Privacy Policy — How to1971 Protects Your Data

1. Data Controller Information

For the purposes of this Privacy Policy, to1971 ("the Platform", "we", "us", "our") is the data controller responsible for the personal information collected through and in connection with the to1971.net website and all associated products and services offered thereon. The to1971 platform is operated for the Bangladesh market, with all services denominated in Bangladeshi Taka (BDT).

If you have any questions, concerns, or requests relating to the processing of your personal data, you should contact the to1971 data protection team using the details provided in Section 12 of this Policy. We are committed to responding to all privacy-related enquiries within 72 hours of receipt.

2. Personal Data We Collect

2.1 Registration Data

When you create a to1971 account, we collect the following information directly from you: your full legal name, date of birth, email address, Bangladeshi mobile phone number, and a chosen username and password. Providing accurate registration information is a requirement of the to1971 Terms & Conditions and is necessary for account operation. Deliberately providing false or inaccurate registration data is a breach of those Terms.

2.2 Identity Verification (KYC) Data

In order to verify your identity and comply with responsible gaming and anti-money-laundering obligations, to1971 may request copies of the following documents at any stage of your account's lifetime: a government-issued photo identity document (such as your Bangladesh National Identity Card, passport, or driving licence), a proof of residential address dated within the last three months, and a copy of or evidence relating to your registered payment method (such as a screenshot of your bKash or Nagad wallet showing your registered mobile number). These documents are processed securely by to1971's internal compliance team and are not shared with third parties except where required by law.

2.3 Financial Transaction Data

When you make a deposit or request a withdrawal on the to1971 platform, we record details of that transaction including the payment method used (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, or BRAC Bank), the transaction reference number provided by the payment provider, the amount in BDT, the date and time of the transaction (recorded in Bangladesh Standard Time, UTC+6), and the running account balance following the transaction. to1971 does not store your full banking credentials or mobile banking PINs.

2.4 Gameplay and Betting Data

to1971 records a full log of all gaming and betting activity conducted through your account. This includes game session start and end times, the games or sports markets accessed, individual wager amounts, outcomes, and resulting balance changes. Gameplay data is used for account management, dispute resolution, responsible gaming monitoring, and fraud detection purposes.

2.5 Technical and Device Data

When you access to1971, our servers automatically collect certain technical information about your device and connection. This includes your IP address, device type and operating system, browser type and version, the referring URL (if any), pages visited within the to1971 platform, session duration, and error logs. This data is used primarily for platform security, fraud prevention, and aggregate traffic analysis. It is not used to build individual advertising profiles.

2.6 Communications Data

If you contact to1971 via the support email address [email protected] or via any live support channel, we will retain a record of that correspondence — including the content of messages exchanged and any attachments submitted — for the purpose of responding to your query, training our support team, and resolving any future disputes. Communications data is retained for a period of five years from the date of the final exchange.

2.7 Data Collected from Third Parties

In limited circumstances, to1971 may receive personal data about you from third parties. This includes identity verification results returned by KYC service providers following document checks, fraud-risk scoring data returned by payment processors, and, where applicable, data shared by affiliate partners confirming that you arrived at to1971 via their referral link. All third-party data is handled in accordance with this Privacy Policy.

3. How We Use Your Data

to1971 processes your personal data for the following defined purposes:

Purpose	Data Categories Used
Creating and managing your player account	Registration data, KYC data
Processing deposits and withdrawals	Financial transaction data, KYC data
Verifying your identity and age (18+ compliance)	KYC data, registration data
Detecting and preventing fraud and money laundering	Technical data, financial data, gameplay data
Providing customer support	Communications data, account data
Responsible gaming monitoring and intervention	Gameplay data, registration data
Sending account-related notifications	Registration data (email, phone)
Sending promotional communications (with consent)	Registration data, gameplay data
Improving and securing the platform	Technical data, gameplay data
Complying with legal and regulatory obligations	All categories as required

to1971 does not use your personal data for automated decision-making that produces significant legal effects on your account without human review, except for the initial automated screening of deposits against known fraud patterns, which is always subject to manual review override.

