Privacy Policy

1. Data Controller

1.1 The data controller responsible for the personal data collected through the zben77 platform is the operator of zben77.club (referred to throughout this Policy as "zben77," "we," "us," or "our").

1.2 As data controller, zben77 determines the purposes and means of processing personal data in connection with the platform's sports betting, casino gaming, account management, and customer support functions.

1.3 All enquiries relating to this Privacy Policy or to the processing of your personal data should be directed to: support@zben77.club

2. Personal Data We Collect

2.1 The following categories of personal data may be collected and processed by zben77 in connection with your account and use of the platform:

Category	Examples	Mandatory / Optional
Identity Data	Full name, date of birth, gender, nationality, government-issued ID number	Mandatory (KYC)
Contact Data	Email address, mobile phone number, residential address	Mandatory
Account Data	Username, encrypted password, account registration date, account status	Mandatory
Financial Data	bKash / Nagad / Rocket / Upay wallet number, bank account details, transaction history, deposit and withdrawal records	Mandatory
Verification Data	Copies of national ID (NID), passport, utility bill, selfie photograph submitted for KYC	Mandatory (upon request)
Behavioural Data	Betting history, game session logs, win/loss records, wagering patterns, login timestamps	Automatic
Technical Data	IP address, device type, operating system, browser type and version, screen resolution	Automatic
Communications Data	Support chat transcripts, email correspondence, complaint records	When you contact us
Marketing Preferences	Opt-in or opt-out status for promotional emails and SMS notifications	Optional

2.2 zben77 does not collect or process sensitive special-category data such as racial or ethnic origin, political opinions, religious beliefs, health data (except where voluntarily disclosed in a responsible gaming context), or biometric data for identification purposes.

3. How We Collect Personal Data

3.1 Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or opt in to marketing communications.

3.2 Automatically — when you access and interact with the zben77 platform, our servers automatically record technical and behavioural data including IP address, device identifiers, session duration, pages visited, bets placed, and game rounds completed.

3.3 From third-party service providers — identity verification agencies and KYC platforms may return enriched data (e.g., address confirmation, document validity status) to zben77 as part of the verification workflow. Payment processors confirm the status and reference of financial transactions. Fraud detection providers may flag behavioural signals associated with suspicious activity.

3.4 From cookies and similar technologies — see Section 10 of this Policy for a full description of how cookies and tracking technologies are used on the zben77 platform.

4. Purposes of Processing

4.1 zben77 processes your personal data for the following purposes:

• Account creation and management: registering your account, authenticating your identity at login, maintaining your account profile and preferences, and communicating account-related notices to you.
• Payment processing: executing deposits and withdrawals via bKash, Nagad, Rocket, Upay, and local bank transfer; reconciling transaction records; and resolving payment disputes.
• Identity and age verification (KYC): confirming that you are at least 18 years of age, verifying your identity against government-issued documents, and complying with anti-money-laundering obligations.
• Service delivery: providing access to sports betting markets, casino games, live dealer tables, and promotional offers; personalising your platform experience based on your activity history.
• Responsible gaming: monitoring betting patterns to identify potential problem gambling behaviours; applying deposit limits, cooling-off periods, or self-exclusion tools at your request or as a safeguarding measure.
• Fraud prevention and security: detecting and investigating suspicious account activity, collusion, bonus abuse, and money laundering; protecting the platform and other players from harm.
• Customer support: responding to enquiries, complaints, and disputes; maintaining records of communications to ensure quality and consistency of support.
• Legal compliance: fulfilling record-keeping, reporting, and audit obligations imposed by applicable law.
• Marketing communications (with consent): sending promotional offers, reload bonuses, tournament invitations, and platform news to players who have opted in. You may withdraw consent at any time.
• Platform improvement: analysing aggregated, anonymised usage data to identify technical issues, improve game performance, and enhance the overall user experience.

5. Legal Basis for Processing

5.1 zben77 processes personal data on the following legal bases:

• Contractual necessity: processing required to register your account, facilitate transactions, and deliver the services you have requested is necessary for the performance of the contract between you and zben77.
• Legal obligation: KYC verification, anti-money-laundering record-keeping, and fraud reporting are required by applicable law.
• Legitimate interests: fraud detection, platform security, responsible gaming monitoring, and internal analytics are processed on the basis of zben77's legitimate interest in operating a safe, compliant, and well-functioning platform — provided those interests are not overridden by your data protection rights.
• Consent: marketing communications and non-essential cookies are processed solely on the basis of your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. How We Share Your Data

6.1 zben77 does not sell, rent, or trade your personal data. We share data only in the following circumstances and only to the extent strictly necessary:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and BRAC Bank receive transaction data (wallet number, amount, reference) to execute deposits and withdrawals.
• KYC and identity verification providers: document images and identity data are transmitted to our verification partners to confirm age and identity in compliance with anti-money-laundering requirements.
• Game software providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed game studios receive a pseudonymous player identifier and session token to deliver game functionality. They do not receive your full name, contact details, or financial data.
• Fraud detection and security vendors: technical and behavioural data may be shared with third-party fraud prevention platforms to identify and block suspicious activity.
• Legal and regulatory authorities: zben77 will disclose personal data to law enforcement or regulatory bodies where required by law, court order, or where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or harm to persons.
• Business transfers: in the event of a merger, acquisition, or sale of all or part of zben77's business, player data may be transferred to the acquiring entity subject to equivalent privacy protections.

6.2 All third-party data processors engaged by zben77 are bound by contractual data processing agreements requiring them to process data only on zben77's documented instructions and to maintain appropriate technical and organisational security measures.

7. International Data Transfers

7.1 Some of zben77's technology partners and game software providers operate servers located outside Bangladesh. Where personal data is transferred internationally, zben77 takes steps to ensure that adequate protections are in place, including contractual data transfer clauses requiring the recipient to uphold privacy standards equivalent to those described in this Policy.

