zc77 Privacy Policy
— How We Protect and Handle
Your Personal Data

1. About This Privacy Policy

This Privacy Policy ("Policy") describes how zc77 ("the Company", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of individuals ("you", "your", "Player", "User") who visit or use the zc77 platform, including the website at zc77.ws, mobile web interfaces, live chat support, promotional communications, and all associated services.

This Policy should be read alongside the zc77 Terms & Conditions, which are available at zc77.ws/terms-conditions. In the event of any conflict between this Policy and the Terms & Conditions regarding data privacy matters, this Privacy Policy shall take precedence.

By registering an account on the zc77 platform, making a deposit, or continuing to use our services, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the zc77 platform.

This Policy applies to all players and users located in Bangladesh and is written in English, which is the governing language of this document. Where translations are made available for convenience, the English version shall always take precedence in the event of any discrepancy.

2. Personal Data We Collect

We collect different categories of personal data depending on how you interact with the zc77 platform. The table below sets out the main categories of data we collect and provides examples of the specific data points within each category.

Category	Examples of Data Collected
Identity Data	Full legal name, date of birth, National ID number, passport number, photograph (selfie with ID)
Contact Data	Email address, mobile phone number, residential address (including district, division, and postal code in Bangladesh)
Financial Data	bKash / Nagad / Rocket / Upay wallet numbers, bank account references, deposit and withdrawal history, transaction amounts in BDT (৳)
Account Data	Username, encrypted password, account registration date, account status, self-exclusion flags, responsible gaming settings
Gaming & Betting Data	Game history, bet amounts, win/loss records, session duration, wager patterns, bonus and promotion usage
Technical Data	IP address, browser type and version, device type and operating system, screen resolution, referring URL, session timestamps
Communications Data	Live chat transcripts, email correspondence, WhatsApp messages sent to our support number, feedback and complaint submissions
Marketing Preferences	Email and SMS marketing opt-in/opt-out status, preferred communication channel, promotional campaign responses

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, or health data, except where the collection of health or vulnerability information is directly relevant to responsible gaming assessments and is provided voluntarily by the player.

3. How We Collect Your Data

3.1 Data You Provide Directly

The majority of the personal data we hold is provided directly by you during the course of your relationship with zc77. This includes data you submit when creating an account, completing KYC identity verification, making a deposit or withdrawal, contacting customer support, opting into a promotion, or responding to a survey.

3.2 Data Collected Automatically

When you access the zc77 platform, we automatically collect certain technical and usage data through server logs, cookies, web beacons, and similar technologies. This data helps us understand how players navigate the platform, identify and resolve technical issues, and detect fraudulent or suspicious activity patterns. For more detail on cookies, see Section 6.

3.3 Data from Third Parties

We may receive personal data about you from third parties in the following circumstances:

• Payment processors (such as bKash, Nagad, Rocket, and Upay) may confirm transaction completion, flag disputed transactions, or provide wallet ownership verification data.
• KYC and identity verification partners may provide results of document authenticity checks and liveness verification against the identity documents you submit.
• Fraud prevention and AML screening services may flag your name, email address, or payment method against known risk databases.
• Game studio providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may share game session data and bet records with us for auditing and dispute resolution purposes.

4. Legal Basis for Processing

We process your personal data only where we have a valid legal basis to do so. The primary legal bases on which zc77 relies are as follows:

