37j77 Privacy Policy

1. Data We Collect

37j77 collects personal data that is necessary for the operation of our platform, the provision of our Services, and compliance with our legal and financial obligations. We do not collect personal data beyond what is reasonably required for these purposes. The categories of personal data we collect are set out below.

1.1 Registration Data

When you create a 37j77 account, we collect the information you provide directly, including:

• Full legal name;
• Date of birth (to verify you are aged 18 or above);
• Residential address (including city, e.g., Dhaka, Chittagong, Sylhet, Khulna);
• Email address;
• Bangladesh mobile number;
• Username and password (passwords are stored in encrypted, hashed form — we never store plain-text passwords).

1.2 Identity Verification (KYC) Data

To satisfy our Know Your Customer (KYC) obligations and to protect the integrity of the platform, we may collect:

• Government-issued photo identification (National ID card, passport, or driving licence);
• Proof of residential address (utility bill or bank statement dated within 3 months);
• Selfie or live photograph for identity confirmation;
• Proof of payment method ownership (e.g., screenshot of your bKash or Nagad account showing your registered mobile number).

1.3 Financial Transaction Data

When you make deposits or withdrawals, we collect and retain records of:

• Payment method type (bKash, Nagad, Rocket, Upay, Visa, Mastercard, bank transfer);
• Transaction reference numbers and timestamps;
• Deposit and withdrawal amounts in BDT (৳);
• Account balance history for audit and compliance purposes.

37j77 does not store full card numbers or mobile wallet PINs. Payment method tokenisation is handled by our payment processing partners.

1.4 Usage and Behavioural Data

As you use the 37j77 platform, we automatically collect technical and behavioural data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Pages visited, session duration, and navigation patterns;
• Games played, wagers placed, bet amounts, and game outcomes;
• Login timestamps and frequency of platform access.

1.5 Communications Data

If you contact our customer support team — via live chat, email, or WhatsApp — we retain records of those communications, including the content of messages, the date and time of contact, and the resolution of your enquiry. This data is used for quality assurance, dispute resolution, and training purposes.

2. How We Use Your Data

37j77 uses the personal data we collect for specific, clearly defined purposes. We do not use your data for purposes beyond those listed below without providing you with prior notice and, where required, obtaining your explicit consent.

2.1 Marketing Communications

If you have opted in to receive marketing communications during registration or at any later point, 37j77 may send you emails or platform notifications regarding promotions, bonuses, seasonal offers (such as BPL cricket season promotions, Eid offers, or Pohela Boishakh specials), and new game launches. You may withdraw consent for marketing communications at any time by updating your notification preferences in your account settings or by contacting support at [email protected].

Withdrawal of marketing consent does not affect the lawfulness of processing carried out prior to the withdrawal, and does not affect our ability to send you service-related communications (e.g., account security alerts, transaction confirmations, or policy update notifications).

3. Legal Basis for Processing

37j77 processes your personal data on one or more of the following legal bases, depending on the specific purpose of processing:

• Contract Performance: Processing is necessary to fulfil our contractual obligations to you as a registered player — including account management, payment processing, and delivery of gaming services.
• Legal Obligation: Processing is required to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, age verification obligations, and financial record-keeping standards.
• Legitimate Interest: Processing is necessary for our legitimate business interests — such as fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your fundamental privacy rights.
• Consent: For certain non-essential processing activities (such as marketing communications and non-essential cookies), we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time.

4. Cookies & Tracking Technologies

4.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device on subsequent visits, remember your preferences, and gather analytical data about how you use the platform. 37j77 uses cookies and similar tracking technologies (including local storage, session storage, and pixel tags) across our platform.

4.2 Types of Cookies We Use

4.3 Managing Your Cookie Preferences

Strictly necessary cookies cannot be disabled as they are essential to the functioning of the 37j77 platform. For all other cookie categories, you may update your preferences at any time through the Cookie Settings panel accessible in your account settings. You may also manage cookies through your browser settings — most modern browsers allow you to view, block, or delete cookies. Please note that disabling certain functional or analytical cookies may affect your experience on the platform.

