jaya77 Privacy Policy

1. Data Controller

The data controller responsible for your personal information is jaya77, the operator of the online casino and sports betting platform at jaya77.vu ("Platform"). References to "jaya77", "we", "us", and "our" throughout this Privacy Policy refer to jaya77 in its capacity as data controller.

If you have any questions about how jaya77 handles your personal data, or if you wish to exercise any of your data rights as described in this Policy, please contact our dedicated privacy team at [email protected]. We aim to respond to all privacy-related enquiries within five business days.

2. Personal Data We Collect

jaya77 collects personal data in several categories depending on the nature of your interaction with the Platform. The categories and specific data points we may hold are set out in the table below:

jaya77 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information, unless specifically required by law enforcement or regulatory request.

3. How We Collect Personal Data

jaya77 collects personal data through the following channels:

• Direct interactions: Data you provide when creating your account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or responding to a survey or promotion.
• Automated technologies: When you access the Platform, our servers automatically record technical data including your IP address, device identifiers, and session activity. This data is collected via server logs, cookies, and similar tracking technologies described in Section 9 below.
• Payment providers: When you make a deposit or initiate a withdrawal via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, the relevant provider transmits confirmation data (transaction reference, timestamp, and partially masked account identifier) to jaya77 to enable reconciliation. jaya77 does not receive or store your full payment credentials.
• Identity verification services: Where you submit identity documents for KYC, our verification process may involve cross-referencing submitted information against records held by third-party identity verification providers operating in Bangladesh. These providers act as data processors under instruction from jaya77 and are bound by confidentiality obligations.
• Third-party game studios: Game providers such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi may transmit aggregated session data (game ID, session start/end time, wager total) to jaya77 for account reconciliation and responsible gaming monitoring purposes.

4. Purposes of Processing

jaya77 processes your personal data for the following specific purposes. We only use your data in ways that are consistent with the purpose for which it was originally collected:

• Account administration: Creating, maintaining, and closing your jaya77 member account; verifying your login credentials; and processing account-level requests such as password resets and preference updates.
• Identity verification (KYC): Verifying that you meet the age requirement of 18 years or above; confirming your identity to comply with anti-money laundering obligations; and preventing fraudulent or duplicate account registration.
• Payment processing: Processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard; reconciling transaction records; and investigating disputed transactions.
• Service delivery: Providing access to casino games, sports betting markets, live dealer tables, and promotional offers; delivering real-time odds and results; and maintaining session continuity.
• Customer support: Responding to your support requests, complaints, and general enquiries via live chat and email; maintaining a record of communications for quality assurance and dispute resolution.
• Responsible gaming: Monitoring gaming patterns for indicators of problem gambling behaviour; implementing deposit limits, cool-off periods, and self-exclusion requests; and proactively contacting members where our data suggests a potential responsible gaming concern.
• Fraud prevention and security: Detecting and investigating suspicious login activity, unusual wagering patterns, multi-accounting, bonus abuse, and other forms of platform misuse; protecting the integrity of all members' accounts.
• Legal and regulatory compliance: Retaining records as required by applicable law; responding to lawful requests from competent authorities; and enforcing our Terms & Conditions.
• Marketing and communications: Sending promotional offers, bonus notifications, and Platform updates to members who have not opted out of marketing communications. You may unsubscribe at any time by contacting [email protected].
• Platform improvement: Analysing aggregated usage data to understand how members interact with the Platform, identify technical issues, and improve the user experience.

5. Legal Basis for Processing

jaya77 processes your personal data on one or more of the following legal grounds, depending on the specific processing activity involved:

• Contractual necessity: Processing required to perform the contract between you and jaya77 — including account creation, payment processing, and service delivery — is carried out on the basis that such processing is necessary to fulfil our contractual obligations to you.
• Legal obligation: Processing required to comply with applicable law, including anti-money laundering regulations, age verification requirements, and responses to lawful authority requests.
• Legitimate interests: Processing carried out in furtherance of jaya77's legitimate business interests — including fraud prevention, security monitoring, and Platform improvement — where those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where jaya77 relies on your consent for a specific processing activity (such as sending marketing communications), you retain the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing and Disclosure

jaya77 does not sell, rent, or trade your personal data to any third party. Personal data may be disclosed in the following limited circumstances:

6.1 Service Providers and Data Processors

jaya77 engages a small number of trusted third-party service providers who process personal data on our behalf and under our instruction. These include:

• Payment gateway operators (bKash, Nagad, Rocket, Upay, and card payment processors) — for transaction processing only
• Identity verification providers — for KYC document authentication
• Cloud hosting and infrastructure providers — for secure data storage and Platform operation
• Customer support platform providers — for management of live chat and email support records
• Game content studios (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Ezugi) — limited session data for game delivery and reconciliation

All third-party processors are contractually required to implement appropriate technical and organisational security measures and to process personal data only for the purposes instructed by jaya77.

