Privacy Policy — ada7

1 About This Policy

This Privacy Policy ("Policy") describes how ada7 collects, uses, stores, shares, and protects the personal data of individuals ("you", "your", "User") who access or use the ada7 platform at https://ada7.io (the "Platform"), including all associated betting, casino, crash game, and customer support services.

This Policy applies to all Users worldwide, including players accessing ada7 from Bangladesh, and covers data collected through the Platform, through communications with our support team, and through technical means such as cookies and server logs.

By registering an account on ada7 or by continuing to use the Platform after this Policy has been published or updated, you confirm that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein.

2 Data Controller

For the purposes of this Policy, ada7 acts as the data controller in respect of all personal data collected from Users of the Platform. As data controller, ada7 determines the purposes for which and the means by which personal data is processed.

ada7 operates as an internationally licensed offshore platform. Formal written inquiries regarding data protection matters may be directed to ada7 via the contact channels described in Section 16 of this Policy. ada7 does not publish its registered office address publicly on the Platform; please contact support to obtain the current registered business address for formal correspondence purposes.

3 Personal Data We Collect

ada7 collects personal data in several categories, depending on how you interact with the Platform. The categories below set out exactly what information we may hold about you.

4 How We Collect Your Data

ada7 collects personal data through the following channels:

4.1 Direct Collection

Data you provide voluntarily when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, participate in promotions, or update your account profile. All fields presented during registration are mandatory unless clearly marked as optional.

4.2 Automated Collection

Data collected automatically as you use the Platform, including server logs that record your IP address, session timestamps, and pages accessed. Automated collection also includes data gathered through cookies, pixel tags, and similar tracking technologies — described in detail in Section 8 of this Policy.

4.3 Third-Party Sources

Data received from third parties to assist with identity verification, fraud prevention, and payment processing. This may include identity check results from KYC service providers, transaction verification data from mobile wallet operators (bKash, Nagad, Rocket), and risk scoring data from fraud prevention partners. ada7 uses such data solely for the purposes stated in Section 5 and does not combine it with your personal data for advertising profiling.

4.4 Device Fingerprinting

For the purposes of enforcing our single-account policy, detecting bonus abuse, and preventing fraud, ada7 may employ device fingerprinting technology. This involves collecting a set of technical attributes from your device that, when combined, form a unique identifier. This data is processed solely for security and integrity purposes and is not used for marketing.

5 How We Use Your Personal Data

ada7 uses your personal data for the following specific purposes. We rely on appropriate legal bases for each purpose, as set out in Section 6.

6 Legal Bases for Processing

ada7 processes your personal data on the following legal bases:

• Contract Performance: Processing that is necessary to provide the services you have requested, including operating your account, processing transactions, and delivering customer support.
• Legal Obligation: Processing required for ada7 to comply with applicable laws and regulatory obligations, including KYC/AML requirements.
• Legitimate Interest: Processing undertaken in pursuit of ada7's legitimate business interests — such as fraud prevention, platform security, and product improvement — where those interests are not overridden by your privacy rights.
• Consent: Where processing is based on your consent (for example, optional marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal. Consent withdrawal does not affect your ability to use the Platform.

7 Data Sharing & Third Parties

7.1 Categories of Recipients

ada7 may share your personal data with the following categories of third parties, strictly on a need-to-know basis and under contractual data protection obligations:

• Payment Processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, and City Bank — to facilitate deposits and withdrawals in BDT.
• Identity Verification Providers: Third-party KYC service providers used to verify the identity and age of Users during the registration and verification process.
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed game studios whose products are integrated into the Platform. These providers receive only the minimum data necessary to render their games and record session outcomes.
• Fraud Prevention & Risk Management Services: Specialist providers engaged to assist with detecting and preventing fraudulent activity, bonus abuse, and money laundering.
• Cloud & Infrastructure Providers: Hosting, database, and content delivery providers operating the technical infrastructure that underpins the Platform, subject to strict data processing agreements.
• Legal and Regulatory Authorities: Law enforcement agencies, regulators, tax authorities, or courts where ada7 is required by law or legal process to disclose information.

7.2 No Sale of Personal Data

ada7 does not sell, rent, lease, or otherwise commercially exploit your personal data to any third party for their own marketing, advertising, or profiling purposes. This prohibition is absolute and without exception.

7.3 Business Transfers

In the event that ada7 undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any resulting changes to this Policy via the Platform or by email.

8 Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by the Platform when you access it via a browser. They allow the Platform to recognise your device on subsequent visits, remember your preferences, maintain your session, and collect usage data for analytics and security purposes.

