Privacy Policy — How a171 Collects, Uses, and Safeguards Your Personal Data

This Privacy Policy ("Policy") is issued by a171 ("a171", "we", "us", or "our") and applies to all individuals who visit, register on, or otherwise interact with the a171 platform at https://a171.io ("Platform"), including through any mobile browser or compatible device. This Policy should be read alongside a171's Terms & Conditions, which govern the overall relationship between a171 and its registered Members.

a171 is committed to protecting the privacy of every person who engages with our Platform. We process personal data only for clearly defined, legitimate purposes and in a manner that is proportionate, transparent, and consistent with applicable data protection principles. This Policy explains in plain English what personal data we collect, how and why we process it, with whom we share it, how long we retain it, and what rights you have in relation to your own data.

a171 collects personal data in two broad categories: data you provide to us directly, and data we collect automatically during your use of the Platform. The table below summarises the categories of personal data we process:

a171 collects personal data through the following channels and mechanisms:

• Direct interactions: When you register an account, complete the KYC identity verification process, make a deposit or withdrawal, contact support via live chat or email, or update your account settings, you provide personal data directly to a171.
• Automated technologies: When you visit and interact with the a171 Platform, we automatically collect Technical Data and Usage Data through server logs, cookies, pixel tags, and similar tracking technologies. For full details, see Section 9 (Cookies and Tracking).
• Payment providers: When you initiate a deposit or withdrawal via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, our payment processing partners share transaction confirmation data with a171 to credit or debit your account wallet.
• Identity verification partners: Where a171 uses a third-party KYC service provider to assist with document verification, that provider shares the outcome of the verification (pass/fail and the verified data fields) with a171.
• Game providers: Game providers such as Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, and Spribe may share session-level game data (game round IDs, bet amounts, outcomes) with a171 for account crediting, dispute resolution, and responsible gaming monitoring purposes.
• Publicly available sources: In limited circumstances (for example, during enhanced due diligence checks), a171 may consult publicly available sources such as sanctions lists or adverse media databases to verify account information.

a171 processes your personal data only for the specific, legitimate purposes set out below. We do not process personal data in a manner that is incompatible with the purpose for which it was originally collected.

• Account registration and management: To create, maintain, and administer your a171 Member account, including verifying your identity, processing deposits and withdrawals, and providing access to Platform features.
• Age and identity verification (KYC): To verify that you are at least 21 years of age and that the personal details you have provided are accurate. This is a mandatory compliance obligation for a171.
• Payment processing: To facilitate deposits to and withdrawals from your a171 BDT wallet via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate transaction records.
• Customer support: To respond to your queries, complaints, and requests submitted via live chat or email. Support interactions are recorded to maintain quality and resolve disputes.
• Platform security and fraud prevention: To monitor the Platform for suspicious activity, prevent unauthorised access, detect and investigate fraud, money laundering, and bonus abuse, and to protect the integrity of the Platform and its Members.
• Responsible gaming compliance: To administer deposit limits, loss limits, session time limits, self-exclusion requests, and reality checks in accordance with a171's responsible gaming commitments and applicable obligations.
• Legal and regulatory compliance: To comply with applicable laws and regulations, respond to lawful requests from competent authorities, and maintain records required by law.
• Platform improvement and analytics: To analyse aggregate usage data and improve the functionality, performance, and content of the a171 Platform. Analytics are conducted at an aggregated level wherever possible.
• Marketing communications (opt-in only): Where you have explicitly opted in, to send you promotional offers, bonus notifications, and news about a171 platform updates. You may opt out at any time by contacting [email protected].

a171 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to perform the contract between a171 and you as a registered Member — including account creation, KYC verification, payment processing, and customer support.
• Legitimate interests: Processing carried out in pursuit of a171's legitimate business interests, including fraud detection, platform security, abuse prevention, and aggregate analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including record-keeping obligations, response to lawful authority requests, and anti-money laundering (AML) compliance.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — for example, for the receipt of marketing communications. You may withdraw consent at any time without prejudice to processing carried out prior to withdrawal.

a171 shares your personal data with third parties only where strictly necessary and only for the purposes described in this Policy. The categories of recipients are as follows:

• Payment processing partners: bKash, Nagad, Rocket, Upay, and card network processors (Visa, Mastercard) receive transaction data necessary to process your deposit and withdrawal instructions. These providers process data under their own privacy policies and are subject to applicable financial regulation.
• Identity verification (KYC) providers: Where a171 engages a third-party KYC service to assist with document verification, that provider receives identity documents and biometric data submitted by you for the purpose of completing the verification check.
• Game providers: Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, Spribe, and other licensed game studios receive session-level data (player ID, session token, bet/win amounts) as required to operate their game software on the a171 Platform.
• IT and infrastructure providers: Hosting, cloud storage, content delivery, and cybersecurity service providers who process data on a171's behalf under strict data processing agreements.
• Legal and law enforcement authorities: Where required by applicable law, court order, or lawful request from a competent authority, a171 will disclose personal data to the extent legally required. This includes co-operation with anti-money laundering and counter-terrorism financing investigations.
• Professional advisers: Lawyers, auditors, and compliance consultants who require access to personal data in the course of providing professional services to a171, under confidentiality obligations.

