Privacy Policy for moja77

moja77 ("we", "us", "our") operates the online gaming and sports betting platform accessible at https://moja77.bet (the "Platform"). This Privacy Policy describes how we collect, use, disclose, store, and protect personal information relating to players, prospective players, and visitors to the Platform (collectively "you").

This Policy applies to all personal data processed by moja77 in connection with the provision of its Services, including account registration, identity verification, payment processing, customer support interactions, marketing communications, and the use of cookies and similar tracking technologies on the Platform.

By accessing or using the Platform, or by creating a moja77 account, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices it describes. If you do not agree with this Policy, you must not use the Platform or create an account.

This Policy should be read alongside our Terms & Conditions, which govern your overall use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail.

For the purposes of applicable data protection legislation, moja77 is the data controller in respect of personal data collected through the Platform. As data controller, moja77 determines the purposes for which and the means by which personal data is processed.

All data protection queries, subject access requests, and consent withdrawal notices should be directed to our support team. Contact details are provided in Section 13 of this Policy.

We collect personal data from you directly (when you provide it to us) and indirectly (automatically through your use of the Platform). The categories of personal data we collect include:

Identity and Contact Data

• Full legal name as it appears on your official identification document.
• Date of birth (used to verify that you are 21 years of age or older).
• Residential address, including district and division within Bangladesh (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi).
• Mobile phone number, including the number registered to your bKash, Nagad, or Rocket mobile financial service account.
• Email address (if provided during registration or subsequent account updates).
• National Identity Card (NID) number or passport number, provided during KYC verification.

Financial and Transaction Data

• Details of deposits and withdrawals, including amounts, timestamps, and payment method references.
• Mobile financial service account identifiers (e.g., your bKash or Nagad wallet number) used to process transactions.
• Bank account details where transactions are processed through Dutch-Bangla Bank, City Bank, BRAC Bank, or other supported institutions.
• Records of wagers placed, game outcomes, bonus activations, and withdrawal requests.

Technical and Usage Data

• IP address and approximate geographic location derived from it.
• Device type, operating system, browser type and version.
• Session duration, pages viewed, navigation paths within the Platform, and game interaction data.
• Cookie identifiers and similar tracking data (see Section 9 for full details).

Communications Data

• Records of your communications with our customer support team, including support tickets, live chat transcripts, and email correspondence.
• Responses to surveys, feedback forms, or promotional communications where you have chosen to participate.

Verification Documents

• Copies of identity documents submitted during KYC verification, including photographs of your NID, passport, or other government-issued identification.
• Proof of address documents where requested.
• Selfie photographs submitted as part of liveness verification processes.

We use the personal data we collect for the following purposes. In each case, we have identified the legal basis on which the processing activity relies:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first notifying you and, where required, obtaining your additional consent.

moja77 does not sell, rent, or trade your personal data to unaffiliated third parties. We may, however, share your personal data with carefully selected third parties in the following circumstances:

• Payment Service Providers: We share necessary transaction data with mobile financial service operators (bKash, Nagad, Rocket, Upay) and banking partners (Dutch-Bangla Bank, City Bank, BRAC Bank) strictly for the purpose of processing your deposits and withdrawals.
• Game Technology Providers: Our casino platform integrates games from providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may receive limited technical data (such as session tokens and bet records) necessary to operate their games within the Platform. They are contractually prohibited from using this data for their own marketing purposes.
• Identity Verification Services: We use third-party KYC and identity verification services to authenticate player identities and comply with age verification requirements. These services process the identity documents and biometric data you submit as part of the verification process.
• Regulatory and Law Enforcement Authorities: We may disclose personal data to regulators, law enforcement agencies, or other competent authorities where required by applicable law, a court order, or a legitimate regulatory investigation. In such cases, we will only disclose the minimum amount of data necessary to satisfy the legal requirement.
• Fraud Prevention Networks: We may share data with industry fraud prevention networks and databases to protect the Platform and its players from fraudulent activity, account takeover attempts, and money laundering.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or substantially all of moja77's assets, your personal data may be transferred to the acquiring entity as part of the transaction. We will notify you of any such transfer that materially affects your privacy rights.