• Contractual necessity: Processing your identity, contact, financial, and account data is necessary to perform the contract between you and zc77 — specifically, to operate your account, process your transactions, and deliver the gaming and betting services you have requested.
• Legal obligation: We are required to collect and retain certain data — particularly identity documents and transaction records — to comply with anti-money laundering (AML) obligations and other applicable regulatory requirements.
• Legitimate interests: We process technical and usage data on the basis of our legitimate interests in operating a secure, fraud-free platform, improving our services, and detecting and preventing prohibited conduct. We balance these interests against your privacy rights when determining the scope of this processing.
• Consent: Where we rely on consent — for example, for sending marketing emails or SMS messages — you may withdraw that consent at any time by contacting [email protected] or by following the unsubscribe instructions in any marketing communication. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To create and manage your zc77 account and verify your identity in accordance with our KYC requirements
• To process deposits and withdrawals through your preferred Bangladeshi payment method (bKash, Nagad, Rocket, Upay, or bank transfer)
• To deliver customer support via live chat, email at [email protected], or WhatsApp
• To detect, investigate, and prevent fraud, money laundering, multi-accounting, bonus abuse, and other forms of prohibited conduct
• To fulfil our responsible gaming obligations, including monitoring gaming patterns, enforcing self-exclusions, and applying deposit limits where requested or required
• To send you transactional communications relating to your account, such as deposit confirmations, withdrawal notifications, and security alerts
• To send you promotional and marketing communications about zc77 bonuses, events, and new game releases, where you have consented to receive such communications
• To analyse aggregate, anonymised usage data for the purpose of improving platform performance, user experience, and game selection
• To comply with applicable legal obligations, respond to lawful requests from authorities, and enforce our Terms & Conditions

6. Cookies and Tracking Technologies

The zc77 platform uses cookies and similar tracking technologies to provide a functional, secure, and personalised experience. A cookie is a small text file stored on your device by your browser when you visit a website. We use the following types of cookies:

• Essential cookies: Required for the platform to function. They enable you to log in, maintain your session, navigate between pages, and access secure areas of the site. These cookies cannot be disabled without impairing the core functionality of the platform.
• Functional cookies: Remember your preferences, such as your chosen language settings, and help personalise your experience on the zc77 platform across sessions.
• Analytics cookies: Collect anonymised data about how users interact with the platform — such as which pages are visited most frequently, how long sessions last, and where users encounter errors — to help us improve the platform over time.
• Security cookies: Used to detect and prevent fraudulent activity, identify suspicious login attempts, and protect your account from unauthorised access.

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the zc77 platform. For detailed guidance on managing cookies in your specific browser, refer to your browser's help documentation.

7. Sharing Your Personal Data

zc77 does not share your personal data with third parties except in the following limited circumstances, all of which are subject to appropriate contractual data protection obligations:

7.1 Service Providers and Data Processors

We engage carefully selected third-party service providers who process personal data on our behalf in order to deliver platform services. These include:

• Payment processing partners (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, and other Bangladeshi banking partners) for the execution of deposits and withdrawals
• KYC and identity verification partners who authenticate identity documents submitted during account verification
• AML and fraud screening providers who cross-reference account data against financial crime risk databases
• Game studio partners (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) for the delivery of casino game content and for audit and dispute resolution purposes
• Cloud hosting and IT infrastructure providers who store and process platform data on secure servers
• Customer support platform providers who facilitate live chat and email support functionality

All service providers acting as data processors on our behalf are required to process personal data only on our documented instructions and to maintain appropriate technical and organisational security measures.

7.2 Legal and Regulatory Disclosure

We may disclose personal data to law enforcement agencies, regulatory authorities, courts, or other public bodies where we are legally required to do so, or where such disclosure is necessary to protect the rights, property, or safety of zc77, our players, or the public. We will notify affected players of such disclosures where we are legally permitted to do so.

7.3 Business Transfers

In the event that zc77 undergoes a merger, acquisition, restructuring, or sale of all or part of its assets, personal data held about players may be transferred to the acquiring entity as part of that transaction. We will notify players of any such transfer and of any changes to this Privacy Policy that result from it, with reasonable advance notice.

8. International Data Transfers

Some of the third-party service providers engaged by zc77 — including game studio partners and cloud infrastructure providers — may be located outside of Bangladesh. Where personal data is transferred to countries that may not offer the same level of data protection as Bangladesh, we take steps to ensure that appropriate safeguards are in place, including contractual data protection clauses that require the recipient to process your data to a standard equivalent to that applied by zc77.

