Privacy Policy — 5777be

1 Introduction

5777be ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of every individual who interacts with its services. This Privacy Policy sets out in clear, formal terms the basis on which any personal data we collect from you — or that you provide to us — will be processed by 5777be.

This policy applies to all users of the 5777be website, mobile applications, live chat service, and any other channel through which you interact with the platform. It covers data collected during the registration process, during the active life of your account, and for the prescribed retention period following account closure.

5777be operates primarily to serve players based in Bangladesh. The platform is available in English and accepts Bangladeshi Taka (BDT) as its primary transaction currency. References to "applicable law" throughout this document are to data-protection obligations that are consistent with internationally recognised standards of data privacy, including principles of lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality.

2 Data We Collect

5777be collects personal data that falls into the following categories. We collect only the minimum data required for the purposes described in Section 4 of this policy.

5777be does not collect special-category sensitive data (such as racial or ethnic origin, religious beliefs, health data, or biometric data) unless specifically required for regulatory compliance purposes, in which case your explicit consent will be sought in advance.

3 How We Collect Your Data

5777be collects personal data through the following channels:

• Direct Submissions: Data you provide when registering an account, completing identity verification, making a deposit or withdrawal request, contacting customer support, or responding to surveys or promotions.
• Automated Technologies: Data collected automatically as you navigate the platform, including session cookies, server logs, and analytics tools. This data is collected in accordance with our Cookie Policy (Section 9).
• Payment Providers: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Visa, and Mastercard when you initiate a deposit or withdrawal. 5777be receives only the minimum data necessary to confirm and reconcile the transaction.
• Identity Verification Partners: Where you submit identity documents for KYC verification, these are processed by our secure verification system. Document images are stored only for the legally required retention period.
• Third-Party Analytics: Aggregated and anonymised usage statistics may be generated through privacy-compliant analytics tools. Individual users are not identifiable in such aggregated reports.

4 Why We Use Your Data

5777be processes personal data for the following specific, legitimate purposes. We do not use your data for any purpose that is incompatible with the reason it was originally collected.

• Account Creation and Management: To register your account, verify your identity, maintain your account profile, and provide access to platform features.
• Transaction Processing: To process deposits, settle withdrawals, issue bonus credits, and maintain an accurate transaction ledger for your account.
• Regulatory Compliance: To fulfil obligations under applicable anti-money laundering (AML) regulations, including know-your-customer (KYC) verification and suspicious transaction reporting.
• Fraud and Security: To detect, investigate, and prevent fraudulent activity, collusion, multi-accounting, chargeback abuse, and unauthorised account access.
• Responsible Gaming: To monitor play patterns that may indicate problem gambling behaviour, and to facilitate self-exclusion, deposit limits, and other responsible gaming tools at your request.
• Customer Support: To respond to your enquiries, resolve disputes, investigate complaints, and provide assistance through live chat and email.
• Platform Improvement: To analyse aggregated usage data and improve the performance, design, and feature set of the 5777be platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given explicit consent to receive such communications. You may withdraw consent at any time.

5 Legal Basis for Processing

5777be processes your personal data on one or more of the following lawful bases, depending on the nature and purpose of the processing activity:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your account, process payments, and provide access to the platform services you have requested.
• Legal Obligation: Processing is required to comply with applicable anti-money laundering, counter-terrorism financing, and related regulatory obligations that apply to the operation of an online gaming platform.
• Legitimate Interests: Processing is necessary for 5777be's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, informed, and unambiguous consent. You have the right to withdraw this consent at any time without affecting the lawfulness of prior processing.

6 Data Sharing

5777be does not sell, rent, or trade your personal data. We share personal data only in the limited circumstances described below, and only to the minimum extent required:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive transaction data necessary to process your deposits and withdrawals. Each provider operates under its own privacy framework and is independently responsible for data it holds.
• Identity Verification Services: KYC document data is shared with our verification partner solely for the purpose of confirming your identity. The partner is contractually bound to process this data for no other purpose.
• IT and Infrastructure Providers: Hosting, database, and cybersecurity service providers may have access to personal data as part of their service delivery. All such providers are bound by strict data-processing agreements.
• Regulatory and Law Enforcement Authorities: 5777be will disclose personal data to relevant authorities where required to do so by law, court order, or regulatory direction. We do not disclose data voluntarily beyond what is legally required.
• Business Transfers: In the event that 5777be undergoes a merger, acquisition, or asset sale, member data may be transferred to the successor entity. Members will be notified of any such transfer in advance.

7 International Data Transfers

5777be's primary data infrastructure is designed to serve the Bangladesh market. Where data is processed or stored on servers located outside Bangladesh — for example, by cloud infrastructure or security service providers — 5777be ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this policy.

Such safeguards include contractual data-protection clauses with all international processing partners, encryption of data in transit and at rest, and access controls that restrict processing to authorised personnel only. By using the 5777be platform, you acknowledge that your personal data may be transferred to and processed in locations outside your country of residence, subject to these protections.

