btw77 Privacy Policy — How We Protect Your Data

1.1 Who We Are. btw77 ("the Platform", "we", "us", "our") operates the online casino and sports betting platform accessible at btw77.io. btw77 is committed to protecting the personal data of every player who uses our services, and this Privacy Policy sets out how we fulfil that commitment.

1.2 Scope. This Privacy Policy applies to all personal data that btw77 collects and processes in connection with your use of the btw77 platform, including but not limited to: account registration, identity verification, deposits and withdrawals, gameplay activity, communications with our support team, and visits to the btw77 website. It applies regardless of whether you access btw77 via a desktop browser, mobile browser, or any native application we may make available.

1.3 Relationship with Other Policies. This Privacy Policy should be read alongside our Terms & Conditions (available at /terms-conditions) and our Responsible Gaming Policy (available at /responsible-gaming). Together, these documents govern the full relationship between you and btw77. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a matter relating to personal data, this Privacy Policy shall take precedence.

1.4 Acceptance. By creating a btw77 account or by continuing to use the platform, you confirm that you have read and understood this Privacy Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree to this Privacy Policy, you must not use the btw77 platform.

btw77 collects different categories of personal data depending on the nature of your interaction with the platform. The table below provides a clear overview of the categories of data we collect and examples of the specific data points within each category.

3.1 Directly From You. The majority of the personal data btw77 holds is provided directly by you during the account lifecycle. This includes information you submit when registering your account, completing our KYC verification process, making deposits or requesting withdrawals, contacting our customer support team, or responding to surveys and promotions.

3.2 Automatically During Platform Use. When you visit and interact with the btw77 platform, certain technical and usage data is collected automatically by our systems. This includes your IP address, device identifiers, browser characteristics, login timestamps, pages visited, games launched, and session duration. This data is collected using server logs, cookies, and similar tracking technologies (see Section 6 for full details on our cookie practices).

3.3 From Third-Party Service Providers. btw77 may receive personal data about you from trusted third-party partners in limited circumstances. For example:

• Payment processors such as bKash, Nagad, and Rocket may share transaction confirmation data and wallet verification details with us to complete deposit and withdrawal processing.
• Identity verification providers may share the results of document checks and facial matching services as part of our KYC process.
• Fraud prevention services may share risk scores or flagged-activity reports to help us protect the security of the platform.

In all such cases, the sharing of your data by these third parties is governed by their own privacy policies and by contractual agreements that require them to protect your data appropriately.

3.4 From Publicly Available Sources. In limited circumstances — for example, when investigating suspected fraud or verifying reported information — btw77 may consult publicly available sources such as public records, social media profiles made publicly available by you, or news databases.

btw77 processes your personal data only where a valid legal basis exists. The following legal bases apply to our data processing activities:

• Performance of a Contract: Processing that is necessary to provide you with the btw77 platform services, including account creation, transaction processing, and customer support. Without this processing, we would be unable to deliver the services you have requested.
• Legal Obligation: Processing that btw77 is required to carry out to comply with applicable legal and regulatory requirements, including anti-money-laundering (AML) obligations, age verification requirements, and record-keeping duties.
• Legitimate Interests: Processing that is necessary for btw77's legitimate business interests, where those interests are not overridden by your rights and freedoms. This includes fraud detection and prevention, platform security, responsible gaming monitoring, and analytics used to improve the player experience.
• Consent: Processing that relies on your freely given, specific, informed, and unambiguous consent. This primarily applies to the sending of marketing and promotional communications. You may withdraw your consent at any time by contacting our support team or using the unsubscribe function in any marketing email.

btw77 uses the personal data we collect for the following specific purposes:

• Account Management: Creating, maintaining, and administering your btw77 player account, including verifying your identity and age (21+), processing login credentials, and managing account preferences.
• Transaction Processing: Processing deposits via bKash, Nagad, Rocket, Upay, Visa, and Mastercard; verifying the ownership of payment instruments; and processing withdrawal requests to verified payment methods in Bangladeshi Taka (৳).
• Identity and KYC Verification: Conducting Know Your Customer checks to verify your identity, confirm your age, and comply with anti-money-laundering obligations.
• Fraud Prevention and Security: Detecting and preventing fraudulent transactions, account takeovers, bonus abuse, multi-accounting, and other activities that threaten platform integrity or harm other players.
• Responsible Gaming: Monitoring gameplay behaviour to identify potential signs of problem gambling, administering self-exclusion and deposit limit tools, and fulfilling our duty of care to vulnerable players.
• Customer Support: Responding to your queries, complaints, and support requests; maintaining records of communications for quality assurance and dispute resolution.
• Marketing and Promotions: Sending you relevant promotional offers, bonus notifications, and event announcements — but only where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: Analysing aggregated, anonymised usage data to understand how players interact with btw77, identify areas for improvement, and develop new features and games.
• Legal and Regulatory Compliance: Fulfilling our obligations under applicable law, responding to lawful requests from regulatory bodies, and maintaining records as required by legal retention obligations.