All third parties with whom we share personal data are required to maintain appropriate technical and organisational security measures and to use your data only for the specific purposes authorised by moja77.

As an online platform, moja77 may process and store personal data on servers located outside Bangladesh. Where personal data is transferred to a jurisdiction that does not provide the same level of data protection as the laws applicable to our operations, we take steps to ensure that appropriate safeguards are in place. These may include data processing agreements incorporating standard contractual clauses, or equivalent protective mechanisms recognised under applicable law.

Where personal data is transferred to game technology providers such as Pragmatic Play or Evolution Gaming, such transfers are governed by data processing agreements that bind these providers to data protection standards consistent with this Policy.

We retain your personal data for as long as your moja77 account remains active and for a period thereafter as required to fulfil the purposes set out in this Policy or to comply with our legal obligations. The following retention periods apply as a general guide:

When personal data is no longer required for any legitimate purpose, we securely delete or anonymise it in accordance with our internal data disposal procedures.

As a moja77 player, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at the details provided in Section 13. We will respond to all verified requests within 30 days:

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to Rectification: If the personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. Note that this right is subject to limitations where retention is required by law or to protect legitimate interests (e.g., pending withdrawal processing or active fraud investigation).
• Right to Restriction: You may request that we restrict the processing of your personal data where you dispute its accuracy, where processing is unlawful, or where we no longer need the data but you require it for a legal claim.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on our legitimate interests, including direct marketing. We will cease direct marketing activities promptly upon receipt of such an objection.
• 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 carried out before the withdrawal.

moja77 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device that allow us to recognise your browser and remember certain information about your session and preferences.

We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the operation of the Platform. These include cookies that maintain your login session, store your language and currency preferences, and enable secure payment processes. These cookies cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymised data about how visitors use the Platform — including pages visited, session duration, and error encounters. This data helps us identify and fix performance issues and improve the overall user experience.
• Functional Cookies: Used to remember your preferences across sessions, such as your preferred game categories (e.g., cricket betting, slots) and notification settings.
• Marketing Cookies: Used to deliver promotional content relevant to your interests, including offers related to BPL cricket season, Eid promotions, and slot tournaments. These cookies are set only where you have given consent.

You may manage cookie preferences through your browser settings. Note that disabling certain categories of cookies may affect the functionality and performance of the Platform. Strictly necessary cookies cannot be disabled through browser settings while continuing to use the Platform.

moja77 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including stored KYC documents and financial records.
• Access controls ensuring that personal data is accessible only to moja77 personnel and contractors who require it to perform their duties.
• Regular security audits and penetration testing by qualified third-party security professionals.
• Multi-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Comprehensive incident response procedures to detect, assess, and respond to data security breaches in a timely manner.

While we take all reasonable steps to protect your personal data, no security system is entirely impenetrable. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and any applicable regulatory authority in accordance with our legal obligations.

The moja77 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21. If we discover, through our KYC process or any other means, that a registered account belongs to a person under 21, we will immediately close that account, delete all associated personal data to the extent permitted by law, and forfeit any associated balance in accordance with our Terms & Conditions.

If you believe that a minor has created an account on the Platform, please notify us immediately at [email protected] so that we can investigate and take appropriate action.

moja77 reserves the right to update or revise this Privacy Policy at any time. The most current version will always be published on this page, identified by the effective date shown at the top of the document. We encourage you to review this Policy periodically to stay informed about how we protect your data.

Where a material change is made to this Policy — such as a significant change in the categories of data we collect, the purposes for which we use it, or the third parties with whom we share it — we will endeavour to notify registered players via the mobile number or email address on file. However, the absence of such a direct notification does not affect the validity or enforceability of the revised Policy.

Your continued use of the Platform following the publication of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the revised Policy, you must stop using the Platform and request account closure.

For any questions, concerns, or requests relating to this Privacy Policy or the personal data we hold about you, please contact the moja77 data protection team using the details below. All communications should be in English to ensure they are routed and processed correctly.