c7778 Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how c7778 ("c7778", "we", "us", or "our") collects, uses, stores, discloses, and protects personal data relating to individuals ("you" or "your") who access or use the c7778 platform available at https://c7778.io, including all associated subdomains, mobile-optimised interfaces, and related services (collectively, the "Platform").

This Policy applies to all personal data processed by c7778 in connection with your use of the Platform, including data collected during account registration, identity verification, payment processing, gameplay, customer support interactions, and marketing communications where you have given consent.

This Policy should be read alongside the c7778 Terms & Conditions and Responsible Gaming Policy, both of which are published on the Platform and incorporated herein by reference. In the event of a conflict between this Policy and the Terms & Conditions regarding data privacy matters, this Policy shall prevail.

2. Data Controller Information

For the purposes of applicable data protection law, c7778 is the data controller responsible for the personal data collected through the Platform. The data controller determines the purposes and means of processing personal data.

If you have any questions about this Policy or wish to exercise any of your data rights, you may contact our Data Privacy team using the contact details provided in Section 15 of this Policy. We aim to respond to all privacy-related correspondence within 30 days of receipt.

3. Personal Data We Collect

c7778 collects personal data through several channels and in different categories depending on the nature of your interaction with the Platform. The table below provides a structured overview of the categories of personal data we collect and the primary source of each category.

3.1 Data We Do Not Collect

c7778 does not collect or process special categories of sensitive personal data (sometimes called "sensitive personal data" or "sensitive data"), such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric data, health data, or data relating to a person's sex life or sexual orientation, except where strictly required by law or where you have provided explicit consent in a specific context (for example, health data disclosed voluntarily in connection with a self-exclusion request).

4. How We Use Your Data

c7778 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your player account, including authentication, password recovery, and account settings management.
• Identity & Age Verification: To verify that you are at least 21 years of age and to confirm your identity in accordance with our KYC obligations and our strict 21+ policy.
• Payment Processing: To process deposits and withdrawal requests via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and other accepted payment methods. Transaction data is shared with relevant payment processors on a need-to-know basis.
• Service Delivery: To provide access to the full game library, sports betting markets, live dealer tables, and all other features of the Platform.
• Customer Support: To respond to enquiries, complaints, and support tickets submitted by you, and to maintain records of those interactions for quality assurance and training purposes.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct as described in the Terms & Conditions.
• Legal & Regulatory Compliance: To comply with applicable anti-money laundering obligations, to respond to lawful requests from regulatory and law enforcement authorities, and to enforce our Terms & Conditions.
• Responsible Gaming: To monitor gameplay patterns for indicators of problem gambling, to enforce deposit and session limits you have set, and to manage self-exclusion requests effectively.
• Platform Improvement: To analyse aggregate usage data (in anonymised or pseudonymised form) to improve the Platform's performance, design, and game offering.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications. You may withdraw marketing consent at any time via your account settings.

5. Legal Basis for Processing

Where data protection law requires c7778 to identify a legal basis for each processing activity, we rely on the following bases:

• Contractual Necessity: Processing required to perform the contract between you and c7778 — including account creation, game access, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable law — including KYC/AML verification, record-keeping requirements, and responding to regulatory or court orders.
• Legitimate Interests: Processing in pursuit of c7778's legitimate interests where those interests are not overridden by your rights — including fraud detection, platform security, responsible gaming monitoring, and aggregated analytics.
• Consent: Processing based on your freely given, informed, and specific consent — including marketing communications and, where applicable, the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6. Data Sharing & Third Parties

c7778 does not sell, rent, or trade your personal data. We may share your data with the following categories of third parties where necessary to deliver the Platform's services:

6.1 Payment Processors

To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and other accepted methods, c7778 shares relevant financial and identity data with the applicable payment processor. Each processor is contractually bound to handle your data securely and in accordance with applicable financial regulations.

6.2 Game Software Providers

Third-party game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) receive technical session data necessary to deliver their games on the Platform. These providers operate under their own data protection frameworks and are selected for their compliance with international standards.

6.3 Identity Verification Services

c7778 may engage specialist KYC and identity verification providers to assist in verifying the identity and age of players. These providers process identity documents and biographic data strictly for verification purposes and are contractually prohibited from using your data for any other purpose.

6.4 IT Infrastructure & Cloud Providers

c7778 uses reputable cloud hosting and infrastructure providers to operate the Platform securely. These providers process data as data processors on our behalf, under contractual terms that require them to implement appropriate technical and organisational security measures.

6.5 Legal & Regulatory Authorities

c7778 may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required by law, court order, or where we believe in good faith that such disclosure is necessary to prevent fraud, money laundering, or other criminal activity.

7. International Data Transfers

As an internationally operated offshore platform, c7778 may transfer personal data to countries outside your country of residence in connection with its use of global cloud infrastructure, game providers, and payment processors. Such transfers are made subject to appropriate safeguards, which may include:

• Standard contractual clauses approved by relevant data protection authorities.
• Binding corporate rules where applicable within a corporate group.
• Transfers to countries that have been assessed as providing an adequate level of data protection.

By registering on and using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside Bangladesh. c7778 takes all reasonable steps to ensure that any such transfers are made securely and in accordance with applicable data protection principles.