6.1 What Are Cookies. Cookies are small text files placed on your device when you visit a website. They allow the site to recognise your device, remember your preferences, and gather information about how you navigate the platform. btw77 uses cookies and similar technologies including web beacons, local storage, and pixel tags.

6.2 Types of Cookies We Use. The following categories of cookies are used on the btw77 platform:

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and whether you have acknowledged certain notices. These improve the consistency of your experience across sessions.
• Analytical Cookies: Used to collect aggregated data about how players use the btw77 platform — such as pages visited, features used, and session duration — to help us improve the product. This data is anonymised and does not identify you personally.
• Security and Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, identify suspicious login behaviour, and protect player accounts from unauthorised access.

6.3 Managing Cookies. You can manage or disable cookies through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the btw77 platform and may prevent you from logging in or completing transactions. Disabling analytical or functional cookies will not prevent you from using the platform but may affect the consistency of your experience.

6.4 Do Not Track. Some browsers transmit a "Do Not Track" signal. btw77 currently honours this signal for non-essential analytical tracking. Strictly necessary and security cookies will continue to operate regardless of this signal as they are essential to platform security.

7.1 Our Principle. btw77 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share personal data only in the specific, limited circumstances described in this section, and only with parties who are contractually bound to protect it.

7.2 Categories of Third Parties. btw77 shares personal data with the following categories of third parties:

• Payment Processors: bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive the financial data necessary to process your deposits and withdrawals. Each processor operates under its own privacy policy and is responsible for the data it holds on its own infrastructure.
• Identity Verification Providers: Third-party KYC service providers receive identity documents and biometric data (selfie photographs) strictly for the purpose of verifying your identity and age as required by our responsible gaming and anti-money-laundering obligations.
• Fraud Prevention and Security Partners: Specialist fraud detection services may receive technical data (IP address, device fingerprint, session behaviour) to generate risk assessments that help us protect the platform and its players.
• Game Content Providers: Studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi may receive a player identifier to authenticate your session within their game environments. These providers do not receive your full personal profile.
• Legal and Regulatory Authorities: Where required by applicable law or a valid legal order, btw77 may disclose personal data to government bodies, law enforcement agencies, regulators, or courts. We will only do so to the extent required and will notify you where legally permitted.
• Professional Advisors: In limited circumstances, btw77 may share data with legal, financial, or audit advisors who are bound by professional confidentiality obligations.

7.3 Business Transfers. In the event of a merger, acquisition, or sale of all or part of btw77's business, personal data held about players may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any resulting changes to this Privacy Policy before they take effect.

8.1 Retention Principle. btw77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, and to comply with our legal and regulatory obligations. When data is no longer required for any legitimate purpose, it is securely deleted or anonymised.

8.2 Standard Retention Periods. The following retention periods apply to the main categories of personal data we hold:

• Account and Identity Data: Retained for the duration of your account plus a minimum of 5 years following account closure, to meet anti-money-laundering and regulatory record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in accordance with financial compliance obligations.
• KYC Verification Documents: Retained for the duration of your account plus 5 years following closure, or longer where required by applicable law.
• Customer Support Communications: Retained for up to 3 years from the date of the last communication, to support dispute resolution and quality assurance.
• Technical and Usage Data: Retained for up to 13 months in identifiable form, after which it is aggregated and anonymised for analytical purposes only.
• Marketing Preference Records: Retained for the duration of your account or until you withdraw consent, plus a short period thereafter to evidence the withdrawal of consent.

8.3 Deletion Requests. Where you exercise your right to erasure (see Section 10), btw77 will assess your request against our legal retention obligations. Where a legal obligation requires us to retain the data, we will inform you of this and the expected retention period before deletion becomes possible. In all other cases, we will process your deletion request promptly.

9.1 Technical Measures. btw77 implements a comprehensive suite of technical security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption across all platform pages and API communications.
• Encrypted storage of sensitive data at rest using industry-standard encryption algorithms.
• Firewall protection and continuous network intrusion detection.
• Multi-factor authentication options for player accounts.
• Regular independent security audits and penetration testing.
• Access controls that restrict internal staff access to personal data on a strict need-to-know basis.

9.2 Organisational Measures. In addition to technical controls, btw77 maintains internal data protection policies, staff training programmes, and incident response procedures. All employees and contractors who handle personal data are subject to confidentiality obligations and receive regular training on data protection best practices.

9.3 Data Breach Response. In the event of a confirmed personal data breach that is likely to result in a risk to your rights and freedoms, btw77 will take immediate steps to contain the breach, assess its impact, and notify affected players without undue delay. We will also report the breach to relevant regulatory authorities where legally required.

9.4 Your Responsibility. While btw77 takes all reasonable steps to secure your data on our end, account security also depends on you. You are responsible for keeping your login credentials confidential, using a strong and unique password, and logging out of your account when using shared devices. If you suspect your account has been compromised, contact our support team immediately.

