bk33e Privacy Policy — Your Data, Your Rights

1 Introduction

Welcome to the bk33e Privacy Policy. bk33e operates an online cricket betting and live casino platform accessible to adult players aged 21 and above across Bangladesh. This Privacy Policy ("Policy") describes how bk33e ("we", "us", "our") collects, uses, stores, shares, and protects personal data relating to users of the bk33e website located at https://bk33e.io and all associated services, features, and content (collectively, the "Platform").

We recognise that privacy is a fundamental right. Every player who registers with bk33e trusts us with personal information, and we take that trust seriously. This Policy is written in plain English so that all players across Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, Mymensingh, Cox's Bazar, and the rest of Bangladesh can clearly understand how their data is handled.

By accessing or using the bk33e Platform, creating an account, making a deposit, or participating in any game or promotion, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, both of which form part of your agreement with bk33e. Where this Policy refers to personal data, it means any information that identifies or could reasonably identify you as an individual.

2 Data Controller

For the purposes of applicable data protection law, bk33e acts as the data controller with respect to all personal data collected from players accessing the Platform. As data controller, bk33e determines the purposes and means by which personal data is processed.

If you have any questions or concerns about how bk33e processes your personal data, or if you wish to exercise any of the data subject rights described in Section 10 of this Policy, you may contact our dedicated data protection team using the contact details provided in Section 15.

3 Personal Data We Collect

bk33e collects personal data that you provide directly to us and data that is generated automatically as you interact with the Platform. The categories of personal data we collect are outlined below.

3.1 Registration Data

When you create a bk33e account, we collect the following information:

• Full legal name as it appears on your National Identity Card (NID) or passport
• Date of birth (for age verification — players must be 21 or older)
• Residential address in Bangladesh
• Email address
• Mobile phone number registered in Bangladesh
• Username and hashed password (we never store passwords in plain text)

3.2 Identity Verification Data

To comply with our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, we may request:

• Copy of National Identity Card (NID), passport, or birth registration document
• Proof of residential address (utility bill or bank statement dated within 90 days)
• Source of funds documentation for large or unusual transactions
• Selfie photograph for facial verification purposes where required

3.3 Financial Data

When you make deposits or request withdrawals, we collect:

• Payment method type (bKash, Nagad, Rocket, Upay, bank account, etc.)
• Mobile wallet account numbers or bank account references associated with your transactions
• Transaction amounts, timestamps, and reference identifiers
• Transaction history for AML monitoring purposes

bk33e does not store full payment card numbers. Card payment data, where applicable, is handled exclusively by our PCI-compliant payment processing partners.

3.4 Gaming Activity Data

• Game session records including game name, provider, stake, outcome, and timestamp
• Sports betting history including markets, odds accepted, outcomes, and settlement details
• Bonus and promotion usage records
• Responsible gaming tool settings (deposit limits, session limits, cool-off periods, self-exclusion status)

3.5 Technical & Device Data

• IP address at the time of each login and significant transaction
• Device type, operating system, and browser version
• Referring URL and pages visited on the Platform
• Session duration and click-stream data
• Cookie identifiers (see Section 9)

3.6 Communications Data

• Content of Live Chat conversations with bk33e support agents
• Email correspondence sent to or received from bk33e support
• Responses to surveys, feedback requests, or promotions you voluntarily participate in

4 How We Collect Your Data

bk33e collects personal data through the following means:

• Directly from you: Data you enter into registration forms, verification uploads, cashier pages, support chats, or survey responses constitutes data provided directly to us. This is the primary source of personal data we hold.
• Automatically during your use of the Platform: Technical and behavioural data is collected automatically via server logs, cookies, session tracking scripts, and analytics tools as you navigate the Platform. This data is collected whether or not you are logged in, though it is linked to your account profile where a session can be identified.
• From payment processors: When you make a deposit or withdrawal, our integrated payment partners (bKash, Nagad, Rocket, Upay, and banking partners) share transaction confirmation data with bk33e for the purpose of crediting your account and maintaining transaction records. bk33e does not receive your full mobile banking PIN or any credential used to authenticate your payment.
• From third-party game providers: Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may share game session data with bk33e in real time to enable game result settlement, bonus tracking, and responsible gaming monitoring. This data is limited to gameplay outcomes and session identifiers.
• From identity verification services: Where bk33e uses third-party KYC partners to verify the authenticity of identity documents, those partners may share a verification result and associated risk score with bk33e. The underlying document data remains with the verification service in accordance with their own privacy practices.

5 Purpose & Legal Basis for Processing

bk33e processes your personal data for specific, legitimate purposes. For each purpose, there is a corresponding legal basis that justifies the processing activity. The main purposes and their legal bases are set out below.

