal Data We Collect
pa77 collects the following categories of Personal Data in connection with the operation of the Platform and the provision of its services:
3.1 Identity and Contact Data
- Full legal name as it appears on official identity documents
- Date of birth (for age verification — players must be 21 years or older)
- Residential address, including city (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi)
- Email address and mobile phone number
- National Identity Card (NID) number or passport number where required for KYC verification
3.2 Financial and Transaction Data
- bKash, Nagad, Rocket, or Upay mobile wallet account numbers used for deposits and withdrawals
- Bank account details (account number, bank name, branch) where bank transfer is used
- Visa or Mastercard card details (card number is tokenised — pa77 does not store raw card numbers)
- Deposit and withdrawal transaction records, including amounts in Bangladeshi Taka (৳)
3.3 Gaming Activity Data
- Bet and wager history across all sports and casino products
- Game session durations and frequency of play
- Bonus claims, wagering progress, and promotional participation records
- Account balance history and net gaming revenue data
3.4 Technical and Device Data
- IP address and approximate geographic location derived from IP
- Device type, operating system, and browser version
- Session timestamps, login history, and access logs
- Cookies and similar tracking technology data (see Section 8)
3.5 Communications Data
- Content of messages sent to pa77 support via email or live chat
- Records of promotional communications sent to you and your engagement with them
- Complaint and dispute correspondence
pa77 does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where a Player voluntarily discloses health information in connection with a responsible gaming self-exclusion request, in which case it is handled with the highest level of confidentiality.
4 How We Collect Your Data
pa77 collects Personal Data through the following channels:
- Direct Submission: Data you provide when registering an Account, completing KYC verification, making a deposit or withdrawal request, contacting support, or participating in a promotion.
- Automated Technical Collection: Data collected automatically when you access the Platform, including IP address, device identifiers, cookies, session data, and browser information.
- Third-Party Verification Providers: Identity and age verification data received from KYC service providers engaged by pa77 to confirm the accuracy of the information you have provided.
- Payment Processors: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard in connection with deposits and withdrawals.
- Game Providers: Gaming session and outcome data received from third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, as part of normal platform operation.
5 Legal Basis for Processing
pa77 processes your Personal Data on one or more of the following legal bases:
| Processing Purpose | Legal Basis |
|---|---|
| Account registration and management | Contractual necessity — required to provide the service you have requested |
| Processing deposits and withdrawals | Contractual necessity — required to fulfil financial transactions |
| Age and identity verification (KYC) | Legal obligation — required to verify the 21+ age restriction and prevent fraud |
| Fraud detection and security monitoring | Legitimate interests — protecting the integrity of the Platform and all players |
| Responsible gaming monitoring | Legitimate interests — protecting vulnerable players from gambling-related harm |
| Sending promotional communications | Consent — only where you have opted in to receive marketing communications |
| Financial record-keeping | Legal obligation — required for regulatory compliance and audit purposes |
| Improving Platform performance | Legitimate interests — using anonymised analytics to enhance the player experience |
6 How We Use Your Personal Data
pa77 uses your Personal Data for the following specific purposes:
- To create, manage, verify, and maintain your pa77 Account.
- To process deposit and withdrawal transactions via your chosen payment method, including bKash, Nagad, Rocket, and bank transfer.
- To verify your identity and age as part of mandatory KYC procedures prior to processing the first withdrawal from your Account.
- To detect and prevent fraud, money laundering, account takeover attempts, and other prohibited activities as defined in the pa77 Terms and Conditions.
- To monitor gaming activity for patterns indicative of problem gambling and to apply responsible gaming tools where appropriate.
- To communicate with you regarding your Account, including transaction confirmations, security alerts, and support responses.
- To send you promotional offers and bonus communications where you have provided consent to receive such communications. You may withdraw this consent at any time.
- To resolve disputes, complaints, and support requests.
- To comply with financial record-keeping and other legal obligations.