a171 retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account applicable legal retention obligations. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your active account relationship with a171, and for a minimum of five (5) years following permanent account closure, in accordance with applicable record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years following the date of each transaction, consistent with financial record-keeping obligations.
• KYC verification documents: Retained for the duration of the account relationship and for a minimum of five (5) years post-closure, or longer if required by applicable AML regulations.
• Customer support communications: Retained for three (3) years from the date of each interaction, or longer where a formal complaint or legal dispute remains unresolved.
• Technical and usage logs: Retained for up to twelve (12) months for security monitoring and performance analysis purposes, after which they are deleted or anonymised.
• Marketing consent records: Retained for the duration of the consent and for a reasonable period thereafter to demonstrate compliance.

a171 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• SSL/TLS encryption: All data transmitted between your device and the a171 Platform is encrypted using industry-standard SSL/TLS protocols. Connections to a171.io are enforced over HTTPS at all times.
• Data encryption at rest: Sensitive personal data stored in a171's systems — including financial data and identity verification documents — is encrypted at rest using strong encryption standards.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. a171 staff and contractors are granted access only to the data categories required to fulfil their specific role. All access is logged and subject to periodic review.
• Password security: Member account passwords are stored in hashed form using industry-standard one-way hashing algorithms. a171 does not store or transmit passwords in plain text.
• Intrusion detection and monitoring: a171's infrastructure is monitored continuously for unauthorised access attempts, anomalous activity, and potential security incidents.
• Staff training: All a171 team members who handle personal data are trained in data protection obligations and security practices.

a171 uses cookies and similar tracking technologies (including pixel tags and session tokens) to operate, secure, and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication tokens, load-balancing cookies, and security cookies. These cookies cannot be disabled without impairing your ability to use the Platform.
• Functional cookies: Remember your preferences and settings (for example, your chosen language or previously entered username) to improve your experience on return visits.
• Analytics cookies: Collect aggregated, anonymised data about how Members use the Platform — including pages visited, session durations, and features accessed — to help a171 improve Platform performance and content. No individual is identified from analytics data.
• Security and fraud-prevention cookies: Used to detect and prevent fraudulent activity, identify suspicious login patterns, and protect the integrity of the Platform and its Members.

a171 does not use advertising cookies or third-party behavioural tracking cookies that share your browsing data with external advertising networks.

As a data subject whose personal data is processed by a171, you hold the following rights in relation to your personal information. To exercise any of these rights, please contact a171 at [email protected] with the subject line "Data Rights Request — [Your Username]". a171 will respond to all verified rights requests within a reasonable timeframe and without undue delay.

The a171 Platform is strictly for adults aged 21 years and above. a171 does not knowingly collect or process personal data belonging to individuals under the age of 21. Age verification is a mandatory step in the a171 registration process, and additional KYC document verification may be requested at any time to confirm a Member's age.

If a171 becomes aware — through its own verification processes or through a report from a third party — that it has inadvertently collected personal data from an individual who is under 21 years of age, a171 will take the following immediate steps:

• Suspend the relevant account immediately, pending investigation.
• Permanently close the account upon confirmation of underage status.
• Return any deposited funds to the original payment source, minus any applicable processing fees.
• Permanently delete the personal data associated with the underage account from all a171 systems, subject to any mandatory legal retention requirements.
• Forfeit all winnings associated with the account without exception.

a171 primarily processes and stores personal data within secure data centre infrastructure. In certain circumstances — for example, where a171 engages a game provider, KYC partner, or technical service provider whose infrastructure is located outside Bangladesh — your personal data may be transferred to and processed in jurisdictions outside your country of residence.

Whenever personal data is transferred internationally, a171 takes the following precautions to ensure that an adequate level of protection is maintained:

• a171 enters into appropriate data processing agreements with all international service providers, incorporating contractual data protection obligations consistent with recognised international standards.
• a171 selects international partners who implement security measures equivalent to or exceeding those described in this Privacy Policy.
• a171 conducts due diligence assessments of international service providers prior to engagement and periodically thereafter to verify ongoing compliance with data protection commitments.

a171 reserves the right to update, amend, or replace this Privacy Policy at any time. Any material changes to this Policy — including changes to the categories of data collected, the purposes of processing, or the rights available to Members — will be communicated to registered Members via the email address associated with their account and through a prominent notice on the a171 Platform prior to the changes taking effect.

The "Last Updated" date at the top of this document will always reflect the date of the most recent revision. We recommend that you review this Privacy Policy periodically to stay informed about how a171 processes your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by a171, please contact our support team through one of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the live chat widget on the a171 Platform. Our support team will direct your privacy query to the appropriate person without delay.
• Email: [email protected] — for all privacy-related requests, use the subject line "Privacy Request — [Your Username]". We aim to respond within 48 hours of receipt.

Formal data rights requests (access, rectification, erasure, objection, restriction, or portability) must be submitted in writing to [email protected] with your full name, registered username, and a description of your request. We will acknowledge receipt within 48 hours and aim to provide a substantive response within 30 calendar days. Members across all regions of Bangladesh — including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, and Mymensingh — are equally entitled to exercise their data rights through these channels.