Privacy Policy 77bb – Your Data Protected by the LGPD

1Who We Are – The Data Controller

A 77bb is the data controller for personal data processed under this Privacy Policy. For the purposes of the General Data Protection Law (LGPD – Law No. 13,709/2018), a "controller" is the legal entity responsible for decisions regarding how personal data is collected, used, and protected.

This policy applies to all users who access or use the 77bb, whether through the website, the mobile app, or any other access channel made available by the company. It covers the processing of data related to registration, Sports Betting, casino games, poker, jackpot, Pix payments, and interactions with customer support.

2What Personal Data We Collect

A 77bb collects personal data at various points during your interaction with the platform. The table below summarizes the categories of data collected and the contexts in which this occurs:

2.1 Data We Do Not Collect

A 77bb does not collect sensitive data such as racial or ethnic origin, religious beliefs, political opinions, genetic data, or biometric data for systematic identification purposes. The only biometric data ever collected is the selfie used for identity verification during the KYC process, which is used solely to confirm that the document belongs to the account holder and is discarded after verification.

3How We Use Your Data and the Legal Basis for Doing So

Each data processing activity carried out by 77bb has a specific purpose and a legal basis under the LGPD. We do not process data without a clear justification. See the main purposes below:

3.1 Contract Performance

Legal basis: Art. 7, V of the LGPD – contract performance. We use your identification, financial, and behavioral data to create and manage your account, process deposits and withdrawals via Pix and boleto bancário, record bets, calculate winnings, and provide customer support. Without this data, the provision of 77bb would not be feasible.

3.2 Legal Obligation Compliance

Legal basis: Art. 7, II of the LGPD – compliance with a legal obligation. 77bb is required by law to verify user identity (KYC process), monitor financial transactions for anti-money laundering purposes (AML/CFT), retain records of bets and payments for the required period, and report suspicious activity to the relevant authorities.

3.3 Legitimate Interest

Legal basis: Art. 7, IX of the LGPD – legitimate interest. We use technical and behavioral data to detect fraud, prevent unauthorized access, personalize your platform experience (such as suggesting games based on your history), and send transactional communications about your account. Whenever we rely on legitimate interest, we carry out a balancing assessment to ensure your rights are not disproportionately affected.

3.4 Consent

Legal basis: Art. 7, I of the LGPD – consent. For marketing communications, personalized promotions, and non-essential cookies, we ask for your explicit consent. You may withdraw this consent at any time in your account settings or by emailing privacidade@77bb.life, without affecting your access to any other services provided by 77bb.

4Third-Party Data Sharing

A 77bb does not sell personal data. Full stop. However, to operate its services, we share data with specific partners, always on a contractual basis and strictly limited to the necessary purposes:

• Payment processors: To process transactions via Pix, boleto bancário, PicPay, Mercado Pago, and credit card, we share the necessary financial data with payment intermediaries. These partners are contractually required to use the data solely for processing purposes and to maintain security standards equivalent to those of 77bb.
• Game providers: Some game session data (such as anonymized user ID and bet amount) is shared with casino software providers for game operation and audit purposes. No identifiable data such as name or CPF is shared with game providers.
• Identity verification services: The KYC process uses specialized document verification partners. Documents submitted are processed by these partners exclusively to confirm identity and are not retained beyond what is necessary.
• Legal authorities: When required by law, court order, or request from a competent authority, 77bb is required to share data with government bodies, tax authorities, or regulatory entities. This includes COAF, the Federal Revenue Service, and other entities with legal authority to request such data.
• Independent auditors: For compliance and security purposes, external auditors may have access to anonymized or aggregated data. Identifiable data is shared with auditors only under a confidentiality agreement and on a strictly need-to-know basis.

5International Data Transfer

Some technology partners of 77bb – such as cloud infrastructure providers and payment processors – may be located outside Brazil. When this occurs, data transfers are carried out only to countries that offer a level of protection equivalent to the LGPD, or under standard contractual clauses that guarantee the same rights to the data subject.

77bb maintains an up-to-date record of all countries to which data may be transferred and the mechanisms used to ensure protection at those destinations. This record is available upon request to the data protection officer (DPO) at privacidade@77bb.life.

Under no circumstances is personal data of Brazilian users transferred to countries that do not provide adequate protection without the contractual and technical safeguard mechanisms required by the LGPD.

