Privacy Policy – 78ttbet: Your Data Protected

1. Personal Data Controller

The controller responsible for processing your personal data is 78ttbet, a sports betting and online casino platform operated under the 78ttbet brand and accessible at 78ttbet.click. For the purposes of this Policy, "controller" means the entity that determines the purposes and means by which personal data is processed, as defined by the General Data Protection Law (LGPD — Law No. 13,709/2018).

78ttbet has appointed a Data Protection Officer (DPO), who can be reached at privacidade@78ttbet.click for matters related to personal data processing, the exercise of rights, or any other questions about this Privacy Policy.

2. Data We Collect

78ttbet collects only the personal data necessary to provide its services and fulfill legal obligations. The data collected falls into the following categories:

2.1 Registration and Identification Data

• Full name as it appears on your government-issued ID;
• CPF (Individual Taxpayer Registration);
• Date of birth;
• Email address;
• Mobile phone number (optional, but required for two-factor authentication);
• Full residential address and ZIP code.

2.2 Identity Verification Data (KYC)

• Front and back images of a government-issued ID (National ID, Driver's License, or Passport);
• Recent proof of address;
• Verification selfie for matching against the provided ID document;
• Proof of ownership of the payment method used, when requested.

2.3 Financial & Transaction Data

• Pix key registered for deposits and withdrawals;
• Full history of deposits, withdrawals, and transfers;
• Partial credit or debit card details (masked number, card brand, and expiry date — never the full CVV);
• Account data from platforms such as Mercado Pago and PicPay, when used.

2.4 Platform Usage and Behavioral Data

• Full sports betting history (markets, odds, amounts wagered, and results);
• Casino game history (titles played, amounts wagered, and results);
• Access session logs with timestamps;
• Pages and sections visited within the platform;
• Interactions with features such as cash out, the VIP program, and promotions.

2.5 Technical & Device Data

• Access IP address;
• Device type and model (mobile phone, tablet, or computer);
• Operating system and browser version;
• Device identifiers (cookies, localStorage, browser fingerprint);
• Approximate geolocation data derived from IP address.

2.6 Support Communications

• Content of messages sent to support via live chat, email, or WhatsApp;
• Support call recordings (where applicable and with prior notice to the user).

3. Purpose of Data Processing

78ttbet processes your personal data exclusively for the purposes listed below. No data is collected in a generic manner or for undefined purposes:

• Provision of contracted services: account creation and management, processing of deposits and withdrawals via Pix and other methods, settlement of sports bets and casino games;
• Identity verification (KYC): confirmation that the user is over 18, is the holder of the payment method used, and does not appear on any regulatory restriction lists;
• Fraud and money laundering prevention: detection of suspicious behavioral patterns, verification of financial transactions, and fulfillment of reporting obligations under Brazilian law;
• Customer support: handling inquiries, resolving disputes, and account-related communications;
• Marketing communications: sending information about promotions, bonuses, and news from 78ttbet — only to users who have not opted out of such communications;
• Experience personalization: presentation of the most relevant games and sports markets based on your usage history;
• Responsible gambling: monitoring behavioral patterns that may indicate problematic platform use, in order to trigger responsible gambling tools;
• Compliance with legal and regulatory obligations: responding to requests from competent authorities, mandatory reporting, and audits.

4. Legal Basis for Processing (LGPD)

All personal data processing carried out by 78ttbet is grounded in one or more of the legal bases established under the LGPD:

• Contract performance — processing necessary to provide the services contracted by the user upon account creation and use of the platform (Art. 7, V, LGPD);
• Compliance with a legal or regulatory obligation — identity verification data, financial data, and transaction records processed to meet legal requirements such as KYC and anti-money laundering regulations (Art. 7, II, LGPD);
• Legitimate interest — usage, behavioral, and technical data processed for fraud prevention, platform security, and service improvement, provided this does not override the data subject's fundamental rights (Art. 7, IX, LGPD);
• Consent — marketing communications and use of non-essential cookies, which may be withdrawn at any time (Art. 7, I, LGPD).

5. Sharing Data with Third Parties

78ttbet never sells personal data to third parties. Sharing only occurs in the situations described below, always with an adequate legal basis and confidentiality and data protection agreements in place:

5.1 Essential Service Providers

To operate the platform, 78ttbet works with partners that process data on its behalf:

• Payment processors: financial institutions and payment processors to handle transactions via Pix, bank slip (boleto), credit/debit card, Mercado Pago, and PicPay. These partners receive only the data strictly necessary to complete each transaction;
• Casino game providers: Evolution Gaming, PG Soft, Pragmatic Play, and other certified providers receive anonymized session identifiers to record game history. No personally identifiable data such as CPF or email is transmitted to game providers;
• Identity verification services (KYC): companies specializing in document verification that process identity documents in a secure, encrypted environment;
• Technology infrastructure: server and cloud hosting providers that store data in environments with strict security controls.

5.2 Authorities and Legal Obligations

78ttbet may share data with public authorities, regulatory bodies, or government entities when required by law, court order, or formal request from a competent authority. In such cases, we will share only the data specifically requested, to the minimum extent necessary to comply with the requirement.

