78games Privacy Policy – LGPD and Your Data

For the purposes of the LGPD, the controller of your personal data is 78games, the operator of the Sports Betting and online casino platform available at 78games.best, focused exclusively on the Brazilian market.

The controller is responsible for all decisions regarding the processing of your data: what data to collect, for what purpose, how long to retain it, and with whom to share it. Every decision about how your data is handled rests with 78games.

To exercise your rights or ask questions about this policy, please contact us at contato@78games.best or via live chat on the platform, available 24 hours a day in Portuguese.

The 78games collects only the data necessary for the purposes stated in this policy. Collection happens in three ways: information you provide directly, data generated by your use of the platform, and information obtained from authorized external sources.

Financial data provided for transactions via Pix, boleto bancário, credit or debit card, PicPay, Mercado Pago, or TED transfer is handled with end-to-end encryption. Full card numbers are never stored on 78games — only tokens generated by the certified payment processor.

The 78games uses personal user data exclusively for the following purposes:

• Account creation and management: verify your identity, keep your registration up to date, and ensure secure access to the platform;
• Financial processing: process deposits via Pix, boleto, card, and other Brazilian payment methods, as well as withdrawals to your bank account;
• Compliance with legal obligations: KYC verification in accordance with Law 9.613/1998 (anti-money laundering), reports to Coaf when required, and compliance with court orders;
• Fraud prevention: detect and prevent unauthorized access, multiple accounts, bonus abuse, and other activities that violate the Terms of 78games;
• Customer support: answer questions, resolve betting disputes, process withdrawal requests, and handle complaints;
• Responsible gambling: monitor behavioral patterns to identify at-risk users and activate available protection tools;
• Marketing communications: send notifications about promotions, special odds on Brasileirão, Superliga de Vôlei, UFC, and selected events — only with your consent and with an opt-out option in every communication;
• Platform improvement: analyze usage data in aggregated and anonymized form to improve the interface, technical stability, and overall user experience.

The 78games does not use your data for any purpose beyond those listed above without prior notice and, where applicable, without obtaining fresh consent.

The LGPD requires that all personal data processing have a legal basis. 78games processes your data based on the following legal grounds set out in Art. 7 of Law 13,709/2018:

• Contract performance (Art. 7, V): processing required to perform the platform usage agreement, including the handling of bets, deposits, and withdrawals;
• Compliance with a legal obligation (Art. 7, II): processing required by the Anti-Money Laundering Law, Central Bank regulations, tax obligations, and court orders;
• Legitimate interest (Art. 7, IX): fraud prevention, platform security, and analysis of usage patterns to improve our services — always with care and respect for your rights;
• Consent (Art. 7, I): sending marketing communications and using non-essential cookies. You may withdraw your consent at any time without affecting your use of the platform.

The 78games does not sell, rent, or trade your personal data. Sharing occurs only in the situations below, always on a lawful basis and with appropriate safeguards:

• Payment processors: certified partners that process transactions via Pix, credit/debit card, boleto, PicPay, and Mercado Pago. They access only the data strictly necessary to complete each transaction;
• Casino game providers: certified providers of slots, live roulette, crash games, and progressive jackpots that require minimal technical data for the gaming session;
• Identity verification (KYC) services: specialized platforms that assist with document verification and regulatory compliance;
• Technology infrastructure: cloud server providers, cybersecurity services, and customer support tools, always under data processing agreements compatible with the LGPD;
• Competent authorities: Federal Revenue Service, Coaf, Central Bank, Federal Police, and other authorities, when required by law or court order. In such cases, the 78games discloses only the minimum necessary.

All third parties that process data on behalf of 78games are classified as operators in accordance with the LGPD and are contractually bound to process data only as instructed by 78games and in compliance with Brazilian law.

The 78games implements technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or destruction. The key protections currently in place include:

• TLS/HTTPS encryption across all communications between your browser or app and 78games servers;
• Encryption at rest for sensitive data stored in our databases, including identification and financial information;
• Financial data tokenization: card numbers are never stored directly — only tokens generated by the certified payment processor;
• Role-based access control: only employees with a legitimate need can access users' personal data, with access logs audited on a regular basis;
• Continuous security monitoring: intrusion and anomaly detection systems that alert the security team in real time about suspicious activity;
• Periodic penetration testing: security audits conducted by specialized external teams to identify vulnerabilities before they can be exploited.

In the event of a security incident that may affect your personal data, 78games commits to notifying the National Data Protection Authority (ANPD) and affected users within the legal deadlines established by the LGPD, with clear information about what occurred and what measures were taken.

