771b Privacy and Data Protection Policy

1. Overview and Data Controller

This Privacy Policy describes how 771b, operated by 771b Gaming Ltd. and accessible at 771b.best, collects, uses, stores, shares, and protects its users' personal data, in full compliance with Brazil's General Data Protection Law (LGPD – Law No. 13.709/2018) and all other applicable regulations in Brazil.

771b acts as the controller of personal data provided during use of the platform. This means we are responsible for determining the purposes and means by which your data is processed. By creating an account, depositing via Pix, betting on the Brasileirão, playing slots, or accessing any platform feature, you acknowledge that you have read and understood this policy.

This Policy is an integral part of the Terms and Conditions of Use of 771b and should be read together with that document. In the event of any conflict between the two, the provision that offers greater protection to the user shall prevail.

2. What Personal Data 771b Collects

771b collects different categories of personal data depending on how you use the platform. Below, we list the types of data and the situations in which each is collected:

Identification and registration data:

Financial and payment data:

Platform usage and behavioral data:

Technical and device data:

Verification documents (KYC):

3. How We Collect Your Data

771b collects personal data through the following channels and situations:

• Account registration: when creating your account, you voluntarily provide your name, CPF, email, phone number, date of birth, and address.
• Financial transactions: when you make deposits via Pix, bank slip, credit or debit card, PicPay, Mercado Pago, or TED transfer, we collect the data required to process and record each transaction.
• Platform usage: when you browse the site, play slots, crash games, poker, bet on the Brasileirão, or use any other features, we automatically collect behavioral data through cookies and similar technologies.
• Identity verification (KYC): when requested, you submit identification documents to increase withdrawal limits or meet regulatory requirements.
• Support contact: when you interact with the 771b team via chat or email, those communications are logged for record-keeping and service improvement purposes.
• Third-party sources: in specific fraud prevention cases, we may consult public databases or those of authorized partners to validate information provided by the user.

4. Data Processing Purposes

771b uses the personal data collected solely for the purposes described below. We do not use your data for purposes incompatible with the original reason it was collected without prior notice and, where required, renewed consent.

5. Legal Basis for Data Processing

Every personal data processing operation carried out by 771b is grounded in at least one of the legal bases set out in the LGPD. The applicable legal basis for each purpose is indicated in the table in the previous section. In summary, the main bases used are:

• Contract performance (art. 7, V of the LGPD): processing is necessary to fulfill the contract entered into with the user upon account creation, making deposits via Pix, and processing withdrawals. Without this data, it is not possible to operate the platform.
• Compliance with a legal obligation (art. 7, II): identity verification (KYC) and anti-money laundering controls are required by Brazilian law applicable to payment platforms and digital entertainment.
• Legitimate interest (art. 7, IX): behavioral analytics for fraud prevention, experience personalization, and platform improvement are carried out on the basis of 771b's legitimate interest, provided they do not infringe on users' rights.
• Consent (art. 7, I): sending marketing communications and using non-essential cookies requires your explicit consent, which may be withdrawn at any time.

6. Data Sharing with Third Parties

771b does not sell, rent, or share personal data with third parties for commercial or advertising purposes. Data sharing occurs only in the strictly necessary situations described below:

• Payment processors: financial data is shared with certified payment gateways to process transactions via Pix, bank slip, credit and debit card, PicPay, Mercado Pago, and TED. These partners act as data processors under contract and are bound by confidentiality obligations.
• Game providers: technical session identifiers are shared with slots, crash games, and live casino providers to operate the games. This data does not include full financial information or identity documents.
• Analytics and security tools: anonymized or pseudonymized technical data may be processed by behavioral analytics and fraud detection tools, always under contractual data protection measures.
• Public authorities: 771b may be legally required to share data with Brazilian regulatory, judicial, or law enforcement authorities when there is a court order or applicable legal obligation. In such cases, we share only what is strictly necessary.
• Identity verification services: documents submitted for the KYC process may be reviewed by specialized identity verification and document authenticity services, under data processing agreements.

7. Data Retention and Storage

771b retains personal data only for as long as strictly necessary to fulfill the purposes described in this policy. The criteria used to determine retention periods are:

• Active account data: retained for the entire duration of the account on the platform, including betting history, financial transactions, and usage preferences.
• Financial and transaction data: retained for a minimum of 5 years after account closure, in accordance with applicable tax and anti-money laundering legislation in Brazil.
• Verification documents (KYC): retained for the legally required period under anti-money laundering regulations, generally 5 to 10 years after the end of the relationship with the user.
• Usage and behavioral data: non-identified or anonymized data may be retained indefinitely for statistical purposes and platform improvement.
• After account closure at the user's request: identifiable personal data is anonymized or deleted within 30 days, except where retention is required by law.

