ap77 Privacy Policy

01 Introduction

This Privacy Policy ("Policy") is published by ap77 ("ap77", "we", "us", "our"), the operator of the online betting and casino platform accessible at https://ap77.io ("Platform"). This Policy describes how ap77 collects, uses, stores, shares, and protects personal data submitted by or generated through use of the Platform by registered players and unregistered visitors based in Bangladesh.

ap77 is committed to handling personal data responsibly, transparently, and in accordance with applicable data protection principles. This Policy should be read alongside the ap77 Terms & Conditions and the Responsible Gaming Policy, both of which form part of your overall agreement with ap77. In the event of any conflict between this Policy and another document published by ap77, this Policy shall govern in matters relating to personal data.

All references to monetary amounts in this Policy are expressed in Bangladeshi Taka (৳). All natural-language content on the Platform, including this Policy, is published in English.

02 Data We Collect

ap77 collects personal data through several distinct channels. The categories of data collected, and the context in which each is collected, are set out below.

2.1 Registration Data

When you create an ap77 account, we collect the information you provide directly, including:

• Full legal name as it appears on your identity document
• Date of birth (used to verify that you meet the 21+ age requirement)
• Residential address, including district, division, and postal code
• Email address (used for account communications and recovery)
• Mobile phone number (used for account security and payment verification)
• Username and encrypted password credentials

2.2 Identity Verification (KYC) Data

To comply with our Know Your Customer obligations and to enforce age and identity verification, ap77 may collect copies of:

• National Identity Card (NID) or valid Passport
• Proof of residential address (utility bill or bank statement dated within three months)
• Source-of-funds documentation where required for large transactions or high-volume accounts

KYC documents are processed through a secure verification workflow and are stored in an encrypted document vault accessible only to authorised personnel.

2.3 Transaction Data

When you make deposits or request withdrawals, ap77 records transaction data including the payment method used (bKash, Nagad, Rocket, Upay, Visa, or Mastercard), transaction reference numbers, transaction amounts in ৳, timestamps, and processing status. ap77 does not store full card numbers or mobile banking PINs — payment credentials are handled by the respective payment provider's secure gateway.

2.4 Betting and Gaming Activity Data

ap77 records a complete log of your betting and gaming activity on the Platform, including bets placed, games played, wager amounts, results, bonus usage, and session durations. This data is used for account management, dispute resolution, responsible gaming monitoring, and fraud prevention.

2.5 Technical and Device Data

When you access the Platform, our servers and analytics systems automatically collect certain technical data, including:

• IP address and approximate geographic location derived from IP
• Browser type, version, and language settings
• Device type, operating system, and screen resolution
• Referring URL and pages visited within the Platform
• Session duration and interaction event logs

2.6 Communications Data

If you contact ap77 customer support, we retain records of that correspondence, including email content, live chat transcripts, and any documentation you submit in connection with a query or complaint. These records are retained to ensure continuity of service and for quality assurance purposes.

03 How We Use Your Data

ap77 uses the personal data it collects for the following specific and documented purposes:

ap77 does not use your personal data for automated profiling that produces legal or similarly significant effects without human review. Responsible gaming alerts generated by automated systems are always subject to review by a trained support agent before any account action is taken.

04 Legal Basis for Processing

ap77 processes personal data on the following legal bases, depending on the purpose of processing:

• Contractual necessity: Processing required to fulfil our obligations to you under the Terms & Conditions — including account management, payment processing, and game delivery — is necessary for the performance of our contract with you.
• Legal obligation: Certain processing activities, including KYC identity verification, transaction record-keeping, and reporting to law enforcement or financial crime authorities, are required by applicable law and are carried out in fulfilment of those obligations.
• Legitimate interests: ap77 processes technical and activity data to detect fraud, prevent abuse, ensure platform security, and improve service quality. These activities serve ap77's legitimate operational interests and do not override your privacy interests.
• Consent: Where ap77 sends optional marketing communications, such processing is based on your explicit consent. You may withdraw this consent at any time by contacting [email protected].

05 Data Sharing

5.1 Payment Providers

To process deposits and withdrawals, ap77 shares necessary transaction data with payment providers including bKash, Nagad, Rocket, Upay, Visa, and Mastercard. Each provider handles data in accordance with their own privacy policies and applicable financial services regulations. ap77 shares only the minimum data required to complete each transaction.

5.2 Game Providers

ap77 hosts games supplied by third-party providers including Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, and Spribe. When you play these games, your session data (including game events and wager outcomes) is processed by the relevant provider's certified systems. Game providers act as data processors under instruction from ap77 and are contractually bound to process data only for the purpose of delivering the game service.

5.3 Identity Verification Services

ap77 may engage specialist KYC and identity verification service providers to assist in processing identity documents and performing age verification checks. These providers act as data processors under contractual obligations consistent with this Policy.

5.4 Legal and Regulatory Authorities

ap77 will disclose personal data to law enforcement agencies, financial crime investigation bodies, or other regulatory authorities where required or permitted by applicable law, including in response to valid legal requests, court orders, or obligations arising from anti-money-laundering regulations.