4. Legal Basis for Processing

to1971 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing that is required to perform our obligations under the contract with you — principally the operation of your player account, the processing of deposits and withdrawals, and the provision of gaming services.
• Legal Obligation: Processing required in order to comply with applicable law, including anti-money-laundering obligations, age verification requirements, and data retention mandates.
• Legitimate Interests: Processing that is necessary for to1971's legitimate business interests where those interests are not overridden by your rights. This covers fraud detection, platform security, and aggregate analytics used to improve the player experience.
• Consent: Processing that is based on your freely given, specific, and informed consent — in particular, the sending of promotional marketing communications by email or SMS. You may withdraw your consent at any time by contacting [email protected] or using the unsubscribe mechanism in any marketing message.

5. Data Sharing & Third Parties

5.1 Payment Processors

In order to process your deposits and withdrawals, to1971 shares the minimum necessary transaction data with the relevant payment provider (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank). Each of these providers operates under its own privacy policy and data protection obligations. to1971 is not responsible for the data handling practices of third-party payment providers once data has been transmitted to them for transaction processing.

5.2 Game Content Providers

to1971's game library is supplied by third-party studios including Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, Microgaming, and Spribe. When you play a game supplied by one of these studios, certain technical data (such as your session token, device type, and game round results) may be processed on that studio's servers. Each provider maintains its own data processing standards. to1971 contractually requires all content providers to handle player data responsibly and in accordance with applicable law.

5.3 Identity Verification Providers

Where to1971 uses a third-party KYC or identity verification service to assist in verifying the documents you submit, your identity document data will be shared with that provider solely for the purpose of performing the verification check. KYC providers engaged by to1971 are contractually prohibited from retaining or using your document data for any other purpose.

5.4 Legal Disclosure

to1971 may disclose personal data to law enforcement authorities, regulatory bodies, or other governmental agencies where we are legally required to do so, or where we reasonably believe that such disclosure is necessary to protect the rights, safety, or property of to1971, our players, or the general public. to1971 will notify affected players of any such disclosure to the extent permitted by law.

5.5 Business Transfers

In the event that to1971 undergoes a business acquisition, merger, or asset transfer, personal data held by the platform may form part of the assets transferred to the acquiring entity. In such circumstances, to1971 will endeavour to provide reasonable advance notice to affected players and the acquiring entity will be required to honour this Privacy Policy or provide players with an updated policy at the point of transfer.

5.6 No Sale of Data

to1971 does not sell, rent, or lease your personal data to any third party for their own marketing or commercial purposes. This is an unconditional commitment that applies regardless of any commercial arrangement between to1971 and any third party.

6. Cookies & Tracking Technologies

6.1 What Are Cookies

Cookies are small text files that are placed on your device by websites you visit. They are widely used to make websites function correctly, to remember user preferences, and to provide anonymised statistical information to site operators. to1971 uses cookies solely for the functional and analytical purposes described in this section.

6.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential / Session	Maintain your login session and account state while you are active on the platform. These cookies are strictly necessary and cannot be disabled without breaking core platform functionality.	Session (deleted on browser close)
Preference	Remember your language preference, lobby display settings, and any responsible gaming limits you have set through the platform interface.	Up to 12 months
Analytics	Collect aggregated, anonymised data about how players navigate the platform, which pages are most visited, and where errors occur. Used solely to improve platform performance and player experience.	Up to 12 months
Affiliate Tracking	Where you arrived at to1971 via an affiliate referral link, a cookie records the referring affiliate ID so that the correct commission attribution can be made. No additional personal data is collected.	30 days

6.3 Managing Cookies

You can control and delete cookies through your browser settings. Please note that disabling essential session cookies will prevent you from logging in to your to1971 account. Disabling analytics cookies will not affect your ability to use the platform but will mean that your session data is not included in aggregate platform improvement analysis. to1971 does not use third-party advertising cookies or cross-site tracking technologies of any kind.