5. Third-Party Data Sharing

37j77 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share your data only in the limited circumstances described below, and only with parties who are bound by appropriate contractual data protection obligations.

5.1 Payment Processing Partners

To process deposits and withdrawals, 37j77 shares the minimum necessary financial and identity data with our licensed payment processing partners, including operators of bKash, Nagad, Rocket, Upay, and card payment gateways. These partners process your data solely for the purpose of executing your requested transaction and are prohibited from using your data for any other purpose.

5.2 Game Software Providers

37j77's casino games are powered by internationally accredited game suppliers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. When you play a game provided by one of these suppliers, certain technical data (such as your anonymised player ID, session token, and game interaction data) is transmitted to the relevant provider for the purpose of game delivery, RNG certification compliance, and technical support. Game providers do not receive your full name, address, or payment method details.

5.3 Analytics and Platform Technology Providers

37j77 may use third-party analytics and platform technology tools to monitor platform performance, detect security threats, and improve user experience. These providers act as data processors on our behalf and are bound by strict data processing agreements that prohibit them from using your data for independent purposes.

5.4 Legal and Regulatory Disclosure

37j77 may disclose your personal data to law enforcement agencies, financial intelligence units, or other regulatory bodies where we are required to do so by law, or where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or other illegal activity. We will notify you of any such disclosure where we are legally permitted to do so.

5.5 Business Transfers

In the event that 37j77 undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified in advance of any such transfer and of any material changes to how your data is processed as a result.

6. Data Security

37j77 takes the security of your personal data seriously and implements a layered set of technical and organisational measures designed to protect your information against unauthorised access, accidental loss, destruction, or disclosure.

6.1 Technical Security Measures

• SSL/TLS Encryption: All data transmitted between your device and the 37j77 platform is encrypted using industry-standard SSL/TLS protocols. Look for the padlock icon in your browser's address bar when accessing 37j77.app.
• Password Hashing: Account passwords are stored using strong one-way cryptographic hashing algorithms. 37j77 staff cannot view your password in plain text — ever.
• Access Controls: Access to personal data within 37j77's internal systems is restricted on a strict need-to-know basis. All internal access is logged and audited.
• Intrusion Detection: 37j77 employs automated monitoring systems to detect and respond to suspicious access attempts, unusual login patterns, and potential data breaches in real time.
• Payment Tokenisation: Full payment method details (card numbers, mobile wallet PINs) are never stored on 37j77's servers. Payment data is tokenised by our PCI-compliant payment processors.

6.2 Organisational Security Measures

• All 37j77 staff who handle personal data are subject to confidentiality obligations and receive regular data protection training;
• Third-party data processors are vetted and bound by contractual data security obligations before being granted access to any player data;
• 37j77 maintains an incident response plan to ensure that any confirmed data breach is investigated promptly and that affected players are notified without undue delay.

6.3 Your Role in Account Security

While 37j77 implements robust security measures on our end, the security of your account also depends on the steps you take to protect your login credentials. We strongly recommend that you use a strong, unique password for your 37j77 account, do not share your login details with anyone, log out of your account when using shared devices, and contact [email protected] immediately if you suspect unauthorised access to your account.

7. Data Retention

37j77 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 legal and financial record-keeping obligations. The key retention periods applicable to your data are set out below.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised so that it can no longer be attributed to you as an individual. Where data is anonymised rather than deleted, it may be retained for statistical and analytical purposes indefinitely, as anonymised data no longer constitutes personal data.

8. Your Privacy Rights

As a 37j77 player, you hold a number of rights with respect to your personal data. 37j77 is committed to honouring these rights promptly and without unnecessary barriers. To exercise any of the rights described below, please contact our data support team at [email protected] with the subject line "Privacy Rights Request".

