ih77 Privacy Policy — How We Protect Your Personal Data

1 Introduction

This Privacy Policy (the "Policy") describes how ih77 (referred to throughout as "ih77", "we", "us", or "our") collects, uses, stores, shares, and protects the personal data of individuals who register for and use the services available at ih77.io (the "Platform"). The Platform provides online casino gaming, sports betting, live dealer games, crash games, slots, and related services primarily to players based in Bangladesh.

This Policy applies to all personal data processed in connection with your use of the ih77 Platform, regardless of the device or method through which you access it. It should be read alongside the ih77 Terms & Conditions, which together constitute the full agreement between you and ih77 governing your use of the Platform.

By creating an ih77 account or continuing to use the Platform after the effective date of this Policy, you acknowledge that you have read and understood its contents and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the ih77 Platform.

2 Data Controller

For the purposes of this Policy, ih77 is the data controller responsible for the personal data of all registered account holders and visitors to the Platform. As data controller, ih77 determines the purposes and means by which personal data is processed and is responsible for ensuring that processing activities comply with applicable data protection principles.

All data protection enquiries, subject access requests, correction requests, and deletion requests should be directed to the ih77 Data Protection contact point at: [email protected]. Please include the subject line "Data Protection Request" and your registered account username or mobile number so that we can locate your records promptly.

3 Personal Data We Collect

ih77 collects personal data in several categories depending on the nature of your interaction with the Platform. The table below summarises the main categories of data collected, the specific data points within each category, and the primary purpose for which each is collected.

Category	Data Points	Primary Purpose
Identity Data	Full legal name, date of birth, gender, national ID number, passport number	Account registration, age verification, KYC compliance
Contact Data	Mobile number, email address, residential address (district, city, division)	Account communication, withdrawal verification, support
Financial Data	bKash/Nagad/Rocket/Upay account numbers, Bank account details, transaction history, deposit and withdrawal records	Payment processing, AML compliance, withdrawal verification
Technical Data	IP address, device type, operating system, browser type, session timestamps, login history	Platform security, fraud detection, session management
Usage Data	Games played, bets placed, bet amounts, win/loss records, bonus usage, time spent on platform	Responsible gaming monitoring, account management, platform improvement
Verification Documents	Scanned copies of NID, passport, or other government-issued ID; selfie images for liveness checks	Identity verification, fraud prevention, regulatory compliance
Communications Data	Support chat transcripts, email correspondence, complaint records	Customer service, dispute resolution, quality assurance
Marketing Preferences	Promotional opt-in/opt-out status, preferred communication channel	Sending relevant offers (consent-based only)

ih77 does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric identification data beyond what is strictly required for identity verification purposes.

4 How We Collect Your Data

ih77 collects personal data through the following channels:

• Direct submission: Data you provide when completing the registration form, submitting a KYC verification request, making a deposit or withdrawal, contacting customer support, or updating your account profile.
• Automated collection: Technical and usage data collected automatically when you interact with the Platform, including via server logs, session tracking, and in-browser event recording (e.g., page views, button clicks, game launches).
• Payment processors: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, and other payment partners when a deposit or withdrawal instruction is processed.
• Identity verification partners: Results and risk scores returned by third-party KYC/AML services used to verify the authenticity of identity documents submitted during account verification.
• Cookies and similar technologies: Data collected via browser cookies, web beacons, and local storage as described in Section 8 of this Policy.

5 How We Use Your Personal Data

ih77 uses the personal data we collect for the following specific purposes:

• Account management: Creating and maintaining your ih77 account, processing login requests, managing account settings, and facilitating account closures or self-exclusions.
• Payment processing: Executing deposit and withdrawal transactions via bKash, Nagad, Rocket, Upay, and bank transfer channels; reconciling transaction records; and resolving payment disputes.
• Identity verification and AML compliance: Verifying your identity and age in accordance with our Know Your Customer (KYC) obligations; screening transactions against anti-money laundering (AML) requirements; and reporting to regulatory authorities where legally obliged.
• Fraud prevention and platform security: Detecting and investigating suspicious account activity, unauthorised login attempts, multi-accounting, bonus abuse, and other platform integrity violations.
• Responsible gaming: Monitoring gameplay patterns to identify signs of problem gambling; enforcing deposit limits, session time-outs, and self-exclusion requests; and proactively contacting players showing concerning patterns.
• Customer support: Responding to queries, processing complaints, and resolving disputes submitted through the ih77 support channel.
• Platform improvement: Analysing aggregated and anonymised usage data to improve game performance, user interface design, loading speeds, and the overall player experience.
• Marketing communications: Sending promotional offers, bonus notifications, and seasonal campaign messages to players who have provided explicit opt-in consent. You may withdraw this consent at any time.
• Legal and regulatory compliance: Retaining records as required by applicable financial, gaming, and data protection regulations; responding to lawful requests from government authorities or courts.

ih77 does not use personal data for automated individual decision-making that produces significant legal effects without human review. Where profiling is used to personalise promotional content, it is based on aggregated behavioural patterns rather than individual-level automated decisions.

6 Legal Basis for Processing

ih77 processes personal data under the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to fulfil the obligations set out in the ih77 Terms & Conditions — including account creation, payment processing, and customer support.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML screening, age verification, tax record-keeping, and responding to lawful authority requests.
• Legitimate interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and the use of non-essential cookies, where your explicit prior consent has been obtained. You retain the right to withdraw this consent at any time without penalty.

7 Sharing Your Personal Data

ih77 shares personal data with third parties only in the circumstances described below. In all cases, data sharing is limited to the minimum necessary for the stated purpose, and recipients are required to handle shared data in accordance with this Policy and applicable data protection standards.

