Privacy Policy — How 7up7 Collects, Uses, and Protects Your Data

01 Definitions

Throughout this Privacy Policy, the following terms carry the meanings assigned below:

• "7up7" / "we" / "us" / "our" — refers to the 7up7 online gaming and sports betting platform, accessible at https://7up7.io, and the entity responsible for processing the personal data described in this policy.
• "Player" / "you" / "your" — refers to any individual who accesses, browses, or holds a registered account on the 7up7 platform.
• "Personal Data" — refers to any information relating to an identified or identifiable natural person, including but not limited to name, email address, date of birth, payment details, and IP address.
• "Processing" — refers to any operation performed on personal data, including collection, storage, use, disclosure, or deletion.
• "Third Party" — refers to any natural or legal person other than the Player and 7up7 who is involved in the processing of personal data.
• "KYC" — refers to Know Your Customer identity verification procedures conducted to confirm a Player's identity and age in compliance with applicable anti-money laundering and responsible gaming standards.
• "Cookies" — refers to small data files placed on your device by a website for the purposes of session management, analytics, and user preference storage.

02 Information We Collect

7up7 collects personal data through several channels — directly from you when you register and interact with the platform, automatically through your use of the platform, and in limited cases from third-party service providers who assist us in operating our services. The categories of data we collect are described below.

2.1 Data You Provide Directly

• Registration Data: Full name, date of birth, email address, mobile number, and preferred username provided at the time of account creation.
• Identity Verification Data: Government-issued photo identification (National ID Card, passport, or driving licence), proof of address documents, and any additional documents submitted in response to a KYC request.
• Payment Data: Payment method details including bKash, Nagad, or Rocket mobile wallet account numbers; bank account details for Dutch-Bangla Bank, BRAC Bank, or other supported institutions; and card details for Visa or Mastercard transactions. Note: full card numbers are processed by our payment partners and are not stored on 7up7 servers.
• Support Communications: The content of any emails, live chat transcripts, or other correspondence you direct to our support team at [email protected].
• Responsible Gaming Data: Any deposit limits, session limits, self-exclusion requests, or reality-check preferences you configure through your account settings.

2.2 Data Collected Automatically

• Device and Connection Data: IP address, device type, operating system, browser type and version, and approximate geographic location derived from IP.
• Usage and Session Data: Pages visited, time spent on each page, game sessions initiated, bets placed, and navigation paths through the platform.
• Transaction Records: A complete log of all deposits, withdrawals, wagers, and bonus activations associated with your account, including timestamps recorded in Bangladesh Standard Time (UTC+6).
• Cookie Data: Data collected via cookies and similar tracking technologies as described in Section 6 of this policy.

2.3 Data Received from Third Parties

In certain circumstances, 7up7 may receive personal data about you from third-party sources, including identity verification service providers, fraud prevention databases, and payment processors. This data is used solely for the purposes of verifying your identity, detecting fraud, and processing your transactions, and is handled in accordance with this Privacy Policy.

03 How We Use Your Data

7up7 uses the personal data it collects for the following specific purposes. We do not use your data for any purpose beyond those listed here without first obtaining your consent or establishing a new legitimate legal basis.

Where we process your data on the basis of legitimate interest, we have assessed that our interest does not override your fundamental privacy rights. You may object to processing on the basis of legitimate interest at any time by contacting us at [email protected].

04 Legal Basis for Processing

7up7 processes personal data only where a valid legal basis exists for doing so. The legal bases we rely on are as follows:

• Contract Performance: Processing that is necessary to provide you with the services you have requested — including account management, game access, and transaction processing — is conducted on the basis that it is required to fulfil our contractual obligations to you.
• Legal Obligation: Certain processing activities, such as identity verification, anti-money laundering record-keeping, and responsible gaming monitoring, are required by applicable law or regulatory guidance. We process personal data for these purposes because we are legally required to do so.
• Legitimate Interest: Some processing activities — such as fraud detection, platform security monitoring, and aggregate analytics used to improve our services — are conducted on the basis of 7up7's legitimate business interest. In each such case, we have assessed that our interest is proportionate and does not override your privacy rights.
• Consent: Where we send you direct marketing communications or deploy non-essential cookies, we do so only with your prior consent. You may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

05 Sharing of Personal Data

7up7 does not sell your personal data. We share personal data with third parties only in the following limited, controlled circumstances:

5.1 Service Providers and Data Processors

We engage carefully selected third-party service providers who process personal data on our behalf for specific, documented purposes. These include payment processing companies (such as the operators of bKash, Nagad, Rocket, and Upay integrations), identity verification and KYC providers, fraud prevention and AML screening services, email delivery and communication infrastructure providers, and cloud hosting and server infrastructure providers. All such providers are bound by contractual data processing agreements that restrict their use of your data to the specific services they provide to 7up7.

5.2 Game Software Providers

The games available on 7up7 are powered by third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, among others. These providers may receive limited technical data — such as session identifiers and wager amounts — that is necessary for the delivery and settlement of their games. They do not receive your name, email address, national ID, or payment details.

5.3 Law Enforcement and Regulatory Authorities

7up7 may disclose personal data to law enforcement agencies, regulatory bodies, or other competent authorities where required to do so by applicable law, court order, or regulatory direction. We may also proactively share data where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or other illegal activity. We are not required to notify you when such a disclosure is made if notification would compromise a law enforcement investigation or legal process.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving 7up7, personal data held by the platform may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity before your data is subject to a materially different privacy policy.