6.2 Legal and Regulatory Disclosure

jaya77 may disclose personal data to competent law enforcement authorities, courts, regulators, or other government bodies where required to do so by applicable law, by court order, or where jaya77 reasonably believes disclosure is necessary to protect the rights, property, or safety of jaya77, its members, or the public.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets involving jaya77, personal data held by jaya77 may be transferred to the successor entity, provided that the successor commits to processing that data in accordance with privacy standards at least equivalent to those in this Policy.

7. Data Retention

jaya77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following indicative retention periods apply:

Upon expiry of the applicable retention period, jaya77 will securely delete or irreversibly anonymise the relevant personal data. Anonymised, aggregated data (from which no individual can be identified) may be retained indefinitely for statistical and analytical purposes.

8. Security Measures

jaya77 implements a range of technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. These include:

• 256-bit SSL/TLS encryption for all data in transit between your device and jaya77 servers
• Encryption at rest for sensitive data fields including identity documents and financial records stored in jaya77 databases
• Access controls: Personal data is accessible only to jaya77 staff and processors who require it for their specific function. Role-based access permissions are applied and reviewed regularly.
• Penetration testing and vulnerability assessments conducted periodically to identify and remediate potential security weaknesses
• Two-factor authentication for administrative access to systems holding personal data
• Incident response procedures: In the event of a data security incident affecting your personal data, jaya77 will notify affected members and relevant authorities in accordance with applicable legal requirements.

While jaya77 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You remain responsible for maintaining the confidentiality of your jaya77 account password and for notifying us immediately if you suspect any unauthorised access to your account.

9. Cookies and Tracking Technologies

jaya77 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device by your browser when you visit a website. jaya77 uses the following categories of cookies:

• Strictly necessary cookies: Essential to the operation of the Platform. These include session authentication cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without rendering the Platform non-functional.
• Functional cookies: Used to remember your preferences such as language settings and your last-visited game category, so that your experience is consistent across sessions.
• Analytics cookies: Used to collect anonymised data about how visitors interact with the Platform, including which pages are most visited and where users encounter errors. This data helps jaya77 improve the Platform experience. Analytics data is aggregated and not associated with any individual member profile.
• Performance cookies: Used to monitor Platform performance, server response times, and load balancing to ensure a reliable and responsive experience for all members across Bangladesh, from Dhaka to Chittagong, Sylhet, Khulna, and beyond.

You may configure your browser to refuse some or all cookies, or to alert you when cookies are being set. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling functional or analytics cookies will not prevent you from accessing the Platform but may reduce personalisation features.

10. Your Data Rights

Subject to applicable law and certain conditions, you hold the following rights in relation to your personal data processed by jaya77. To exercise any of these rights, please contact us at [email protected]. We will respond to all verified requests within 30 days.

• Right of access: You may request a copy of the personal data jaya77 holds about you, along with information about how it is being processed.
• Right to rectification: If any personal data jaya77 holds about you is inaccurate or incomplete, you may request that it be corrected or updated. Please note that jaya77 cannot alter identity data that has been verified against official documents without re-verification.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to jaya77's legal retention obligations. jaya77 cannot delete data it is legally required to retain (such as financial transaction records within the statutory retention period).
• Right to restriction: You may request that jaya77 temporarily restrict processing of your data in certain circumstances, such as while you contest the accuracy of the data or object to jaya77's use of it.
• Right to data portability: Where jaya77 processes your data on the basis of your consent or contractual necessity using automated means, you may request that the data be provided to you in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing carried out on the basis of jaya77's legitimate interests, including profiling for marketing purposes. You may also unsubscribe from marketing communications at any time by contacting [email protected].
• 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 that took place prior to withdrawal.

11. Minors

The jaya77 Platform is strictly intended for adults aged 18 years and above. jaya77 does not knowingly collect personal data from any person under the age of 18. If jaya77 discovers or is notified that personal data has been collected from a minor, that data will be deleted immediately and the associated account permanently closed.

If you are a parent or guardian and believe that a minor in your care has created a jaya77 account or submitted personal data to the Platform, please contact us immediately at [email protected]. We will investigate and act promptly upon receiving such a notification.

12. Changes to This Privacy Policy

jaya77 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or the services we offer. When material changes are made, jaya77 will notify registered members by email or via a prominent notice on the Platform prior to the change taking effect. The "Effective" date at the top of this Policy will be updated accordingly.

We encourage you to review this Policy periodically. Your continued use of the Platform after notification of any change constitutes your acceptance of the revised Policy. If you disagree with any changes, you must cease using the Platform and contact us to close your account.

13. Contact and Privacy Enquiries

All privacy-related requests, questions, and complaints should be directed to the jaya77 privacy team. We are committed to resolving all data-related concerns fairly and transparently.

If you are not satisfied with jaya77's response to a privacy complaint, you may seek independent resolution through a reputable third-party mediator or escalate the matter to a relevant data protection authority as applicable in your jurisdiction.