Data is stored on servers with encryption at rest, housed in data centers with physical and logical security certifications. Internal access is restricted by role-based access controls (RBAC), ensuring that only staff with a legitimate operational need can access sensitive information.

8. Data Security

771b implements technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, destruction, or accidental loss. The main safeguards in place are:

• SSL/TLS 256-bit encryption: all communication between your browser or mobile device and 771b's servers is encrypted to the same standard used by Brazil's major banks, such as Itaú, Bradesco, and Banco do Brasil.
• Encryption at rest: sensitive data stored on 771b's servers is encrypted at rest, making it unreadable even in the event of unauthorized physical access to the server.
• Two-factor authentication (2FA): available to protect account access and confirm sensitive operations such as withdrawals and changes to account details.
• Continuous monitoring: automated systems monitor access and transaction patterns in real time, identifying and blocking suspicious behavior before it causes any impact.
• Internal access control: 771b staff only access the data necessary for their specific roles. Access to sensitive data is logged and audited on a regular basis.
• Security testing: the platform undergoes periodic vulnerability assessments and penetration tests carried out by specialized teams.

In the event of a security incident involving personal data that may pose a risk to affected users, 771b will report the occurrence to the National Data Protection Authority (ANPD) and notify affected users within the timeframes established by the LGPD, providing information about the nature of the incident and the measures taken.

9. Cookies and Tracking Technologies

771b uses cookies and similar technologies to ensure the platform works correctly, analyze usage behavior, and personalize the experience. See the types of cookies used:

Essential and security cookies cannot be disabled, as they are required for the basic and secure functioning of the platform. For all others, you can manage your preferences through your browser settings. Note that disabling functional cookies may affect your 771b experience, such as having to reset preferences on every visit.

10. Your Rights as a Data Subject (LGPD)

The LGPD grants you a set of rights over your personal data. 771b is committed to respecting and facilitating the exercise of all these rights:

To exercise any of these rights, please contact our Data Protection Officer (DPO) by email at suporte@771b.best, specifying the right you wish to exercise, the data involved, and a copy of a photo ID for verification. Response time is up to 15 business days, as provided under the LGPD.

11. Protection of Minors

771b's services are intended exclusively for individuals aged 18 or older. The platform does not intentionally collect personal data from minors, and registration by minors is strictly prohibited by the Terms and Conditions.

771b takes the following measures to prevent access by minors:

• Date of birth verification at registration, with automatic blocking for users under 18.
• Requiring a valid CPF, which allows cross-referencing with official databases for age verification.
• Identity verification process (KYC) involving official photo ID analysis for users who reach certain transaction thresholds.
• Monitoring of usage patterns that may indicate access by a minor.

If you identify that an account has been created by a minor, contact 771b support immediately. The account will be closed and all collected data will be deleted, except where retention is required by law.

Parents and guardians who wish to prevent minors from accessing online gaming platforms can use parental control tools available on Android, iOS, and major web browsers.

12. Changes to this Privacy Policy

771b may periodically review and update this Privacy Policy to reflect operational, legal, or technological changes. Any update that significantly affects your rights as a data subject will be communicated at least 7 days in advance by email and through a prominent notice on the platform.

The most up-to-date version of this policy will always be available on this page, showing the date of the last revision. We recommend checking it periodically to stay informed about how 771b protects your data.

Continued use of the platform after a new version of this policy takes effect constitutes acceptance of the updated terms. If you do not agree with the changes, you may close your account before the effective date and request deletion of your data.

13. Contact, Data Protection Officer (DPO) & Privacy Channel

To exercise your rights as a data subject, ask questions about this policy, or report any privacy-related issue at 771b, please use the channels below:

• DPO email / privacy channel: suporte@771b.best — include in the email subject line: "LGPD Request – [your right]". Response time is up to 15 business days.
• Support chat: available directly on the 771b.best platform, 24 hours a day, 7 days a week. For privacy-related matters, the chat will redirect you to the dedicated channel.

To help us handle your request efficiently, please include: the right you wish to exercise, a clear description of the data involved, and a copy of an official photo ID to verify your identity as the data subject.