7.2 Financial transaction data processed via Bangladeshi mobile wallet providers (bKash, Nagad, Rocket, Upay) remains within Bangladesh's domestic payment infrastructure and is subject to Bangladesh Bank's applicable regulations.

8. Data Retention

8.1 zben77 retains personal data for the periods set out below, after which data is securely deleted or irreversibly anonymised:

• Active account data: retained for the duration of your account's active status plus a minimum of 5 years following account closure, to meet anti-money-laundering record-keeping requirements.
• Transaction records: retained for a minimum of 5 years from the date of each transaction.
• KYC documents: retained for 5 years following account closure or the date of the last transaction, whichever is later.
• Customer support communications: retained for 3 years from the date of the communication.
• Marketing consent records: retained for 3 years from the date of consent or until consent is withdrawn, whichever is earlier.
• Technical and behavioural logs: retained for 13 months on a rolling basis for platform security and fraud detection purposes, then deleted.

8.2 Where a legal hold is in place — for example, where an account is subject to an ongoing fraud investigation or litigation — data will be retained beyond the standard periods until the matter is resolved.

9. Your Privacy Rights

9.1 As a registered zben77 player, you have the following rights in relation to your personal data:

• Right of access: you may request a copy of all personal data held about you by zben77. We will respond within 30 days of receiving a verified request.
• Right to rectification: if any personal data we hold is inaccurate or incomplete, you may request that it be corrected. Minor account details (e.g., contact number) can be updated directly in your account settings.
• Right to erasure ("right to be forgotten"): you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Note that transaction records and KYC data cannot be deleted within the mandatory retention periods.
• Right to restriction: you may request that we restrict the processing of your data while a rectification or objection request is being assessed.
• Right to data portability: you may request a copy of the data you provided to us in a structured, machine-readable format (e.g., CSV or JSON), where processing is based on consent or contract.
• Right to object: you may object to processing based on legitimate interests, including profiling for responsible gaming monitoring, and we will cease such processing unless we have compelling legitimate grounds that override your interests.
• Right to withdraw consent: where processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time by contacting support or using the unsubscribe link in any marketing email. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

9.2 To exercise any of these rights, please submit a written request to support@zben77.club with the subject line "Privacy Rights Request." We will require identity verification before processing any access, rectification, or deletion request.

10. Cookies & Tracking Technologies

10.1 zben77 uses cookies and similar technologies (local storage, session storage, pixel tags) to operate the platform, remember your preferences, maintain your login session, and analyse platform performance.

10.2 The following categories of cookies are used:

• Strictly necessary cookies: required for core platform functions including session authentication, account security, and payment flow integrity. These cannot be disabled without breaking core functionality.
• Functional cookies: store your language preference, display settings, and last-visited game category to improve convenience across sessions.
• Analytics cookies: collect anonymised data about page visits, click patterns, and session duration to help us identify technical issues and improve the platform experience. No personally identifiable information is transmitted via analytics cookies.
• Marketing cookies: used only with your explicit consent to track which promotions you have viewed and to avoid showing you the same offer repeatedly. Marketing cookies are not shared with third-party advertising networks.

10.3 You may manage your cookie preferences via your browser settings. Disabling strictly necessary cookies will impair your ability to use the platform. Disabling functional or analytics cookies will not prevent access but may reduce the quality of your experience.

11. Minors

11.1 The zben77 platform is strictly intended for adults aged 18 and above. zben77 does not knowingly collect personal data from individuals under the age of 18.

11.2 If zben77 becomes aware that a player under the age of 18 has registered an account or provided personal data, that account will be immediately closed, all funds will be returned to the originating payment method (where technically feasible), and all associated personal data will be deleted from our systems without undue delay.

11.3 If you believe a minor has registered on the zben77 platform, please notify us immediately at support@zben77.club so that we can take prompt action.

12. Security Measures

12.1 zben77 implements the following technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption for sensitive data at rest, including payment details and KYC documents.
• One-way cryptographic hashing (bcrypt) for all stored account passwords — zben77 staff cannot read your password.
• Role-based access controls ensuring that staff can access player records only to the extent required by their specific job function.
• Multi-factor authentication (MFA) for all internal administrative systems that have access to player data.
• Regular third-party security penetration testing and vulnerability assessments of the platform infrastructure.
• Automated monitoring and alerting for anomalous access patterns, large-volume data queries, and failed authentication attempts.

12.2 In the event of a data breach that is likely to result in a risk to your rights and freedoms, zben77 will notify affected players without undue delay and will take immediate remedial action to contain the breach and prevent recurrence.

13. Changes to This Privacy Policy

13.1 zben77 reserves the right to update this Privacy Policy at any time. Material changes — those that affect how we use your personal data or your privacy rights — will be communicated to you via the email address registered on your account and via a prominent notice on the platform, with a minimum of 7 days' advance notice before the changes take effect.

13.2 Minor changes (such as clarifications, corrections of typographical errors, or updates to contact details) may be made without prior notice. The "Effective Date" at the top of this document will always reflect when the current version came into force.

13.3 Your continued use of the zben77 platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you should cease using the platform and contact support to close your account.

13.4 The current version of this Privacy Policy is always accessible at zben77.club/privacy-policy.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by zben77, please contact our support team using the details below:

• Email: support@zben77.club (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week via the chat widget on the zben77 platform
• Response Time: We aim to acknowledge all privacy-related enquiries within 4 hours and resolve them within 30 calendar days of receipt of a verified request.
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6)

When submitting a privacy rights request by email, please include your registered username and the nature of your request in the subject line to help us process it efficiently. We will require identity verification before actioning any access, rectification, or deletion request.