- To analyse aggregated, anonymised Platform usage data to improve the performance, design, and content of the pa77 service.
pa77 will not use your Personal Data for any purpose that is materially different from those listed above without providing you with prior notice and, where required by law, obtaining your consent.
7 Data Sharing and Disclosure
pa77 does not sell, rent, or trade your Personal Data. We share Personal Data with Third Parties only in the following limited circumstances:
7.1 Service Providers
pa77 engages trusted third-party service providers to assist in operating the Platform, including KYC verification providers, payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard, and partnered banks), cloud hosting providers, and customer support tools. These providers are contractually bound to process your data only on pa77's instructions and to maintain appropriate security standards.
7.2 Game Providers
In the course of normal Platform operation, limited gaming session data (such as Player ID, bet amounts, and game outcomes) is shared with third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, solely for the purpose of delivering the games you play and ensuring accurate game settlement.
7.3 Legal and Regulatory Disclosure
pa77 may disclose Personal Data to law enforcement agencies, regulatory bodies, or other government authorities where required to do so by applicable law, court order, or in connection with the investigation of suspected criminal activity including fraud and money laundering. pa77 will notify the Player of such disclosure where it is legally permitted to do so.
7.4 Business Transfers
In the event that pa77 undergoes a merger, acquisition, or sale of all or part of its assets, Personal Data held by pa77 may be transferred to the successor entity, subject to that entity agreeing to honour the commitments made in this Privacy Policy.
Absolute Prohibition: Under no circumstances will pa77 sell, share, or otherwise provide your Personal Data to third-party marketing companies, data brokers, or advertising networks. This applies regardless of the commercial value of the data or any request made by a third party.
8 Cookies and Tracking Technologies
8.1 What Are Cookies?
Cookies are small text files placed on your device by a website when you visit it. They allow the website to remember your preferences, maintain your session, and collect analytical data about how you use the site.
8.2 Cookies Used by pa77
pa77 uses the following categories of cookies on the Platform:
- Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during your visit. These cookies cannot be disabled without impairing core Platform functionality.
- Functional Cookies: Enable the Platform to remember your preferences such as language settings, display options, and last-visited game categories. These improve your experience but are not essential.
- Analytical Cookies: Used to collect aggregated, anonymised data about how players navigate and use the Platform. This data is used solely to improve Platform design and performance. pa77 does not use this data to identify individual players.
- Security Cookies: Used to detect fraud, protect against account takeover, and identify unusual or suspicious access patterns.
8.3 Managing Cookies
You can manage and delete cookies through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to log in and use the Platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation. pa77 does not use cross-site tracking cookies or third-party advertising cookies.
9 Data Security
pa77 implements a comprehensive set of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration, and destruction. These measures include:
- 256-bit SSL/TLS Encryption: All data in transit between your device and pa77 servers is encrypted using industry-standard TLS protocols.
- Data Encryption at Rest: Sensitive stored data, including payment method details and identity documents, is encrypted using AES-256 encryption at the storage level.
- Access Controls: Access to Personal Data is restricted to pa77 personnel who have a legitimate operational need to view that data. All access is logged and subject to periodic audit.
- Payment Card Tokenisation: Raw card numbers are never stored on pa77 systems. Card payment data is tokenised by our payment processor at the point of entry.
- Regular Security Audits: pa77 conducts regular internal security reviews and engages independent security assessors to conduct penetration testing and vulnerability assessments.
- Incident Response: pa77 maintains a documented data breach response procedure. In the event of a breach affecting your Personal Data, pa77 will notify you without undue delay where required by applicable law.
While pa77 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is 100% secure. You are responsible for maintaining the security of your Account credentials and for logging out of the Platform when using shared or public devices.