As a btw77 player, you have the following rights with respect to the personal data we hold about you. To exercise any of these rights, please contact our support team at [email protected] with a clear description of your request. We will respond within a reasonable timeframe and, where identity verification is required, we may ask you to confirm your identity before processing your request.

• Right of Access: You have the right to request a copy of the personal data btw77 holds about you, along with information about how it is processed. This is sometimes called a Subject Access Request (SAR).
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
• Right to Erasure ("Right to be Forgotten"): In certain circumstances, you have the right to request the deletion of your personal data — for example, where the data is no longer necessary for the purposes it was collected, or where you withdraw consent and no other legal basis applies. This right is subject to our legal retention obligations.
• Right to Restriction of Processing: In certain circumstances, you may request that btw77 restrict the processing of your personal data — for example, while a dispute about the accuracy of the data is being resolved.
• Right to Data Portability: Where processing is based on your consent or 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, machine-readable format, and to request that it be transferred to another controller where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on btw77's legitimate interests. You also have an absolute right to object to the use of your personal 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 carried out before the withdrawal.
• Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to decisions made solely by automated processing that produce significant legal or similarly significant effects on you, except where such processing is permitted by law or you have provided explicit consent.

11.1 Minimum Age Policy. btw77 is strictly an adult platform. Our services are available only to individuals who are 21 years of age or older. We do not knowingly collect personal data from persons under the age of 21. If you are under 21, you must not attempt to register an account or use any service offered by btw77.

11.2 Age Verification. btw77 employs active age verification measures as part of our KYC process to confirm that all registered players meet the 21+ requirement. Any account found to be held by a person under 21 will be immediately closed, all gameplay will be voided, and any deposited funds will be returned to the payment source.

11.3 If We Discover Minor's Data. If btw77 becomes aware that personal data has been collected from a person under the age of 21 without appropriate consent, we will take immediate steps to delete that data from our systems and close the associated account. If you are a parent or guardian and believe your child has registered an account with btw77, please contact us immediately at [email protected] so that we can take appropriate action.

11.4 Parental Controls. btw77 encourages parents and guardians to use available parental control software and internet filtering tools to prevent underage individuals from accessing online gambling sites. While we take robust measures on our end, parental supervision is an important additional layer of protection.

12.1 Cross-Border Processing. As an online platform serving players primarily in Bangladesh, btw77 may process or store personal data on servers located outside of Bangladesh. Where such international transfers occur — for example, in connection with services provided by our game content partners, identity verification providers, or infrastructure providers — we take steps to ensure that your data is afforded an equivalent level of protection to that which it would receive in Bangladesh.

12.2 Safeguards Applied. Where personal data is transferred to a third country, btw77 ensures that appropriate safeguards are in place. These safeguards may include contractual clauses that bind the recipient to data protection standards consistent with this Privacy Policy, or transfers to countries that are deemed to provide an adequate level of data protection under applicable frameworks.

12.3 Your Right to Information. You may request further information about the specific safeguards in place for any international transfer of your personal data by contacting our support team at [email protected].

13.1 Right to Update. btw77 reserves the right to update, amend, or replace this Privacy Policy at any time. Changes may be made to reflect updates in our data processing practices, changes in applicable law, new product features, or feedback from our players and regulators.

13.2 Notification of Changes. Where changes to this Privacy Policy are material — meaning they significantly affect how we collect, use, or share your personal data — btw77 will notify you by email to the address registered on your account, or by displaying a prominent notice on the btw77 platform, at least 14 days before the changes take effect. Minor or clarificatory changes may be made without prior notice.

13.3 Continued Use as Acceptance. Your continued use of the btw77 platform after any updated Privacy Policy takes effect constitutes your acceptance of the revised terms. If you do not agree with any changes, you must stop using the platform and may request account closure by contacting our support team.

13.4 Version History. The effective date shown at the top of this Privacy Policy always reflects the date of the most recent revision. We recommend bookmarking this page and reviewing it periodically so you are always informed of how your data is being handled.

14.1 Contacting Us. If you have any questions, concerns, or requests relating to this Privacy Policy or to the way btw77 handles your personal data, please contact our support team using the details below. We aim to respond to all privacy-related enquiries within 5 business days.

14.2 Complaints. If you are not satisfied with how btw77 has handled your personal data or responded to a privacy request, you have the right to raise a formal complaint. We take all such complaints seriously and will investigate them thoroughly. Please direct formal complaints to [email protected] with the subject line "Formal Privacy Complaint" and include as much detail as possible about your concern so that we can investigate and respond appropriately.

14.3 Regulatory Recourse. If you remain dissatisfied after raising a complaint with btw77 directly, you may have the right to escalate your complaint to a relevant data protection authority or regulatory body in your jurisdiction. btw77 will cooperate fully with any such regulatory investigation.