6. International Data Transfers

Some of 78ttbet's service providers — particularly casino game providers and technology infrastructure services — operate servers located outside Brazil. When personal data is transferred to other countries, 78ttbet contractually requires the recipient to apply a level of protection equivalent to that established by the LGPD, including:

• Standard contractual clauses for data protection;
• Certified corporate privacy policies;
• Compliance with local regulations equivalent to the LGPD, such as the European GDPR, where applicable.

78ttbet maintains an up-to-date record of all international data transfer flows and makes this information available to any data subject who requests it by contacting the DPO.

7. Data Security

78ttbet implements appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, destruction, or improper disclosure. The main measures in place are:

• Encryption in transit: all communications between your device and 78ttbet's servers are protected by a TLS/SSL protocol with a 256-bit certificate, ensuring no data can be intercepted during transmission;
• Encryption at rest: sensitive data — such as identity documents, banking details, and KYC information — is stored with AES-256 encryption on 78ttbet's servers;
• Access control: only employees with a specific operational need are granted access to users' personal data, with a full log of all queries and operations carried out;
• Two-factor authentication: available to all users and required for sensitive operations such as changes to registration data and withdrawals above a certain amount;
• Continuous monitoring: automated intrusion detection and suspicious activity monitoring systems operate 24 hours a day across 78ttbet's environments;
• Security testing: the platform conducts periodic penetration tests and security audits carried out by independent specialized firms.

In the event of a security incident that may put your personal data at risk, 78ttbet will notify the National Data Protection Authority (ANPD) and the affected data subjects within the timeframes set out by the LGPD.

8. Data Retention and Deletion

78ttbet retains your personal data for as long as necessary for the purposes for which it was collected, or for the minimum period required by applicable law:

• Registration and KYC data: retained for the period during which the account remains active and for at least five years after account closure, in accordance with anti-money laundering compliance requirements;
• Financial transaction data: retained for a minimum of five years as required by Brazilian Central Bank regulations and tax legislation;
• Betting and game history: retained for a minimum of two years after the last account activity;
• Customer support communication data: retained for a minimum of two years for dispute resolution and quality audit purposes;
• Marketing and preference data: deleted immediately upon withdrawal of consent by the data subject.

After the retention period ends, data is securely deleted or irreversibly anonymized so that the individual can no longer be identified.

9. Cookies and Tracking Technologies

78ttbet uses cookies and similar technologies to improve the user experience, ensure platform security, and measure service performance. The types of cookies used are:

You can manage your cookie preferences through the privacy settings panel available on the platform. Rejecting non-essential cookies does not affect access to 78ttbet's core features. Essential and security cookies cannot be disabled as they are required for the platform to operate securely.

10. Your Rights as a Data Subject (LGPD)

The LGPD grants you, as the data subject whose personal data is processed by 78ttbet, a set of rights that may be exercised at any time by submitting a request to our DPO:

• Right of access: request confirmation that 78ttbet processes your data and obtain a copy of all personal data we hold about you;
• Right to rectification: request the correction of incomplete, inaccurate, or outdated personal data;
• Right to erasure: request the deletion of your personal data processed on the basis of consent, except where retention is required by law;
• Right to data portability: request the transfer of your data to another service controller in a structured, machine-readable format;
• Right to object: object to the processing of data carried out on the basis of legitimate interest, where such processing disproportionately affects your rights;
• Right to withdraw consent: withdraw, at any time, consent given for specific processing activities, such as receiving marketing communications;
• Right to information: be informed about the public and private entities with which 78ttbet shares data;
• Right to lodge a complaint: file a complaint with the National Data Protection Authority (ANPD) in the event of non-compliance with this Policy or the LGPD.

To exercise any of these rights, send a written request to privacidade@78ttbet.click with the subject line "Data Subject Rights — LGPD", identifying yourself with your full name and CPF. We will respond within 24 hours to confirm receipt and within up to 15 business days to fulfill the request, in accordance with the deadlines established by the LGPD.

11. Minors

78ttbet's services are intended exclusively for individuals who are 18 years of age or older. 78ttbet does not knowingly collect personal data from minors. If we identify that an account was created by someone under 18, we will immediately close the account and delete all associated data, as required by minor protection legislation and the LGPD.

If you suspect that a minor has created an account on 78ttbet, please notify our team immediately at suporte@78ttbet.click. We treat these cases as the highest priority.

12. Changes to this Privacy Policy

78ttbet may update this Privacy Policy periodically to reflect changes in data processing practices, applicable legislation, or platform features. Significant changes will be communicated via the registered email address and through an in-platform notification at least seven days before they take effect.

The date of the last update to this Policy is displayed at the top of the document and at the beginning of this section. We recommend that you review this Policy periodically. Continued use of the platform after any changes take effect constitutes acceptance of the new practices described.

13. Contact the Data Protection Officer (DPO)

For any questions regarding the processing of your personal data, the exercise of your rights as a data subject, or this Privacy Policy, please contact 78ttbet's Data Protection Officer (DPO):

• DPO Email: privacidade@78ttbet.click
• General Support Email: suporte@78ttbet.click
• Response time: up to 24 hours to confirm receipt; up to 15 business days for full completion of the request