10 Data Retention
pa77 retains Personal Data for the periods set out in the table below, or for longer periods where required by applicable law:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account identity and contact data | 5 years after Account closure | Legal obligation (financial record-keeping) |
| KYC / identity verification documents | 5 years after Account closure | Legal obligation (anti-money laundering compliance) |
| Transaction and financial records | 7 years after transaction date | Legal obligation (financial audit requirements) |
| Gaming activity and bet history | 3 years after Account closure | Legitimate interests (dispute resolution) |
| Support and complaint correspondence | 3 years after resolution | Legitimate interests (dispute resolution) |
| Marketing preference records | Until consent is withdrawn, then deleted within 30 days | Consent |
| Technical / access log data | 12 months from collection | Legitimate interests (security monitoring) |
| Cookie / analytical data | 13 months from collection | Legitimate interests (Platform improvement) |
At the end of the applicable retention period, Personal Data is securely deleted or irreversibly anonymised such that it can no longer be associated with any individual player.
11 Your Privacy Rights
As a pa77 player, you hold the following rights in respect of your Personal Data. These rights may be exercised at any time by contacting pa77 support at [email protected]:
pa77 will acknowledge all rights requests within 48 hours and will respond substantively within 30 calendar days. Where a request is complex or involves a large volume of data, pa77 may extend this period by a further 30 days, with prior notification to the Player.
pa77 reserves the right to decline requests that are manifestly unfounded or excessive, or where fulfilling the request would conflict with a legal obligation. In such cases, pa77 will provide a written explanation of the reason for refusal.
12 Children and Minors
The pa77 Platform is strictly for adults aged 21 years and over. pa77 does not knowingly collect Personal Data from individuals under the age of 21. If pa77 discovers that Personal Data has been collected from a minor — whether through misrepresentation of age at registration or any other means — the Account will be immediately closed, all data will be deleted, and any deposited funds will be returned where legally permissible.
Parents and guardians who believe that a minor may have registered an Account on the pa77 Platform are encouraged to contact pa77 support immediately at [email protected] so that the matter can be investigated and resolved without delay.
Age Verification: pa77 uses third-party age verification tools as part of its KYC process. All players are subject to age verification before the first withdrawal is processed. pa77 may also conduct spot-check age verification on existing Accounts at any time.
13 Third-Party Links
The pa77 Platform does not contain links to third-party websites. All content and functionality accessible through the Platform is hosted and operated by pa77 or its contracted service providers under agreements that include data protection obligations.
Game provider interfaces (e.g., Pragmatic Play, Evolution Gaming, Ezugi live dealer tables) are embedded directly within the pa77 Platform environment. While these providers process limited gaming session data as described in Section 7.2, they do so under data processing agreements with pa77 and are not permitted to use that data for their own independent marketing or profiling purposes.
14 Changes to This Policy
pa77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or the way the Platform operates. Material changes — meaning changes that affect your privacy rights or the purposes for which your data is used — will be communicated to registered players via email notification and an on-Platform notice at least 14 days before the updated policy takes effect.
The "Last Updated" date at the top of this document indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how pa77 protects your data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.
15 Contact and Complaints
If you have any questions, concerns, or complaints regarding this Privacy Policy or the way pa77 handles your Personal Data, please contact the pa77 support team:
- Email: [email protected] (plain text — not a clickable link)
- Subject Line: Reference "Privacy Request" or "Data Complaint" for prompt routing
- Support Hours: 24 hours a day, 7 days a week, 365 days a year
- Acknowledgement: Within 48 hours of receipt
- Resolution Target: Within 30 calendar days
- Time Zone: Bangladesh Standard Time (BST, UTC+6)
If you are not satisfied with pa77's response to your privacy complaint, you may have the right to escalate the matter to an applicable supervisory or regulatory authority in your jurisdiction. pa77 will cooperate fully with any such authority in the investigation of a complaint.
Your Data is Safe with pa77
We are committed to keeping your personal information secure at every step. If you have questions about your privacy or want to explore what pa77 has to offer, our team is here for you around the clock.