By using the zc77 platform, you acknowledge that your personal data may be processed in countries outside Bangladesh for the purposes described in this Policy.

9. Data Retention

We retain your personal data for as long as is necessary to fulfil the purposes for which it was collected, including the satisfaction of any legal, accounting, or reporting obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a period of five (5) years following account closure, in accordance with our AML record-keeping obligations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Game and betting history: Retained for the duration of your account and for two (2) years following account closure, for audit and dispute resolution purposes.
• Communications data (support records): Retained for two (2) years from the date of the last communication, unless a longer period is required to resolve an outstanding complaint or legal matter.
• Technical and usage data: Typically retained in anonymised or aggregated form for up to two (2) years for analytics purposes.
• Marketing preference records: Retained until you withdraw your consent or request deletion, and for a short period thereafter to document the withdrawal.

When personal data is no longer required, it is securely deleted or anonymised so that it can no longer be linked to an identified individual.

10. Security Measures

zc77 takes the security of your personal data seriously and implements a range of technical and organisational measures to protect it against unauthorised access, accidental loss, alteration, or disclosure. Our key security measures include:

• SSL/TLS encryption for all data transmitted between your device and the zc77 platform
• Encryption of sensitive data fields (including passwords and financial identifiers) stored in our databases
• Role-based access controls that restrict internal access to personal data to authorised team members on a strict need-to-know basis
• Regular security assessments and penetration testing of the zc77 platform infrastructure
• Two-factor authentication (2FA) options available to players to secure their accounts
• Monitoring systems for detecting unusual login patterns, suspicious transactions, and potential data breaches

Notwithstanding these measures, no method of data transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially reasonable means to protect your personal data, we cannot guarantee its absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify affected players without undue delay.

11. Your Privacy Rights

As a player on the zc77 platform, you have the following rights with respect to your personal data. To exercise any of these rights, please submit a written request to [email protected]. We will acknowledge your request within two (2) business days and provide a substantive response within thirty (30) days.

• Right of access: You have the right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you. For account details, you can update many fields directly within your account settings.
• Right to erasure: You have the right to request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Note that we may be unable to delete data that we are legally required to retain.
• Right to restrict processing: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or where you have objected to processing and we are considering that objection.
• Right to data portability: You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, where processing is carried out by automated means on the basis of your consent or a contract.
• Right to object: You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis, and where your individual circumstances mean that the processing has a disproportionate impact on your privacy.
• Right to withdraw consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

We will not charge a fee for handling data rights requests unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable administrative fee or decline to act on the request.

12. Children and Minors

The zc77 platform is strictly for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that a registered player is under 21 years of age, we will immediately suspend the account, void any associated winnings, and delete all personal data associated with that account to the extent permitted by our legal retention obligations.

If you believe that a minor may have registered on the zc77 platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action. We take our responsibility to prevent underage gambling very seriously and cooperate fully with parents and guardians who raise concerns about minors accessing online gambling platforms.

13. Changes to This Privacy Policy

zc77 reserves the right to update 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, we will post an updated version of the Policy at zc77.ws/privacy-policy and update the "Last Updated" date at the top of the document.

For significant changes that materially affect how we process your personal data, we will notify registered players by email to the address on file prior to the changes taking effect, where practicable. Your continued use of the zc77 platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you must cease using the platform and contact us to close your account.

14. Contact and Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way zc77 handles your personal data, please contact our data privacy team using the details below. All communications should be made in English to ensure accurate handling and a timely response.

• Privacy Enquiries: [email protected]
• General Support: [email protected]
• Response Time: We aim to acknowledge all privacy-related enquiries within two (2) business days and provide a full response within thirty (30) calendar days.
• WhatsApp Support: +880 1XXX-XXXXXX (09:00–24:00 BST, for general enquiries only — do not send sensitive documents via WhatsApp)

If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the relevant data protection authority or to seek independent legal advice. zc77 is committed to resolving all privacy complaints fairly and in good faith.