to777 Privacy Policy — How We Handle Your Personal Data
Your privacy matters to us. This policy explains what data to777 collects, why we collect it, and how we keep it secure.
1. Introduction
to777 ("to777", "we", "us", "our") is committed to protecting the privacy and personal data of all registered players and visitors to the to777 platform. This Privacy Policy ("Policy") describes the types of personal information we collect, the purposes for which we use that information, the conditions under which we may share it, the measures we take to keep it secure, and the rights available to you in relation to your personal data. This Policy applies to all users of the to777 website and any associated services accessible through the Platform.
By registering a to777 account, using the Platform, or interacting with any of its features, you acknowledge that you have read this Policy in full and that you consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform. We encourage you to read this Policy in conjunction with our Terms and Conditions, which also govern your use of to777.
2. What Personal Data We Collect
The following categories of personal data may be collected by to777 depending on how you interact with the Platform.
Identity Data
Full name, date of birth, gender, and copies of government-issued identity documents submitted during KYC verification (e.g. National ID card, passport, or driving licence).
Contact Data
Registered mobile phone number, email address (if provided), and communication preferences. This information is used to deliver account notifications, support responses and promotional messages where you have opted in.
Payment and Transaction Data
Mobile wallet identifiers associated with bKash, Nagad, Rocket or Upay transactions (specifically the registered phone number or wallet ID used for deposit and withdrawal); transaction amounts, timestamps, and reference numbers. to777 does not store your wallet PIN, password or full payment credentials.
Gaming and Betting Activity Data
Game sessions played, bets placed, wager amounts, game outcomes, win/loss records, bonus claims, wagering progress, deposit and withdrawal history, and account balance movements. This data is used to operate the Platform, resolve disputes, detect fraud and comply with responsible gaming obligations.
Technical and Device Data
IP address, device type (mobile, tablet), operating system version, browser type and version, screen resolution, mobile network provider (e.g. Grameenphone, Robi, Banglalink, Teletalk), session start and end times, pages visited, and click-path data. This information is collected automatically via server logs and is used for security, performance monitoring, and fraud prevention.
KYC Verification Documents
Copies of identity documents, selfies or photographs submitted for age and identity verification as part of the Know Your Customer process. These documents are stored securely and are not shared except where required by law or regulation.
3. How We Use Your Personal Data
to777 uses the personal data it collects solely for legitimate, specified purposes. We do not use your data for any purpose beyond what is described in this Policy. The primary purposes for which we process your data include:
- Account registration and management: creating and maintaining your to777 account, verifying your identity, processing your login, and managing your account settings and preferences.
- Transaction processing: receiving deposits from your bKash, Nagad, Rocket or Upay wallet, crediting winnings to your account, processing withdrawal requests to your registered wallet, and maintaining accurate financial records.
- Fraud prevention and security: monitoring account activity for signs of fraud, unauthorised access, money laundering, bonus abuse, multiple-account violations, and other prohibited conduct as defined in our Terms and Conditions.
- Responsible gaming compliance: enforcing age verification (21+ requirement), applying self-exclusion and deposit limit settings, monitoring gaming patterns for indicators of problem gambling, and complying with applicable responsible gaming standards.
- Customer support: responding to your inquiries, resolving account issues, investigating complaints, and providing technical assistance via live chat or email.
- Platform improvement: analysing aggregated, anonymised usage data to identify performance issues, improve user experience, prioritise new features, and optimise the Platform for Bangladeshi mobile network conditions and device types.
- Marketing communications: sending you relevant promotional offers, bonus notifications, and Platform updates where you have consented to receive such communications. You may withdraw your marketing consent at any time by contacting support or adjusting your account notification settings.
to777 does not use automated decision-making processes that produce legal or similarly significant effects on players solely without human review. Where automated tools flag an account for potential fraud or policy breach, a member of the to777 team will review the case before any account action is taken.
4. Legal Basis for Processing Your Data
to777 processes your personal data on the following legal bases, depending on the specific processing activity:
- Contractual necessity: processing your account data, transaction data and gaming activity records is necessary to perform the contract between you and to777 — specifically, to provide the gaming and betting services you have registered to use.