8 Data Retention

5777be retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active Accounts: All personal and transaction data is retained for the full duration of your active membership with 5777be.
• Closed Accounts: Following account closure, personal data (including identity documents, transaction history, and correspondence) is retained for a minimum of five years in compliance with AML regulations. After this period, data is securely and permanently deleted.
• Marketing Data: Where you have consented to marketing communications, your contact data for this purpose is retained until you withdraw consent, at which point it is removed from all marketing systems within 14 days.
• Technical and Usage Data: Anonymised or aggregated technical data (from which no individual can be identified) may be retained indefinitely for platform improvement purposes.
• Support Records: Live chat transcripts and email correspondence are retained for two years from the date of the interaction for quality assurance and dispute resolution purposes.

9 Cookies & Tracking Technologies

5777be uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device by your browser. The following types of cookies are used:

• Essential Cookies: Necessary for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Preference Cookies: Used to remember your platform settings and preferences (such as language and display preferences) across sessions.
• Analytics Cookies: Used to collect anonymised data about how members use the platform — including pages visited, session duration, and error events. This data is used exclusively to improve the platform. Individual users are not identifiable from this data.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot activity, multi-account creation, and unusual login patterns.

5777be does not use third-party advertising or retargeting cookies. You may manage or disable non-essential cookies through your browser settings at any time. Please note that disabling essential cookies will impair your ability to use the 5777be platform.

10 Your Privacy Rights

Subject to applicable law, you hold the following rights in relation to your personal data held by 5777be. To exercise any of these rights, contact us at the email address in Section 15.

• Right of Access: You may request a copy of the personal data that 5777be holds about you. Requests will be fulfilled within 30 days.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data. Corrections to identity data may require supporting documentation.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal retention obligations (see Section 8).
• Right to Restrict Processing: You may request that 5777be restrict its processing of your data in certain circumstances — for example, while a dispute is being resolved.
• Right to Data Portability: You may request a structured, machine-readable copy of the personal data you provided to 5777be, for the purpose of transferring it to another service.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes. Marketing communications will cease immediately upon receipt of a valid objection.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

11 Children's Privacy

The 5777be platform is strictly intended for adults aged 18 years and above. 5777be does not knowingly collect personal data from individuals under the age of 18. Age verification is conducted as a mandatory part of the account registration process, and enhanced checks are performed before any withdrawal is processed.

If 5777be becomes aware that it has inadvertently collected personal data from a person under the age of 18, it will immediately suspend the relevant account, delete the personal data concerned, and — where applicable — report the matter to the appropriate responsible gaming authority. If you believe that a minor may have created an account on the platform, please notify us at [email protected] without delay.

12 Security Measures

5777be implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Key security measures include:

• Transport Layer Security: All data transmitted between your device and the 5777be platform is encrypted using TLS 1.2 or higher (256-bit SSL).
• Data Encryption at Rest: Sensitive data fields — including identity document references and financial account identifiers — are encrypted within the 5777be database.
• Access Controls: Internal access to personal data is governed by role-based access controls. Only staff with a documented operational need may access member data, and all such access is logged and auditable.
• Two-Factor Authentication: 5777be's internal systems require multi-factor authentication for all staff who can access member data. Members are strongly encouraged to enable 2FA on their own accounts.
• Intrusion Detection: Real-time monitoring and automated intrusion detection systems are in operation 24/7 to identify and respond to anomalous activity.
• Security Testing: 5777be conducts regular vulnerability assessments and security reviews of its platform infrastructure.

While 5777be takes all reasonable steps to protect your data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 5777be will notify affected members without undue delay and will take all necessary remedial action.

13 Third-Party Links

The 5777be platform may, from time to time, reference third-party service providers such as payment partners (bKash, Nagad, Rocket, Upay, Visa, Mastercard) in the context of payment processing. Such references are operational in nature and do not constitute endorsement of those parties' privacy practices.

If you navigate away from the 5777be platform to a third-party website or application, 5777be has no control over and accepts no responsibility for the data-collection practices, content, or privacy policies of those third parties. You should review the privacy policy of any third-party service before submitting personal data to it.

14 Amendments to This Policy

5777be reserves the right to update or revise this Privacy Policy at any time. Where changes are material — meaning they significantly affect your rights or how your data is used — 5777be will notify registered members by email and will display a prominent notice on the platform at least 7 days before the revised policy takes effect.

Minor clarifications or administrative updates that do not materially affect member rights may be made without advance notice. The effective date at the top of the policy will always reflect the version currently in force. Your continued use of the 5777be platform following the effective date of any revision constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this page periodically to stay informed about how 5777be is protecting your information. The most current version of this policy is always accessible via the footer of every page on the platform.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a complaint about how 5777be has handled your personal data, please contact us using the details below:

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate.
• Live Chat: Available 24 hours a day, 7 days a week, from any page on the 5777be platform.
• Response Time: All privacy-related enquiries will receive an initial acknowledgement within one business day and a full response within 30 calendar days.

5777be takes all privacy complaints seriously. If you submit a complaint and are not satisfied with our response, you have the right to escalate the matter to an appropriate supervisory authority or data protection body in your jurisdiction.