377bd Privacy Policy — How We Handle Your Data

Introduction

This Privacy Policy ("Policy") describes how 377bd ("377bd", "we", "us", "our") collects, processes, stores and protects the personal data of individuals ("you", "Player", "User") who access or use the 377bd website, mobile platform and associated services. By registering an account with 377bd or by using any 377bd service, you acknowledge that you have read and understood this Policy and you consent to the processing of your personal data as described herein.

377bd operates exclusively as an online casino and sportsbook platform serving the Bangladesh market. The data we collect is the minimum necessary to deliver a secure, compliant and functional service. We do not sell personal data to third parties, and we do not use personal data for purposes incompatible with the ones described in this Policy.

Our Core Privacy Commitments

1. Data We Collect

377bd collects personal data in five categories. We collect only data that is necessary and proportionate to the purposes for which it is collected. The five categories are described below.

377bd does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (other than what may be derived from KYC identity documents for age verification purposes only), or health data. If you contact us by email, the contents of that communication are retained as customer support records.

2. How We Use Your Data

377bd uses the personal data it collects for the following purposes. We process data only where we have a lawful basis to do so, as described in Section 3.

• Account creation, verification and management: creating your 377bd account, verifying your identity and age, maintaining your account in good standing, and processing account closure requests.
• Payment processing: processing BDT deposits and withdrawals via bKash, Nagad, Rocket, Upay and partner banks; reconciling transactions; investigating payment disputes.
• Service delivery: providing access to sportsbook markets, casino games, live dealer tables, crash games, fishing arcade games, and all other platform features you use.
• Responsible gaming: monitoring gambling patterns to identify players who may be experiencing gambling-related harm; administering deposit limits, session limits, cooling-off periods and self-exclusion tools; fulfilling responsible gaming obligations.
• Fraud prevention, AML compliance and security: detecting and preventing fraud, money laundering, identity theft, account takeover, and other forms of prohibited conduct; complying with applicable AML laws and regulations.
• Customer support: responding to support requests submitted by email to [email protected]; investigating and resolving complaints; maintaining records of support interactions.
• Platform improvement and analytics: analysing aggregated, anonymised usage data to improve platform performance, game selection, payment processing speed and the overall player experience. This analysis does not involve processing of individually identifiable data.

Where 377bd wishes to use your data for a purpose not listed above, we will notify you in advance and obtain your explicit consent before proceeding. You may refuse consent for any new purpose without affecting your existing account or access to the platform.

3. Legal Basis for Processing

377bd processes personal data only where it has a lawful basis to do so. The lawful bases on which 377bd relies are set out below.

Most processing by 377bd is necessary to perform the contract with you — the Terms and Conditions you accepted when registering. This covers account creation and management, payment processing, service delivery, and customer support. Without this processing, 377bd cannot provide the platform services you have contracted for.

Certain processing is required by law — specifically, the collection and retention of identity verification data and financial transaction records to satisfy AML obligations, and the enforcement of responsible gaming requirements including age verification (21+ only).

377bd processes technical and device data on the basis of legitimate interests — specifically, the interest in maintaining platform security, detecting and preventing fraud, and improving the technical performance of the platform for all players. When relying on legitimate interests, 377bd has assessed that its interests do not override your fundamental privacy rights.

Marketing communications (promotional emails and SMS) are sent only on the basis of your explicit opt-in consent. You may withdraw consent for marketing communications at any time without penalty by contacting [email protected]. Withdrawal of marketing consent does not affect the lawfulness of prior processing or your access to the platform.

4. Sharing Your Data

377bd shares personal data with third parties only where necessary to operate the platform and comply with legal obligations. The categories of third parties with whom data may be shared are listed below.

• Payment providers: bKash, Nagad, Rocket, Upay and partner banks receive only the payment transaction data necessary to process deposits and withdrawals. They do not receive gameplay data or KYC documents.
• Game providers: Certified game providers (Evolution Gaming, Ezugi, Pragmatic Play, Spribe, PG Soft, Jili) receive a session token and player identifier sufficient to launch game sessions. They do not receive your full name, mobile number, payment details or KYC documents.
• Compliance and regulatory authorities: 377bd may be required by law to disclose personal data and transaction records to competent authorities in connection with AML investigations, fraud investigations or other lawful requests. 377bd will comply with all lawful orders and will notify affected players to the extent permitted by law.
• Technology infrastructure providers: Hosting providers, cloud infrastructure services, and cybersecurity vendors who process data on behalf of 377bd under strict data processing agreements. These providers act only on 377bd's instructions and may not use the data for their own purposes.

5. Payment Data and Mobile Banking

377bd processes all deposits and withdrawals in Bangladeshi Taka (BDT) using Bangladesh's most trusted mobile financial services and banking channels. Given the sensitivity of payment data, 377bd applies additional safeguards to financial transaction information beyond those applied to other categories of personal data.

The specific additional safeguards applied to payment data are as follows.