• Account creation and management: Processing is necessary for the performance of the contract between you and bk33e (our Terms & Conditions). We cannot provide you with a bk33e account without processing registration data.
• Age and identity verification (KYC): Processing is necessary to comply with our legal obligations. We are required to verify that all players are aged 21 or above and to conduct due diligence on customer identity for AML compliance purposes.
• Payment processing: Processing is necessary for the performance of our contract with you. Depositing and withdrawing funds requires us to process payment method details and transaction data.
• Fraud prevention and AML monitoring: Processing is necessary for compliance with legal obligations and for the pursuit of our legitimate interests in maintaining the integrity of the Platform and preventing financial crime.
• Responsible gaming compliance: Processing is necessary to comply with legal obligations and to protect the vital interests of players who may be at risk of harm from problem gambling. We use gaming activity data to identify patterns that may indicate a player requires intervention or account controls.
• Customer support: Processing is necessary for the performance of our contract with you. Responding to your support queries requires access to your account data and communication history.
• Platform analytics and improvement: Processing is based on our legitimate interests in understanding how the Platform is used in order to improve its performance, layout, game offering, and user experience for players in Bangladesh.
• Marketing communications: Where you have opted in to receive promotional emails or Platform notifications from bk33e, processing is based on your freely given consent. You may withdraw consent at any time (see Section 12).

6 Data Sharing & Third Parties

bk33e does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the circumstances described below, and only to the extent necessary for the stated purpose.

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank receive the transaction data necessary to process your deposits and withdrawals. Each payment partner is subject to their own privacy and data security obligations under applicable law.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed third-party game suppliers receive session identifiers and stake/outcome data to deliver game services on the Platform. They do not receive your full registration or financial profile.
• Identity verification partners: Third-party KYC service providers receive copies of identity documents you submit during the verification process. These partners operate under strict data processing agreements with bk33e and are prohibited from using your data for any purpose other than the verification service they provide to us.
• Analytics and technology providers: We use third-party analytics tools to understand Platform usage patterns. These tools may receive anonymised or pseudonymised technical data. No personally identifiable financial or identity data is shared with analytics providers.
• Legal and regulatory authorities: Where required by applicable law, court order, or legitimate regulatory request, bk33e may disclose personal data to law enforcement agencies, financial intelligence units, or other government bodies in Bangladesh or other applicable jurisdictions. We will notify you of such disclosures where we are legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of bk33e's business assets, personal data held by bk33e may be transferred to the acquiring entity. You will be notified of such a transfer via email or a prominent Platform notice before your data is subject to any new privacy policy.

7 Data Retention

bk33e retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The general retention periods applicable to different categories of data are described below.

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 individual. Where data must be retained beyond standard periods due to an active dispute, legal investigation, or regulatory inquiry, it will be retained until that matter is fully resolved and the relevant retention obligation has lapsed.

8 Security Measures

bk33e implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Key measures include:

• SSL/TLS Encryption: All data transmitted between your device and the bk33e Platform is encrypted using industry-standard SSL/TLS protocols. This protects your login credentials, payment information, and personal data from interception during transit.
• Encrypted Data Storage: Sensitive personal data, including identity documents and financial records, is stored in encrypted form using AES-256 encryption at rest on our secure servers.
• Password Security: Account passwords are stored exclusively as salted cryptographic hashes. bk33e employees cannot read or recover your password. If you forget your password, a reset link is issued — passwords are never provided in plain text.
• Access Controls: Access to personal data within bk33e's internal systems is restricted on a strict need-to-know basis. Only personnel whose job function requires access to specific data categories are granted the relevant permissions. All internal access is logged and auditable.
• Two-Factor Authentication (2FA): bk33e strongly recommends enabling 2FA on your account for an additional layer of login security. 2FA options are available from your Account Settings panel.
• Regular Security Audits: bk33e conducts periodic internal and third-party security assessments to identify and remediate vulnerabilities in the Platform's infrastructure, application code, and data handling processes.
• Incident Response: In the event of a data security incident that poses a risk to your rights and freedoms, bk33e will notify affected players without undue delay and take all reasonably practicable steps to contain and remediate the incident.

9 Cookies & Tracking Technologies

bk33e uses cookies and similar tracking technologies on the Platform to enable core functionality, improve your experience, and gather analytics data. A cookie is a small text file placed on your device by the Platform when you visit. The types of cookies we use are described below.

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable you to navigate the site, maintain your login session, and use the cashier. These cookies cannot be disabled as the Platform cannot function without them.
• Functional Cookies: These cookies remember your preferences such as your preferred language, display settings, and responsible gaming tool configurations so that you do not need to re-enter them on each visit.
• Analytics Cookies: These cookies collect aggregated, anonymised information about how visitors use the Platform — which pages are visited most frequently, how long sessions last, and where users navigate from. This data helps bk33e improve the Platform. Analytics cookies do not identify you personally.
• Security Cookies: These cookies support our fraud detection and AML monitoring systems by helping bk33e identify unusual login patterns, multi-accounting behaviour, or device anomalies that may indicate unauthorised access or prohibited use.

Most web browsers allow you to control cookies through their settings. You may be able to refuse or delete certain cookies; however, disabling strictly necessary cookies will impair or prevent your use of the Platform. Refer to your browser's help documentation for guidance on managing cookies.