7. Data Retention Periods

to1971 retains different categories of personal data for different periods, based on the purpose for which the data was collected and applicable legal requirements:

• Active Account Data: Retained for the full duration of your account's active status, plus five years following account closure.
• KYC and Identity Documents: Retained for five years following account closure in accordance with anti-money-laundering record-keeping requirements.
• Financial Transaction Records: Retained for five years following each transaction for accounting and compliance purposes.
• Gameplay Logs: Retained for two years following the date of each session for dispute resolution and responsible gaming monitoring purposes.
• Customer Support Communications: Retained for five years from the date of the final message in each exchange.
• Technical and Device Logs: Retained for up to 12 months from the date of collection, after which they are aggregated and anonymised.
• Marketing Consent Records: Retained for the duration of consent plus three years following withdrawal of consent, as evidence of compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that makes re-identification impossible. Anonymised or aggregated data that cannot be linked back to an individual player may be retained indefinitely for statistical analysis purposes.

8. Data Security Measures

to1971 employs a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data in transit between your device and the to1971 platform servers.
• Encryption at rest for sensitive personal data fields including identity document images and payment method records.
• Access controls that restrict internal access to personal data to those members of the to1971 team who genuinely require it for their specific role.
• Regular internal security audits and vulnerability assessments of the platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised login.
• Monitoring and automated alerting systems to detect and respond to anomalous access patterns.

Notwithstanding these measures, no internet-based platform can guarantee absolute security against all possible threats. In the event of a personal data breach that is likely to result in a risk to player rights or freedoms, to1971 will notify affected players without undue delay via the email address registered on their account. You are responsible for maintaining the confidentiality of your own login credentials; to1971 cannot be held responsible for unauthorised account access resulting from your failure to protect your username and password.

9. Your Privacy Rights

As a registered player on to1971, you hold a number of rights in relation to your personal data. These rights are summarised below. To exercise any of them, please contact [email protected] with the subject line "Privacy Rights Request" and your registered account username or email address.

• Right of Access: You have the right to request a copy of the personal data that to1971 holds about you and to be provided with information about how that data is used and stored. Requests will be fulfilled within 30 days of receipt.
• 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. Minor corrections (such as a misspelled name) will be actioned within five business days.
• Right to Erasure: In certain circumstances, you have the right to request deletion of your personal data. This right applies where the data is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. Note that this right is subject to overriding legal retention obligations — for example, we cannot delete KYC records that we are legally required to retain.
• Right to Restrict Processing: You may request that to1971 pause the processing of your personal data in certain circumstances, such as while a dispute about the accuracy of that data is being resolved.
• Right to Data Portability: Where data has been processed on the basis of your consent or to perform a contract, you have the right to receive a machine-readable copy of that data so that it can be transferred to another service provider.
• Right to Withdraw Consent: Where processing is based on your consent (principally marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.
• Right to Object: You may object to the processing of your personal data on grounds relating to your particular situation where processing is based on to1971's legitimate interests.

10. Children's Privacy

The to1971 platform is strictly intended for adults aged 18 and above. to1971 does not knowingly collect personal data from any individual under the age of 18. If you are under 18, you must not register an account or use any service offered on the to1971 platform. If to1971 becomes aware that it has inadvertently collected personal data from a player who is under 18, that data will be securely deleted and the associated account will be closed immediately. Any deposits received from an underage player will be returned to the originating payment method; any winnings will be forfeited.

Parents and guardians who believe that a minor in their care has registered an account on to1971 should contact [email protected] immediately. Our compliance team will investigate and take appropriate action within 24 hours of receiving such a report.

11. Changes to This Policy

to1971 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. When material changes are made — meaning changes that significantly affect your rights or the way in which we use your personal data — we will notify registered players by email to the address held on their account at least seven days before the revised Policy takes effect. Continued use of the to1971 platform following the effective date of a revised Policy constitutes acceptance of the updated terms.

The effective date displayed at the top of this document is updated each time a new version of the Policy is published. We recommend bookmarking this page and reviewing it periodically to stay informed about how to1971 handles your personal data.

12. Contact & Data Requests

All privacy-related enquiries, data rights requests, and complaints relating to the handling of your personal data should be directed to the to1971 data protection team at the following contact point:

Email: [email protected]
Subject line: Privacy Rights Request
Response time: Within 48 hours for acknowledgement; within 30 days for substantive response.

Please include your registered account username or the email address associated with your to1971 account in all privacy correspondence so that we can locate your records and respond accurately. For identity verification purposes, we may ask you to confirm additional details before processing a sensitive data rights request.