5.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of ap77's business, personal data held by ap77 may be transferred to the acquiring entity as part of that transaction. ap77 will provide reasonable advance notice to registered players of any such transfer that materially affects the processing of their personal data.

06 Cookies & Tracking Technologies

ap77 uses cookies and similar tracking technologies on the Platform to deliver essential functionality, analyse usage patterns, and maintain session security. The categories of cookies used by ap77 are as follows:

• Essential cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and preference cookies. Essential cookies cannot be disabled without impairing Platform functionality.
• Analytical cookies: Used to collect aggregated, anonymised data about how visitors interact with the Platform — such as pages visited, session duration, and navigation paths. This data is used to identify usability issues and improve the Platform experience.
• Functional cookies: Store your preferences (such as language settings and responsible gaming tool configurations) so that you do not need to re-enter them on each visit.

ap77 does not use third-party advertising or retargeting cookies. You may manage your cookie preferences through your browser settings. Note that disabling essential cookies will affect your ability to log in and use core Platform features.

07 Data Security

ap77 implements a layered security framework to protect personal data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between the Platform and your device
• Encryption at rest for stored sensitive data, including identity documents and financial records
• Role-based access controls limiting internal data access to authorised personnel with a documented operational need
• Regular security assessments and penetration testing of Platform infrastructure
• Automated anomaly detection systems monitoring for suspicious login activity, unusual transaction patterns, and potential data breaches
• Secure deletion protocols applied when data reaches the end of its defined retention period

Despite these measures, no data transmission over the internet or electronic storage system is entirely free of risk. ap77 takes commercially reasonable steps to protect your data but cannot guarantee absolute security. In the event of a data breach that is likely to result in a significant risk to affected individuals, ap77 will notify impacted players as promptly as is reasonably practicable.

08 Data Retention

ap77 retains personal data for defined periods based on the purpose of collection and applicable legal requirements. The principal retention periods are summarised below:

Upon expiry of the applicable retention period, data is securely deleted from ap77 systems or, where full deletion is not technically feasible in the short term, anonymised such that it can no longer be attributed to any identifiable individual.

09 Your Rights

As an ap77 account holder and data subject, you hold the following rights in relation to your personal data. To exercise any of these rights, submit a written request to [email protected] with the subject line "Data Rights Request" and include your registered email address and a brief description of your request. ap77 will acknowledge receipt within 5 business days and respond substantively within 30 days.

• Right of access: You may request a copy of the personal data ap77 holds about you, along with information about the purposes for which it is processed and the categories of recipients with whom it has been shared.
• Right to rectification: If any personal data ap77 holds about you is inaccurate or incomplete, you may request that it be corrected. Some corrections (e.g., legal name changes) may require supporting documentation.
• 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 you object to processing and there are no overriding legitimate grounds. Note that legal retention obligations may prevent full erasure in some cases.
• Right to restriction: You may request that ap77 restrict processing of your data in certain circumstances, such as while the accuracy of data you have contested is being verified.
• Right to data portability: You may request a structured, machine-readable export of personal data you have provided to ap77, where that processing is based on consent or contractual necessity and is carried out by automated means.
• Right to object: You may object to processing carried out on the basis of ap77's legitimate interests. ap77 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, or where processing is necessary for legal claims.
• Right to withdraw consent: Where processing is based on your consent (e.g., for optional marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

10 Children's Privacy

The ap77 Platform is strictly for adults aged 21 and above. ap77 does not knowingly collect personal data from individuals under the age of 21. If ap77 discovers or has reasonable grounds to believe that a registered account belongs to a person under 21, that account will be suspended immediately, all personal data associated with the account will be reviewed, and any data collected from the underage individual will be deleted as soon as reasonably practicable, subject to any mandatory legal retention obligations.

11 Third-Party Links

The ap77 Platform may from time to time reference or display content associated with third-party service providers such as payment networks and game providers. ap77 is not responsible for the privacy practices of third-party websites or services. If you navigate to a third-party website from the ap77 Platform, we encourage you to review that party's privacy policy independently. This Privacy Policy applies only to the ap77 Platform and the data processing activities carried out directly by ap77.

12 Changes to This Policy

ap77 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or operational structure. When material changes are made, ap77 will provide advance notice to registered players via the email address associated with their account, and will display a prominent notice on the Platform, before the updated Policy takes effect.

The effective date and version number at the top of this document will be updated with each revision. Minor, non-material changes (such as corrections to typographical errors or clarifications that do not alter the substance of any provision) may be made without advance notice. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Policy.

ap77 maintains an archive of prior Policy versions. If you wish to review a previous version, contact ap77 support at [email protected] with a request specifying the version date you require.

13 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way ap77 processes your personal data, please contact the ap77 Data Protection team:

• Email: [email protected] — subject line: "Privacy Enquiry" or "Data Rights Request"
• Response time: Acknowledgement within 5 business days; substantive response within 30 days for formal data rights requests
• Availability: 24 hours a day, 7 days a week including public holidays observed in Bangladesh (BST, UTC+6)

If you are not satisfied with ap77's response to a privacy concern, you have the right to escalate the matter through appropriate legal channels available to you under applicable law in Bangladesh. ap77 will cooperate fully with any legitimate investigative process.