06 Cookies and Tracking Technologies

7up7 uses cookies and similar technologies on its platform. Cookies are small text files placed on your device that enable the platform to function correctly and allow us to understand how players use our services. The categories of cookies we use are as follows:

6.1 Strictly Necessary Cookies

These cookies are essential to the operation of the 7up7 platform. They enable core functions such as session authentication, security validation, and load balancing. Without these cookies, the platform cannot function. These cookies do not require your consent and cannot be disabled while you use the platform.

6.2 Functional Cookies

Functional cookies remember your preferences and settings — such as your preferred display language, remembered username, and session time-out preferences. They improve your experience on the platform but are not strictly necessary for its operation. You may disable functional cookies, though doing so may affect the quality of your experience.

6.3 Analytics Cookies

Analytics cookies collect aggregated, anonymised data about how players navigate and use the 7up7 platform. This data helps us identify areas for improvement and optimise platform performance. Analytics cookies are deployed only with your consent and may be withdrawn at any time through your account settings or browser controls.

6.4 Managing Cookies

You may control the cookies placed on your device through your browser settings. Most browsers allow you to block or delete cookies. Please note that blocking strictly necessary cookies will prevent you from using the 7up7 platform. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

07 Data Retention

7up7 retains personal data for only as long as is necessary for the purpose for which it was collected, or as required by applicable legal and regulatory obligations. Our general retention periods are as follows:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data cannot be immediately deleted due to technical constraints, it is isolated from active processing systems pending secure deletion at the next scheduled purge cycle.

08 Data Security

7up7 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes the following measures:

• SSL/TLS Encryption: All data transmitted between your device and 7up7 servers is encrypted using industry-standard SSL/TLS protocols. Our platform operates exclusively over HTTPS.
• Data Encryption at Rest: Sensitive personal data stored on our servers — including identity documents and payment details — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within 7up7's internal systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo background screening and are bound by contractual confidentiality obligations.
• Regular Security Audits: 7up7 conducts periodic security assessments of its platform infrastructure, including vulnerability scanning and penetration testing, to identify and remediate potential security weaknesses before they can be exploited.
• Incident Response: In the event of a data breach that poses a risk to your rights and freedoms, 7up7 will notify affected Players without undue delay, in accordance with applicable data protection law. Notifications will be sent to your registered email address.

09 Your Rights

As a Player, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our support team at [email protected] with the subject line "Data Rights Request — [Your Username]". We will respond to all valid requests within 30 days.

• Right of Access: You have the right to request a copy of the personal data we hold about you, together with information about how it is processed. We will provide this in a clear, portable format.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may also update many details directly through your account settings.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing has no lawful basis. This right is subject to any legal retention obligations that require us to keep your data for a minimum period.
• Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances — for example, while a dispute about its accuracy is being resolved.
• Right to Data Portability: Where processing is based on consent or contract performance and is carried out by automated means, you may request that we provide your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Object: You may object to processing carried out on the basis of legitimate interest at any time. You may also withdraw consent for marketing communications at any time by following the unsubscribe link in any marketing email or by contacting our support team.

10 Children and Minors

The 7up7 platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from persons under the age of 21. If we discover or have reason to believe that an account has been registered by a person under the age of 21, we will immediately suspend the account, initiate an investigation, and delete all personal data associated with that account to the extent permitted by law.

If you are a parent or guardian and believe that a minor in your care has registered an account on 7up7, please contact us immediately at [email protected]. We will treat all such reports as a high priority and take prompt action. 7up7 employs age verification measures as part of its registration and KYC processes to minimise the risk of underage access, and we continually review these measures to ensure their effectiveness.

11 International Data Transfers

7up7 operates internationally. In the course of providing its services, personal data may be transferred to and processed in countries other than Bangladesh. Where such transfers occur, 7up7 takes steps to ensure that your personal data receives an equivalent level of protection to that afforded in Bangladesh, including through the use of contractual safeguards such as standard data protection clauses in agreements with our third-party service providers.

In particular, data held by our cloud infrastructure and game software providers may be processed in data centres located in multiple jurisdictions. All such providers are required, as a condition of their engagement with 7up7, to implement security and privacy standards consistent with those described in this Privacy Policy and to process your data only in accordance with 7up7's documented instructions.

12 Changes to This Privacy Policy

7up7 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. Where changes are material — meaning they affect how we use your personal data in a significant way — we will notify you before they take effect via your registered email address or through a prominent notice on the platform. The effective date and version number at the top of this document will be updated with each revision.

If you continue to use the 7up7 platform after a revised Privacy Policy has taken effect, you are deemed to have accepted the updated terms. If you do not accept the revised policy, you should contact us to request account closure before the effective date of the update. We strongly encourage you to review this Privacy Policy periodically to stay informed about how 7up7 protects your data.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data 7up7 holds about you, please contact us using the details below. We are committed to responding to all privacy-related enquiries promptly and transparently.

• Email: [email protected]
• Subject Line for Data Rights Requests: Data Rights Request — [Your Username]
• Subject Line for Privacy Complaints: Privacy Complaint — [Your Username]
• Support Hours: 24 hours a day, 7 days a week — Bangladesh Standard Time (UTC+6)
• Response Time: We aim to acknowledge all privacy enquiries within 48 hours and to resolve them within 30 days