6How We Protect Your Data

The security of personal data belonging to users of 77bb is a responsibility we take seriously. We have implemented technical and organizational controls across multiple layers:

6.1 Technical Measures

• Encryption in transit: All communication between your device and 77bb's servers is protected by TLS 1.3 encryption — the same protocol used by digital banks like Nubank and Itaú.
• Encryption at rest: Sensitive data stored in 77bb's databases is encrypted at rest. Passwords are stored using bcrypt hashing — never in plain text.
• Access controls: Internal access to user data follows the principle of least privilege. Only team members with a specific need are granted access to identifiable data, with full audit trail tracking.
• Security testing: 77bb's infrastructure undergoes penetration testing (pentests) and vulnerability assessments conducted by independent security firms on a semi-annual basis.
• Two-factor authentication (2FA): Available to all users and mandatory for internal administrative access.

6.2 Organizational Measures

• Regular data protection and LGPD training for all staff members;
• Security incident policy with a documented response plan;
• Data protection impact assessment (DPIA) for new processing activities;
• Data processing agreements with all third parties that access user data.

7Cookies and Tracking Technologies

A 77bb uses cookies and similar technologies to ensure the platform functions correctly, improve the user experience, and — with your consent — personalize content and communications. The cookies used fall into three categories:

7.1 Essential Cookies (non-negotiable)

These are strictly necessary for the platform to function. Without them, you cannot log in, place bets, or process payments on 77bb. Examples: session token, CSRF security cookie, language and region preferences. These cookies do not collect data for marketing purposes.

7.2 Performance Cookies (opt-out available)

These cookies collect anonymous information about how users navigate the platform, helping 77bb identify technical issues and improve the product. The data is aggregated and does not identify you individually. You can opt out of these cookies in your account settings.

7.3 Personalization Cookies (require consent)

Used to personalize your experience, such as remembering your betting preferences and suggesting games based on your history at 77bb. Activated only with your explicit consent and can be disabled at any time in your account's privacy settings.

77bb does not use third-party tracking cookies for targeted behavioral advertising. Your browsing habits within the platform are not shared with external ad networks.

8How Long We Retain Your Data

A 77bb retains personal data only for as long as necessary for the stated purposes or to meet legal and regulatory obligations. The main retention periods are:

• Identification and KYC data: for as long as the account remains active and for up to 5 years after closure, as required by anti-money laundering regulations.
• Financial transaction history (Pix, boleto, TED): 10 years from the transaction date, in compliance with the Brazilian Civil Code and BACEN regulations.
• Betting History: 5 years from the date of the bet, for audit and dispute resolution purposes.
• Support and communications data: 2 years after the support interaction is closed.
• Cookies and session data: depending on the cookie type (session cookies: deleted when the browser is closed; persistent cookies: up to 12 months or until consent is withdrawn).

Once the retention periods above expire, data is irreversibly anonymized or permanently deleted from the systems of 77bb, with no possibility of recovery.

9Your Rights as a Data Subject

The LGPD grants you, as the data subject whose information is processed by 77bb, the following rights, all exercisable free of charge and without excessive formalities:

To exercise any of these rights, please contact the data protection officer at 77bb by email at privacidade@77bb.life. All requests are responded to within 15 business days. In complex cases, this deadline may be extended by an additional 15 days, with prior notice to the data subject.

If you believe your rights have not been adequately addressed by 77bb, you may file a complaint directly with the ANPD (National Data Protection Authority), in accordance with Art. 18, § 1 of the LGPD.

10Protection of Minors' Data

The services provided by 77bb are strictly intended for individuals aged 18 and over. The platform does not intentionally collect data from minors under 18. The identity verification process (KYC) is designed to prevent minors from registering.

Should 77bb identifies that it has collected data from a user under 18, the account will be immediately closed, the data will be deleted, and any deposited funds will be returned to the rightful owner following a verification process. If you suspect that a minor has improperly used our platform, please contact us immediately at privacidade@77bb.life so we can act swiftly.

11Changes to This Privacy Policy

A 77bb may update this Privacy Policy to reflect changes in data processing practices, new legal requirements, or platform improvements. Any material change will be communicated with a minimum advance notice of 15 days by registered email and with a prominent notice on the platform.

The date of the last update is shown at the top of this page and in the document summary. Continued use of 77bb's services after a new version of this policy takes effect constitutes acceptance of the changes. If you do not agree with the changes, you may request account closure before the new version's effective date.

Previous versions of this policy are archived and available upon request to the data protection officer at privacidade@77bb.life.

12Contact, DPO & Support

A 77bb has appointed a Data Protection Officer (DPO) responsible for ensuring compliance with the LGPD and for handling data subject requests. For any questions, rights requests, or complaints related to the processing of personal data, please contact:

• DPO Email: privacidade@77bb.life
• General support: contato@77bb.life or live chat on the platform, available 24 hours a day
• Help center: visit the FAQ page for quick answers on privacy and data security

The DPO of 77bb responds to all personal data requests within 15 business days. For urgent requests related to security incidents or suspected account misuse, please reach out via live chat for immediate assistance.