8.2 Types of Cookies Used by ada7

• Strictly Necessary Cookies: Essential to the operation of the Platform. These cookies maintain your session, enforce security controls, remember your login state, and prevent cross-site request forgery. The Platform cannot function without them and no consent is required for their use.
• Functional Cookies: Remember preferences you have set on the Platform, such as language settings and display preferences, to improve your experience on return visits.
• Analytics Cookies: Collect aggregated, anonymised data about how Users navigate and interact with the Platform, enabling ada7 to identify usability improvements and optimise content. These cookies do not identify you personally.
• Security Cookies: Used for fraud detection, device fingerprinting, and the enforcement of our single-account policy. These cookies are necessary for the integrity of the Platform.

8.3 Managing Cookies

You may manage or disable cookies through your browser settings at any time. Note that disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from logging in or completing transactions. ada7 does not use third-party advertising cookies or behavioural tracking cookies for advertising retargeting.

9 Data Retention

ada7 retains personal data only for as long as is necessary for the purpose for which it was collected, unless a longer retention period is required by law or regulatory obligation.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to any identifiable individual.

10 Security Measures

ada7 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or device and the ada7 Platform is encrypted in transit using industry-standard TLS 1.2 or higher protocols.
• Encrypted Data Storage: Sensitive personal data — including identity documents and financial details — is stored in encrypted form at rest using AES-256 encryption on secured cloud infrastructure.
• Access Controls: Access to personal data within ada7's internal systems is restricted on a strict need-to-know basis. Employees and contractors are granted the minimum level of data access required to perform their role, and all access is logged and audited.
• Multi-Factor Authentication: Administrative access to systems that store or process personal data requires multi-factor authentication.
• Penetration Testing & Security Audits: ada7 conducts regular security assessments and penetration tests to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: ada7 maintains a documented data breach response plan. In the event of a confirmed breach that creates a material risk to Users, affected individuals will be notified without undue delay.

11 Your Data Rights

You hold the following rights in respect of the personal data ada7 holds about you. To exercise any of these rights, please contact our support team via live chat or at [email protected]. ada7 will respond to all verified requests within 30 days of receipt.

• Right of Access: You have the right to request a copy of the personal data ada7 holds about you, together with information about how it is being used.
• 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 or updated.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ada7's legal retention obligations. Note that data subject to regulatory retention requirements (e.g., AML records) cannot be deleted before the mandatory period has elapsed.
• Right to Data Portability: You may request that ada7 provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to Restriction of Processing: You may request that ada7 restrict the processing of your data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to Object: Where processing is based on ada7's legitimate interests, you have the right to object to that processing. ada7 will cease processing unless there are compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

12 Children's Privacy

The ada7 Platform is strictly intended for adults aged 21 years and over. ada7 does not knowingly collect or process personal data relating to persons under the age of 21. If you are under 21, you must not register an account or use the Platform.

If ada7 becomes aware that personal data has been collected from a person under the age of 21, we will immediately close that account, delete the personal data, and take appropriate action in accordance with our Terms & Conditions and applicable law.

If you believe that ada7 may have inadvertently collected data from an individual under the age of 21, please notify us immediately at [email protected] so that we can investigate and take prompt corrective action.

13 International Data Transfers

ada7 operates as an internationally licensed offshore platform. As a result, your personal data may be transferred to and processed in countries outside Bangladesh, including the country in which ada7's infrastructure and game providers are hosted.

Where personal data is transferred internationally, ada7 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy. Such safeguards may include contractual data processing agreements with third-party recipients that impose obligations consistent with internationally recognised data protection standards.

By using the Platform and accepting this Policy, you consent to the transfer of your personal data to jurisdictions outside Bangladesh for the purposes described in this Policy. If you have concerns about specific international transfers, please contact us at [email protected].

14 Third-Party Links

The ada7 Platform may contain references to game providers and payment partners whose services are integrated within the Platform. These third parties operate under their own privacy policies and data practices. ada7 is not responsible for the privacy practices of game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi, nor for the data handling practices of payment partners such as bKash, Nagad, or Rocket.

We recommend that you review the privacy policies of any third-party service providers whose products you interact with through the Platform. ada7 does not publish external links to third-party websites from the Platform, but game providers and payment gateways may independently process data you submit directly to their own systems during gameplay or payment processing.

15 Policy Updates

ada7 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, ada7 will notify registered Users by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your account.

The "Last updated" date at the top of this page reflects the date on which the most recent changes took effect. We encourage you to review this Policy periodically to remain informed about how ada7 protects your personal data.

Your continued use of the Platform after any update to this Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must cease using the Platform and may request account closure by contacting support.

16 Contact Us

For all privacy-related inquiries, data subject rights requests, complaints about how ada7 handles your personal data, or questions about this Policy, please contact the ada7 data protection team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 directly within your ada7 account dashboard
• Response Time: Under 2 hours for live chat; within 30 days for formal written data rights requests (Bangladesh Standard Time, UTC+6)

When submitting a formal data rights request by email, please include your full name, registered email address, and a clear description of the right you wish to exercise or the nature of your complaint. ada7 may request additional verification to confirm your identity before processing your request.