- Legal obligation: processing KYC verification documents, age verification data, and transaction records is necessary to comply with applicable anti-money laundering, counter-terrorism financing and responsible gaming obligations.
- Legitimate interests: processing technical and device data for security monitoring, fraud prevention, and Platform performance optimisation. to777's legitimate interest in maintaining a secure and well-functioning platform does not override your right to privacy — we apply proportionate data collection practices.
- Consent: sending marketing communications, using non-essential cookies, and processing data for personalisation purposes where you have given your prior consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
5. Sharing Your Personal Data
to777 does not sell, rent or trade your personal data to third parties for commercial purposes. We may share your data only in the following limited circumstances:
- Service providers and technology partners: third-party vendors who support the operation of to777 — such as identity verification services, fraud detection technology providers, cloud hosting providers, and customer support platform operators — may process your data on our behalf under strict data processing agreements. These parties may only use your data as instructed by to777 and for no other purpose.
- Payment processors: your wallet identifier and transaction data are shared with bKash, Nagad, Rocket or Upay as necessary to execute your requested deposit or withdrawal. These payment providers operate under their own privacy policies and are independently responsible for the data they process.
- Law enforcement and regulatory authorities: we may disclose your personal data to police, courts, financial intelligence units or other competent authorities when required to do so by applicable law, by court order, or in connection with the investigation of suspected fraud, money laundering or other criminal activity.
- Business transfers: in the event of a merger, acquisition, restructuring or sale of all or a substantial part of to777's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the applicable privacy arrangements via the Platform.
All third parties with whom to777 shares personal data are required to implement appropriate technical and organisational security measures to protect that data. to777 does not authorise third parties to use your data for their own marketing purposes.
6. Payment Data and Mobile Wallet Providers
to777 processes deposits and withdrawals exclusively through established Bangladeshi mobile financial services — bKash, Nagad, Rocket and Upay. When you initiate a deposit or withdrawal, you are redirected to or interact with your chosen wallet provider's interface. to777 does not at any point access, store or transmit your mobile wallet PIN, password or account password. The wallet provider's own privacy policy governs the data they independently collect during any transaction initiated from their interface.
to777 retains transaction reference numbers, wallet identifiers (registered mobile numbers used for wallet transactions), transaction amounts, and timestamps as part of its financial records. This data is retained for the periods described in Section 7 of this Policy and is subject to the security measures described in Section 8.
7. Data Retention
to777 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law or regulation. The following general retention periods apply: account data and transaction records are retained for a minimum of five years following account closure to meet applicable financial record-keeping and anti-money laundering obligations; KYC verification documents are retained for a minimum of five years following account closure or the completion of the relevant verification process, whichever is later; gaming activity records are retained for a minimum of three years; technical logs are typically retained for up to 12 months unless a longer period is required for security investigation purposes.
When your personal data is no longer required for any legitimate purpose and no legal retention obligation applies, to777 will securely delete or anonymise it. You may request deletion of your personal data at any time (see Your Rights, Section 10), subject to any overriding legal retention obligations.
8. Data Security
to777 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform; encrypted storage of sensitive account and KYC data at rest; access controls limiting data access to authorised personnel only, on a need-to-know basis; regular security reviews and vulnerability assessments of Platform infrastructure; and secure deletion procedures for data that is no longer required.
While to777 takes all reasonable steps to protect your data, no internet-based system is entirely immune to security risks. In the event of a data breach that is likely to result in a significant risk to your rights and freedoms, to777 will notify affected users via the Platform and take immediate steps to contain and remediate the breach. You are also responsible for keeping your own login credentials confidential — to777 strongly recommends using a unique, strong password for your account and never sharing it with any third party.
9. Cookies and Tracking Technologies
to777 uses cookies and similar tracking technologies to operate the Platform, maintain your logged-in session, remember your preferences, and analyse aggregated usage patterns. The cookies used on to777 fall into the following categories:
- Strictly necessary cookies: these are essential for the Platform to function. They enable core functions such as session management, login state, and fraud prevention. These cookies cannot be disabled without breaking core Platform functionality.