• Mobile wallet numbers (bKash, Nagad, Rocket, Upay) are stored in masked form after the transaction is confirmed. Only the last four digits and the payment method type are retained in plain text for display purposes. Full mobile wallet numbers are not accessible to 377bd customer support staff.
• Bank account numbers provided for bank transfer withdrawals are stored encrypted and are accessible only to the 377bd finance team for withdrawal processing purposes. They are deleted from active systems 90 days after the associated account is closed.
• All payment API integrations between 377bd and payment providers use encrypted communication channels and tokenised transaction references. Raw payment credentials are never transmitted or stored in 377bd's own systems — they pass directly through the payment provider's secure gateway.

6. Cookies and Tracking Technologies

377bd uses cookies and similar tracking technologies on the platform. Cookies are small data files placed on your device when you visit the platform. The cookies used by 377bd fall into three categories.

• Essential cookies: Required for the platform to function. They maintain your login session, remember your language preference, and store your shopping cart or active bet slip state. These cookies cannot be disabled without breaking core platform functionality.
• Analytical cookies: Used to understand how players interact with the platform — which pages are visited most frequently, where errors occur, and how navigation flows perform. Data from analytical cookies is aggregated and anonymised before analysis. No individual player is identified through analytical cookie data.
• Preference cookies: Remember your platform settings between sessions, such as your chosen deposit method, notification preferences, and display settings. These cookies improve your experience by reducing the need to reconfigure settings on each visit.

377bd does not use third-party advertising cookies or cross-site tracking technologies. You may manage cookie preferences through your browser settings. Disabling essential cookies will impair platform functionality; disabling analytical or preference cookies will not affect your ability to use the platform.

7. Data Retention

377bd retains personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations, and to resolve disputes. The retention periods applied to each data category are as follows.

• Account and identity data (name, date of birth, mobile number, address, KYC documents): retained for the lifetime of the account and for 5 years following account closure, to satisfy AML record-keeping obligations.
• Financial transaction records (deposit and withdrawal records, payment method references): retained for 7 years following the date of each transaction, consistent with standard AML and financial record-keeping requirements.
• Technical and device data (IP logs, session logs, error logs): retained for 12 months from the date of collection for security and fraud investigation purposes, then deleted.

Following the expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised. Where a legal dispute or regulatory investigation is ongoing at the point at which a retention period would otherwise expire, 377bd will retain the relevant data until the dispute or investigation is resolved and the applicable limitation period has passed.

8. Your Rights Over Your Personal Data

You have the following rights in relation to the personal data 377bd holds about you. To exercise any of these rights, please contact the 377bd support team at [email protected]. Requests will be acknowledged within 5 business days and responded to within 30 calendar days.

• Right of access: You may request a copy of all personal data 377bd holds about you. We will provide this in a structured, commonly used, machine-readable format.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or complete it. Where practicable, corrections will be applied within 10 business days.
• 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 withdraw consent (for consent-based processing), or where the data has been unlawfully processed. This right is subject to legal retention obligations — we cannot erase data we are legally required to retain.
• Right to restrict processing: You may request that 377bd restrict processing of your personal data in certain circumstances — for example, while the accuracy of the data is disputed, or while a legitimate interests assessment is pending.
• Right to data portability: Where processing is based on your consent or on contractual necessity, you may request that we provide your personal data in a portable, machine-readable format so you can transfer it to another service provider.
• Right to object: You may object to processing based on legitimate interests at any time. If you object, 377bd will cease processing unless it can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims.

377bd will not charge a fee for exercising any of the above rights unless a request is manifestly unfounded or excessive. In those cases, a reasonable administrative fee may be charged. 377bd may request proof of identity before processing a rights request to protect against fraudulent requests.

9. Security Measures

377bd implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include SSL encryption on all data in transit, encrypted storage of data at rest on secured cloud servers, access controls limiting data access to authorised personnel only on a need-to-know basis, regular security audits and penetration testing, and automated intrusion detection systems that monitor for suspicious access patterns in real time.

Notwithstanding the above, no internet-based data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your account has been compromised or that your interaction with 377bd is no longer secure, please notify us immediately at [email protected]. 377bd will investigate all reported security incidents promptly and will notify affected players in accordance with applicable data breach notification requirements.

10. Children and Minors

377bd is strictly an adult-only platform. Access by or registration of any person under the age of 21 is absolutely prohibited. 377bd does not knowingly collect personal data from persons under 21. If 377bd becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed. Parents and guardians who believe that a minor may have registered with 377bd are encouraged to contact [email protected] immediately.

11. Changes to This Privacy Policy

377bd reserves the right to update or amend this Privacy Policy at any time. When changes are made, the revised Policy will be published on this page with an updated "Last updated" date. Continued use of the 377bd platform following publication of any amendment constitutes your acceptance of the revised Policy.

For material changes — changes that significantly affect how your personal data is processed — 377bd will provide advance notice by email to your registered mobile number or email address, where one has been provided, at least 14 days before the change takes effect. Where the change is required by law or regulation, advance notice may not be possible.

12. Contact and Data Enquiries

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or wish to report a data protection concern, please contact the 377bd support team. All privacy-related enquiries are handled with strict confidentiality and are responded to within 30 calendar days.