10 Your Data Subject Rights

As a data subject whose personal data is processed by bk33e, you hold the following rights. To exercise any of these rights, please contact our data protection team using the details in Section 15. We will respond within five (5) BST business days of receiving a valid request.

• Right of Access: You have the right to request a copy of the personal data that bk33e holds about you. We will provide this in a structured, commonly used, machine-readable format where technically feasible.
• Right to Rectification: If any personal data bk33e holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. You may update certain profile details directly via Account Settings without contacting support.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent on which processing was based. Note that this right is subject to override where bk33e has legal obligations to retain data (e.g., AML record-keeping — see Section 7).
• Right to Restriction of Processing: You may request that bk33e restrict processing of your personal data in certain circumstances — for example, while the accuracy of data is contested, or while an objection to processing is under consideration.
• Right to Data Portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, machine-readable format and to transmit it to another data controller.
• Right to Object: You have the right to object to processing of your personal data where bk33e relies on legitimate interests as the legal basis. bk33e will cease processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

11 Protection of Minors

bk33e is strictly an adult-only Platform. Access to all services, including free-to-play features, is prohibited for persons under 21 years of age. We do not knowingly collect personal data from individuals under the age of 21.

As part of our registration process, all applicants are required to confirm that they are aged 21 or above and to submit identity documentation that verifies this. Where bk33e has reason to believe that an account was registered by or is being used by a person under 21, the account will be immediately suspended, all activity will be reviewed, and the account will be closed in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a person under the age of 21 in your care has registered an account on the bk33e Platform, please contact our support team immediately via Live Chat or email. We will take prompt action to investigate and close the account.

Any personal data inadvertently collected from a person under 21 will be deleted from bk33e's systems as soon as the underage status is identified and confirmed, subject only to any mandatory legal retention obligations.

12 Marketing Communications

bk33e may send you promotional emails, Platform notifications, or SMS messages about new games, seasonal promotions (including BPL season offers, Eid bonuses, Pohela Boishakh specials, and IPL promotions), deposit match bonuses, free spin offers, and other marketing content. All marketing communications are sent only where you have provided explicit opt-in consent.

You may opt out of marketing communications at any time by:

• Clicking the "Unsubscribe" link included at the bottom of every promotional email;
• Updating your communication preferences in the Account Settings panel on the Platform; or
• Contacting bk33e support via Live Chat and requesting removal from the marketing list.

Opting out of marketing communications does not affect transactional communications such as deposit confirmations, withdrawal processing notifications, account security alerts, or important policy update notices. These communications are necessary to your use of the Platform and cannot be opted out of while your account remains active.

bk33e will never share your contact details with third parties for their own marketing purposes. All promotional communications received by you will originate exclusively from bk33e via official channels associated with the bk33e.io domain.

13 International Data Transfers

In the course of operating the Platform, bk33e may transfer your personal data to servers or service providers located outside of Bangladesh. Such transfers may occur in connection with cloud hosting infrastructure, third-party game provider systems, or KYC verification services that operate internationally.

Wherever personal data is transferred internationally, bk33e ensures that appropriate safeguards are in place to provide a level of data protection equivalent to the protections afforded within Bangladesh. Such safeguards may include:

• Contractual data protection clauses that bind the receiving party to applicable data protection standards;
• Transfers to entities that have implemented recognised security frameworks and certification standards (e.g., ISO 27001, SOC 2); or
• Transfers that are necessary for the performance of the contract between you and bk33e (e.g., routing a bKash payment through a payment gateway's international infrastructure).

If you require further information about the safeguards in place for any specific international transfer, please contact our data protection team as described in Section 15.

14 Changes to This Privacy Policy

bk33e reserves the right to update or amend this Privacy Policy at any time to reflect changes in law, regulatory guidance, Platform functionality, or our data processing practices. When we make material changes to this Policy, we will notify registered players via email to the address on file and via a prominent notice on the Platform upon login, no less than seven (7) days before the revised Policy takes effect.

The updated Policy will always be available at this URL (https://bk33e.io/privacy-policy), with the effective date and version number clearly indicated at the top of the document. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the changes. If you do not agree with the revised Policy, you must cease using the Platform and request account closure before the effective date.

We encourage you to review this Policy periodically to stay informed about how bk33e is protecting your data. If you have questions about any change, our support team is available 24/7 via Live Chat to assist you.

15 Contact Information

If you have any questions, concerns, or requests relating to this Privacy Policy or to bk33e's handling of your personal data, please contact us using the following details:

• Support Email (plain text — not a link): [email protected]
• Live Chat: Available 24 hours a day, 7 days a week via the Platform dashboard after login.
• Subject Line for Privacy Requests: Please include "Privacy Request — [Your Username]" in the subject line of any email enquiry so our team can prioritise your message.
• Response Time: We aim to respond to all privacy-related requests within five (5) BST business days of receipt of a complete, verified request.
• Time Zone: All stated hours refer to Bangladesh Standard Time (BST, UTC+6).