- Functional cookies: these remember your preferences such as language selection and notification settings to provide a more personalised experience when you return to the Platform.
- Analytics cookies: these collect anonymised information about how visitors use the Platform — such as which pages are visited most frequently and how long sessions last — to help us improve the Platform. Analytics data is processed in aggregate and is not linked to individual user identities.
You may manage your cookie preferences through your mobile browser settings. Please note that disabling cookies may affect the functionality of certain Platform features. to777 does not use third-party advertising cookies or cross-site tracking technologies.
10. Your Rights Over Your Personal Data
Subject to applicable law, you have the following rights in relation to the personal data to777 holds about you. To exercise any of these rights, please contact us at [email protected] with your registered mobile number and a description of your request:
- Right of access: you may request a copy of the personal data to777 holds about you, including information about how it is being used and with whom it has been shared.
- Right to rectification: if any personal data we hold about you is inaccurate or incomplete, you may request that we correct or supplement it. Where the inaccuracy relates to your registered contact details, you should update them directly in your account settings if possible.
- Right to erasure: you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn your consent (and no other legal basis applies), or where to777 has processed your data unlawfully. This right is subject to legal retention obligations — to777 may be required to retain certain data even following an erasure request.
- Right to restrict processing: you may request that to777 restrict the processing of your data in certain circumstances — for example, while the accuracy of data you have contested is being verified, or where you have objected to processing based on legitimate interests pending to777's verification of whether its interests override yours.
- Right to data portability: where to777 processes your data based on your consent or on the performance of a contract, and the processing is carried out by automated means, you may request a copy of your data in a structured, commonly used, machine-readable format.
- Right to object: you may object at any time to the processing of your personal data for direct marketing purposes. You may also object to processing carried out on the basis of to777's legitimate interests, though to777 may continue to process your data if it demonstrates compelling legitimate grounds that override your interests.
to777 will respond to all data rights requests within 30 days of receipt. In complex cases requiring additional investigation, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it within the initial 30-day period. to777 will not charge a fee for handling data rights requests except where requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.
11. Children and Minors
The to777 platform is strictly restricted to persons aged 21 years and above. to777 does not knowingly collect, process or retain personal data relating to persons under the age of 21. The collection of data from minors is expressly prohibited, and to777 takes active steps to prevent it through age verification procedures applied at registration and throughout account use.
If to777 discovers or is informed that it has collected personal data from a person under 21, it will immediately suspend the associated account, delete the data in question (subject to any mandatory legal retention requirement), and — where a deposit has been made — arrange the return of funds to the payment source. If you believe that a person under 21 has registered an account on to777, please contact us at [email protected].
12. Third-Party Links and Services
The to777 Platform may reference third-party services such as mobile wallet providers (bKash, Nagad, Rocket, Upay) in the course of facilitating transactions. These providers operate as independent data controllers in respect of data they collect through their own interfaces. to777 is not responsible for the privacy practices of these third-party services and encourages you to review their respective privacy policies before initiating any transaction through their platforms. to777's Privacy Policy governs only the data to777 itself collects and processes.
13. Changes to This Privacy Policy
to777 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to the Platform. When we make material changes to this Policy, we will notify registered users via the Platform and update the effective date shown at the top of this page. Your continued use of the Platform after a revised Policy has been published constitutes your acceptance of the changes.
We recommend that you review this Policy periodically. The version currently displayed on this page is always the current and binding version. If you disagree with any change to this Policy, you should cease using the Platform and may request account closure by contacting to777 support.
14. Contact Us
If you have any questions about this Privacy Policy, wish to exercise any of your data rights, want to make a complaint about to777's data practices, or need to report a suspected data breach, please contact the to777 data support team. All data-related inquiries are handled by our support team and will receive a response within the timeframes stated in Section 10 of this Policy.
Email: [email protected] — Please include your registered mobile number, a summary of your query or complaint, and any relevant reference numbers in all correspondence to help us respond promptly and accurately.
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