8. Data Retention

c7778 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

When data is no longer required, it is securely deleted or anonymised so that it can no longer be associated with any individual. Anonymised or aggregated data may be retained indefinitely for statistical and analytical purposes.

9. Security Measures

c7778 implements a layered security framework to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• Transport Security: All data in transit is protected using 256-bit SSL/TLS encryption. HTTPS is enforced across all Platform endpoints.
• Data-at-Rest Encryption: Sensitive data fields stored in our databases — including passwords (stored as salted hashes), payment method identifiers, and identity document references — are encrypted using AES-256 or equivalent algorithms.
• Access Controls: Access to personal data within c7778 is restricted to authorised personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Intrusion Detection: c7778's infrastructure is protected by network-level firewalls, intrusion detection systems, and regular penetration testing conducted by independent third-party security firms.
• Incident Response: c7778 maintains a documented data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights and freedoms, we will notify affected individuals as required by applicable law.

While c7778 takes all reasonable precautions to protect your data, no internet-based system is completely immune to risk. You are responsible for maintaining the security of your own account credentials. If you suspect any unauthorised access to your account, please contact us immediately at [email protected].

10. Cookies & Tracking Technologies

c7778 uses cookies and similar tracking technologies (such as local storage objects and session tokens) to operate the Platform effectively. The categories of cookies used are as follows:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens, security cookies that protect against cross-site request forgery (CSRF), and load-balancing cookies. No personal data collected by these cookies is used for marketing or profiling purposes.

10.2 Functional Cookies

These cookies remember your preferences — such as your selected language, last viewed game category, and session time limit reminders — to provide a more personalised experience. These cookies do not track your activity on other websites.

10.3 Analytics Cookies

c7778 uses first-party analytics tools to understand how players use the Platform in aggregate. These tools collect anonymised or pseudonymised data about page views, session durations, game interactions, and navigation paths. This data is used solely to improve the Platform's performance and user experience.

10.4 Cookie Management

You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Detailed instructions for managing cookies in popular browsers are available from each browser's help documentation.

11. Your Data Rights

Subject to applicable data protection law, you may have the following rights regarding your personal data held by c7778:

• Right of Access: You have the right to request confirmation of whether c7778 processes personal data about you, and if so, to receive a copy of that data along with information about how it is processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update many details directly through your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis for processing. Note that this right is subject to overriding legal retention obligations (for example, AML record-keeping requirements).
• Right to Restrict Processing: You have the right to request that c7778 restrict the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested.
• Right to Data Portability: Where processing is based on your consent or on contract performance, and is carried out by automated means, you may request that your personal data be provided to you in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where c7778 relies on legitimate interests as the legal basis. You also have an unconditional right to object to the processing of your data for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing prior to the withdrawal.

11.1 How to Exercise Your Rights

To exercise any of the rights described above, please submit a written request to [email protected] with the subject line "Data Rights Request" and include your full name, registered email address, and a description of the right you wish to exercise. c7778 will respond within 30 days. In some cases, we may need to verify your identity before processing a request.

c7778 will not charge a fee for reasonable data rights requests. However, where a request is manifestly unfounded or excessive — particularly where it is repetitive — c7778 reserves the right to charge a reasonable administrative fee or to refuse to act on the request.

12. Minors & Age Restriction

The Platform is strictly for individuals aged 21 and above. c7778 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been submitted by or on behalf of an individual who is under 21 years of age, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered on the Platform or submitted personal data to c7778, please contact us immediately at [email protected] so that we can investigate and take appropriate action. Parents and guardians are encouraged to monitor the online activities of minors in their care and to use parental control tools provided by their internet service provider or device manufacturer.

13. Anti-Money Laundering & Fraud Detection

c7778 is committed to preventing money laundering, terrorist financing, and fraud. In order to meet these obligations, c7778 processes personal data — including identity documents, financial transaction records, and behavioural data — for the purpose of detecting and reporting suspicious activity.

This processing is carried out on the basis of legal obligation. Where c7778 has reasonable grounds to suspect that a transaction is related to money laundering or other financial crime, we are required by applicable law to report that suspicion to the relevant authorities. In such cases, c7778 is legally prohibited from informing you that a report has been made ("tipping off" prohibition).

Automated fraud detection systems are used to flag transactions and account behaviours that deviate from established patterns. Where such a flag results in a decision to restrict, suspend, or close your account, you may have the right to request a manual review of that decision by contacting [email protected].

14. Changes to This Policy

c7778 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When we make material changes to this Policy, we will notify registered users via the email address on their account and/or via a prominent notice on the Platform prior to the changes taking effect.

The revised Policy will state the new effective date at the top of the document. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically to stay informed about how c7778 protects your data.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way c7778 handles your personal data, please contact our Data Privacy team using the details below:

• Email: [email protected]
• Subject Line: Privacy Policy Enquiry / Data Rights Request
• Response Time: Within 30 days for data rights requests; within 5 business days for general privacy enquiries
• Support Hours: 24 hours a day, 7 days a week

Please note that this contact channel is for privacy and data protection enquiries only. For account support, deposits, withdrawals, and general gameplay assistance, please use the main customer support channel at [email protected].