The 78games retains personal data for as long as necessary to fulfill the stated purposes and legal obligations. The general retention periods are:

• Active account data: retained for as long as your account is active and you continue using the platform;
• After account closure: identification data, transaction history, and betting records are retained for up to 5 years after account closure, as required by Law 9.613/1998 (anti-money laundering) and Brazilian tax legislation;
• Customer support data: conversation records and requests are retained for up to 2 years after the case is resolved, for audit and quality improvement purposes;
• Marketing data: retained until you withdraw consent. Withdrawal takes effect immediately upon clicking "unsubscribe" or by submitting a request to support;
• Cookies and session data: as described in the cookie settings detailed in Section 9 of this policy.

Once the retention period ends, data is securely deleted or anonymized so that the data subject can no longer be identified. Early deletion may be requested by the user (see Section 8), but may not be possible when a legal retention obligation applies.

The LGPD grants you, as a data subject, the following rights regarding the information that 78games stores about you:

• Access: request a copy of the personal data we hold about you, in a readable format;
• Correction: request the correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or deletion: request that unnecessary, excessive, or non-compliant data be anonymized, blocked, or deleted;
• Portability: request the transfer of your data to another service or product, where technically feasible and in accordance with ANPD regulations;
• Sharing information: know which companies and entities 78games shares your data with;
• Withdrawal of consent: withdraw consent given for processing based on that legal ground, without affecting your ability to use the platform for purposes based on other legal grounds;
• Right to Object: object to data processing carried out on the basis of legitimate interest, where there are valid grounds to do so;
• Review of automated decisions: request human review of decisions made solely through automated data processing that affect your interests.

To exercise any of these rights, send a request to contato@78games.best with the subject line "LGPD Rights – [your right]" and proof of identity. The 78games will respond within 15 business days from the date your request is received, at no cost to you.

The 78games uses cookies and similar technologies to ensure the platform works correctly, personalize the user experience, and — with your consent — for analytics and marketing purposes.

• Essential cookies: required for the platform's basic functionality, such as keeping your session active and remembering language preferences. These cannot be disabled without affecting your ability to use 78games;
• Performance cookies: collect anonymized data on how you use the platform to help identify errors and improve the experience. These require your consent;
• Preference cookies: remember settings such as your preferred odds format and sports filters to personalize your experience on your next visit;
• Marketing cookies: used only with your explicit consent to personalize communications and measure campaign effectiveness. They are not shared with external advertising networks.

You can manage your cookie preferences at any time in your account settings or through your browser settings. Disabling non-essential cookies does not affect your ability to bet, deposit, or withdraw on 78games.

Some of the technology providers used by 78games – such as cloud infrastructure providers and customer support platforms – may process data on servers located outside Brazil. When this occurs, 78games adopts the following safeguards required by the LGPD:

• Transfers only to countries with a level of data protection deemed adequate by the ANPD;
• Execution of specific data protection contractual clauses with international vendors, equivalent to LGPD requirements;
• Prior review of the privacy policies and security certifications of vendors before any engagement;
• Limiting the scope of transferred data to what is strictly necessary for the provision of the specific service.

The 78games does not carry out international data transfers for marketing purposes or to entities unrelated to the provision of the platform's services.

The 78games is a platform exclusively for users aged 18 and over. We do not knowingly collect personal data from minors. Registration by minors is strictly prohibited, and any account identified as belonging to a minor will be closed immediately.

If you suspect that a minor has created an account on 78games, please report it immediately by emailing contato@78games.best. We will investigate and, if confirmed, close the account and delete any data collected.

If you are the legal guardian of a child or teenager and believe they have provided data to 78games, please contact us so we can delete that information immediately, with no red tape.

The 78games may update this Privacy Policy periodically to reflect changes in its services, Brazilian legislation, or data processing practices. When significant updates are made, you will be notified by:

• An email sent to the address registered on your account, with at least 15 days' notice for changes that affect your rights;
• A prominent notice on the platform upon your next login after the new version is published;
• Updating the "last updated" date at the top of this page.

Continued use of the platform after the effective date of updated terms constitutes acceptance of the changes. If you do not agree with the changes, you may close your account and request deletion of your data as described in Section 8.

The 78games has appointed a Data Protection Officer (DPO) as required by Art. 41 of the LGPD. The DPO serves as the point of contact between 78games, data subjects, and the National Data Protection Authority (ANPD).

To get in touch with the privacy channel of 78games:

• Email: contato@78games.best (subject: "Privacy – [your request]")
• Live chat: available 24 hours on the platform, in Portuguese
• Response time: up to 15 business days for LGPD rights requests; up to 48 hours for general privacy inquiries

You may also file complaints directly with the National Data Protection Authority (ANPD) if you believe your rights as a data subject have not been adequately addressed by 78games.