8.1 Right of Access

You have the right to request a copy of the personal data that 37j77 holds about you. We will provide this in a structured, readable format within 30 days of receiving your verified request. We may ask you to confirm your identity before processing a data access request to ensure that we do not disclose your personal data to an unauthorised party.

8.2 Right to Rectification

If any personal data that 37j77 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update certain account details (such as your contact number or email address) directly through your account settings. For changes to core identity data (such as legal name or date of birth), please contact customer support and provide supporting documentation.

8.3 Right to Erasure

You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis for processing exists), or where the data has been processed unlawfully. Please note that 37j77 may be required to retain certain data beyond your erasure request in order to satisfy our legal and regulatory obligations (see Section 7 — Data Retention). In such cases, we will inform you of the specific data that must be retained and the reason for its retention.

8.4 Right to Restrict Processing

You have the right to request that 37j77 restricts the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested, or while a legitimate interest objection is being assessed. During a restriction period, 37j77 will store your data but will not actively process it beyond what is strictly necessary.

8.5 Right to Data Portability

Where processing is based on your consent or on the performance of a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another data controller. To submit a data portability request, contact [email protected].

8.6 Right to Object

You have the right to object at any time to the processing of your personal data where that processing is based on 37j77's legitimate interests. You also have the right to object unconditionally to the processing of your data for direct marketing purposes. We will honour such objections promptly.

8.7 Right to Withdraw Consent

Where 37j77 relies on your consent as the legal basis for processing (e.g., marketing communications, non-essential cookies), you may withdraw that consent at any time without detriment. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

9. Minors & Age Verification

37j77 is strictly an 18+ platform. We do not knowingly collect, store, or process personal data belonging to individuals under the age of 18. The collection of personal data during the registration process — including date of birth — is used specifically to verify that each new player meets the minimum age requirement before account activation.

Where 37j77 has reasonable grounds to believe that an account has been registered by or is being used by a person under 18, we will immediately suspend the account, initiate an age verification review, and — if the suspicion is confirmed — permanently close the account and forfeit any balance in accordance with our Terms & Conditions.

Parents and guardians who believe that a minor may have accessed or registered an account on 37j77 are encouraged to contact us immediately at [email protected]. We will investigate the matter as a priority and take all necessary action to close the account and delete any personal data belonging to the minor, subject to any legal retention obligations.

10. Changes to This Policy

37j77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, operational procedures, applicable laws, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email to the address associated with their account and/or by displaying a prominent notice on the 37j77 platform for a minimum of 14 days prior to the changes taking effect.

The updated Policy will be published on this page with a revised effective date clearly displayed at the top of the document. We encourage you to review this Policy periodically to stay informed about how 37j77 is protecting your personal data. Your continued use of the 37j77 platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

If any amendment to this Policy materially reduces your privacy rights or significantly changes how we process your personal data, we will seek your explicit consent where required by applicable law before the changes take effect with respect to your account.

10.1 Version History

11. Contact & Data Enquiries

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which 37j77 processes your personal data, please contact our data support team using the details below. We take all privacy enquiries seriously and will respond within 4 business hours during normal operating hours (Bangladesh Standard Time, UTC+6).

11.1 Data Support Contact

• Email: [email protected] (subject line: "Privacy Enquiry")
• WhatsApp: +880 1700 000000
• Live Chat: Available 24/7 via the 37j77 platform
• Response Time: Email within 4 hours · Live Chat immediate

11.2 Complaints

If you believe that 37j77 has processed your personal data in a manner that is inconsistent with this Privacy Policy or applicable data protection principles, we encourage you to contact us directly in the first instance so that we have the opportunity to address your concern. We will investigate all complaints thoroughly and respond with a substantive reply within 14 calendar days.

If you are not satisfied with our response, you retain the right to escalate your complaint to the relevant data protection authority or seek independent legal advice. 37j77 will cooperate fully with any regulatory investigation into our data practices.