• Payment service providers: Transaction data is shared with bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard solely for the purpose of processing deposits and withdrawals to and from your ih77 account.
• Identity verification partners: Identity document data and selfie images are shared with accredited KYC service providers for the purpose of verifying your identity and age. These providers are contractually prohibited from using the data for any other purpose.
• Game content providers: Certain technical identifiers (such as session tokens and player-level identifiers) may be shared with game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi for the purpose of delivering game content and resolving game disputes. These providers do not receive your personal contact or financial data.
• Regulatory and law enforcement authorities: ih77 may disclose personal data to government bodies, regulators, courts, or law enforcement agencies where required or permitted by applicable law. We will make reasonable efforts to notify you of any such disclosure unless legally prohibited from doing so.
• Professional advisers: Legal, accounting, and auditing firms engaged by ih77 may access personal data on a strictly confidential, need-to-know basis for the purpose of providing professional services.

8 Cookies & Tracking Technologies

ih77 uses cookies and similar technologies (including web beacons, pixel tags, and local storage) to operate the Platform, ensure a consistent user experience, and — with your consent — to deliver relevant promotional content. The main categories of cookies used on ih77 are as follows:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies, load-balancing cookies, and security tokens. These cookies cannot be disabled as they are required for the Platform to operate.
• Functional cookies: Remember your preferences such as your last-visited game category, language settings, and responsible gaming reminder intervals. These improve your experience but are not essential.
• Analytics cookies: Collect anonymised and aggregated data about how players navigate the Platform — which pages are visited most, where sessions end, and which features are used most frequently. This data helps ih77 improve the Platform. Analytics cookies are only set with your consent.
• Marketing cookies: Used to deliver promotional content relevant to your gaming preferences and activity history. These are only placed with your explicit consent and are not shared with third-party advertising networks.

You can manage or withdraw your consent for non-essential cookies at any time through your browser settings. Disabling cookies may affect some Platform features, but will not prevent you from accessing core gaming and account functions.

9 Data Retention

ih77 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, or for the duration required by applicable law, whichever is longer. The retention schedule below outlines the standard periods applied to each major data category:

Data Category	Retention Period	Basis
Account and identity data	Duration of account + 5 years after closure	Legal obligation, AML requirements
Financial transaction records	7 years from transaction date	Financial record-keeping obligations
KYC verification documents	5 years after account closure	Regulatory compliance
Support and complaint records	3 years from resolution date	Dispute resolution, legal claims
Technical and usage logs	13 months from collection date	Security monitoring, analytics
Marketing preference records	Until consent is withdrawn + 1 year	Consent record-keeping

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to any identified or identifiable individual.

10 Your Data Rights

As an ih77 account holder, you have the following rights in relation to your personal data. ih77 will not charge any fee for exercising these rights, and will respond to all valid requests within 30 calendar days of receipt.

• Right of access: You may request a copy of all personal data ih77 holds about you, together with an explanation of how it is used and with whom it is shared.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data held in your ih77 account record. For data that you can update directly within your account settings, we encourage you to do so without delay.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where processing is unlawful. This right is subject to ih77's legal obligation to retain certain records as described in Section 9.
• Right to restrict processing: You may request that ih77 temporarily suspend processing of your personal data while a rectification or objection request is under review.
• Right to data portability: You may request a structured, machine-readable export of the personal data you have provided directly to ih77 (e.g., your registration details and account history) for transfer to another service provider.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes. Where you object to marketing-related processing, we will cease that activity immediately.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications or non-essential cookies), you may withdraw that consent at any time via account settings or by contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of the above rights, contact ih77 support at [email protected] with the subject line "Data Rights Request" and your registered username or mobile number. ih77 may request proof of identity before processing your request to protect against unauthorised access to another person's data.

11 Data Security

ih77 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and ih77 servers.
• AES-256 encryption for personal data stored in ih77 databases.
• Role-based access controls limiting internal access to personal data to only those employees and systems that require it to perform their function.
• Multi-factor authentication for administrative access to systems holding personal data.
• Regular vulnerability assessments and penetration testing of the ih77 Platform and underlying infrastructure.
• Automated intrusion detection systems with 24/7 monitoring and alerting capabilities.
• Documented incident response procedures to ensure prompt containment, assessment, and notification in the event of a data breach.

In the event of a personal data breach that poses a risk to your rights and interests, ih77 will notify affected account holders by email or account notification within 72 hours of becoming aware of the breach, and will provide clear guidance on any recommended steps you should take to protect yourself.

12 Children's Privacy

ih77 services are strictly intended for individuals aged 21 years and above. ih77 does not knowingly collect, store, or process personal data belonging to any person under the age of 21. If we become aware that personal data of an underage individual has been submitted to the Platform, the associated account will be closed immediately, any balance will be voided in accordance with the Terms & Conditions, and all data related to that account will be deleted from our systems within 30 days.

If you believe that a person under 21 has created an ih77 account or submitted personal data to the Platform, please notify us immediately at [email protected] with the subject line "Underage Account Report". ih77 takes all such reports seriously and will act upon them promptly.

13 Amendments to This Policy

ih77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or regulatory guidance. The most current version of this Policy is always available at ih77.io/privacy-policy and supersedes all previous versions.

Where amendments are material — meaning they significantly change how we collect, use, or share your personal data — ih77 will notify registered account holders by email or in-platform notification at least seven (7) calendar days before the changes take effect. Your continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

We recommend reviewing this page periodically so that you remain fully informed about how ih77 protects your privacy. The effective date at the top of this Policy indicates when it was last reviewed and updated.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data ih77 holds about you, please contact us using the details below. All privacy-related communications are handled by dedicated staff and are treated with the highest level of confidentiality.

ih77 is committed to resolving all privacy-related concerns directly and transparently. We encourage you to contact us in the first instance so that we have the opportunity to address your concern before any escalation.