bq44 Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how bq44 ("we", "us", or "our") collects, uses, stores, and shares personal data when you access or use the bq44 website and mobile platform (collectively, the "Platform"). bq44 is an online casino and sports betting platform operated for players primarily based in Bangladesh. We are committed to handling your personal data responsibly and in accordance with applicable data protection principles.

By registering for an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform and contact our support team to close your account.

2. Personal Data We Collect

We collect personal data from you directly when you register, deposit, play, or contact us, and automatically when you browse or interact with the Platform. We apply a data minimisation principle — we collect only what is necessary for legitimate operational, compliance, and service improvement purposes.

Data You Provide Directly

When you create an account, verify your identity, make deposits or withdrawals, or contact our support team, we may collect the following categories of personal data:

• Identity data: full legal name, date of birth, and — where KYC verification is required — a copy of a government-issued identification document.
• Contact data: mobile phone number (used as your primary account identifier and for transaction OTP verification via bKash, Nagad, or Rocket), and optionally an email address.
• Financial data: deposit and withdrawal transaction records, mobile banking account numbers associated with transactions on your account. We do not store payment card numbers as we do not accept card payments.
• Gaming data: bet history, game session records, win/loss records, and responsible gaming tool settings (such as deposit limits and self-exclusion records).
• Communications data: the content of support tickets, chat messages, or emails you send to us and our responses.

Data Collected Automatically

When you visit or use the Platform, our servers and analytics tools may automatically record certain technical information. This data is used for security monitoring, fraud prevention, and Platform performance optimisation:

• Device and browser information: device type, operating system, browser type and version, screen resolution, and device language settings.
• Network data: IP address, mobile network operator, and approximate geographic location derived from IP address (country and city level only — we do not use GPS or precise location tracking).
• Usage data: pages visited, links clicked, game sessions started, session duration, and navigation paths through the Platform.
• Cookie data: session identifiers, authentication tokens, and preference cookies. See Section 7 (Cookies) for full details.

3. How We Use Your Personal Data

We process your personal data only where we have a lawful basis to do so. The primary bases on which we rely are: performance of our contract with you (operating your account, processing deposits and withdrawals, delivering game services); compliance with legal obligations (KYC, anti-money laundering checks, age verification); legitimate interests (fraud prevention, platform security, responsible gaming monitoring); and your consent (for optional marketing communications, where applicable).

Core Service Purposes

Your personal data is used for the following core purposes:

• Account creation and management: registering your account, verifying your identity, processing your login, and maintaining your account preferences.
• Payment processing: facilitating deposits via bKash, Nagad, Rocket, and Upay; processing withdrawal requests to your registered mobile banking account; maintaining transaction audit records.
• Compliance and fraud prevention: conducting age verification and KYC checks in accordance with applicable requirements; monitoring transactions and player behaviour patterns for indications of fraud, money laundering, match-fixing, or other prohibited conduct.
• Responsible gaming: monitoring gameplay patterns to identify signs of problem gambling; applying deposit limits, session reminders, and self-exclusion measures as requested or as required by our responsible gaming obligations.

Analytics and Platform Improvement

We also use aggregated and, where possible, anonymised data to improve our Platform and services:

• Analysing game performance and player engagement to improve game selection and user experience on the Platform.
• Monitoring Platform technical performance, identifying and resolving errors, and planning infrastructure capacity.
• Where you have given consent, sending you relevant promotional offers, bonus notifications, and service announcements via SMS or email. You may withdraw consent at any time by contacting [email protected].

4. Data Sharing and Disclosure

bq44 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for each specific purpose.

Service Providers

We engage trusted third-party service providers to help us operate the Platform. These providers act as data processors under our instruction and are contractually required to keep your data confidential, use it only for the purposes we specify, and implement appropriate security measures. Categories of service providers include:

• Game technology providers (Pragmatic Play, Evolution Gaming, Spribe, Ezugi, NetEnt, Microgaming) — who receive session and bet data to operate game software and enforce game rules.
• Mobile payment processors — who receive minimal transaction data necessary to process deposits and withdrawals via bKash, Nagad, Rocket, and Upay.
• Identity verification and KYC providers — who assist with document verification and fraud screening, receiving only the specific documents and identity fields required for verification.
• Platform analytics and hosting providers — who process technical usage data to support Platform stability and performance monitoring under strict confidentiality obligations.

Legal Disclosures

We may disclose your personal data to competent authorities, regulatory bodies, law enforcement agencies, or courts where we are legally required to do so, or where such disclosure is necessary to protect the rights, property, or safety of bq44, our players, or the public. We will, where legally permissible, endeavour to notify you before making such a disclosure.

5. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with applicable legal retention obligations, or to resolve disputes and enforce our agreements. The retention periods we apply are guided by the following principles:

Account and Transaction Records

Account registration data and transaction records are retained for a minimum of five years from the date of account closure or the last recorded transaction (whichever is later). This period is required to satisfy financial record-keeping obligations and to support any post-closure investigations or legal proceedings that may arise.

• KYC and identity verification documents are retained for a minimum of five years following account closure, in line with applicable anti-money laundering record-keeping requirements.
• Technical logs (IP address logs, session logs) are retained for up to 12 months for security and fraud monitoring purposes, after which they are deleted or anonymised.
• Support communications are retained for up to 24 months from the date of the last communication in a given thread, to enable consistent handling of ongoing or recurring issues.

Deletion and Anonymisation

When a retention period expires, we will either securely delete the personal data or — where deletion is technically impractical due to backup systems — anonymise it so that it can no longer be associated with you as an individual. Data subject to an ongoing legal hold, regulatory inquiry, or active dispute will be retained until the matter is fully resolved, regardless of the standard retention period.

6. Data Security

bq44 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures are reviewed and updated regularly to reflect current best practice.

Security Measures in Place

The following security controls are applied across the bq44 Platform:

• SSL/TLS encryption for all data transmitted between your device and our servers, preventing interception of data in transit.
• Encrypted storage of sensitive personal data (including identity documents and financial records) at rest, using industry-standard encryption protocols.
• Access controls restricting internal access to personal data on a need-to-know basis, with role-based permissions and audit logging of all access events.
• Real-time fraud and anomaly detection systems that monitor account activity and transaction patterns for signs of compromise or abuse.
• Regular security assessments and penetration testing to identify and remediate vulnerabilities in Platform infrastructure before they can be exploited.

7. Cookies and Tracking Technologies

The bq44 Platform uses cookies and similar tracking technologies to maintain your session, remember your preferences, and analyse usage patterns to improve the Platform. A cookie is a small text file stored on your device by your browser when you visit a website. bq44 does not use cookies to collect personally identifiable information beyond what is necessary for the purposes described in this Policy.

Types of Cookies We Use

We use the following categories of cookies on the Platform:

• Strictly necessary cookies: required for core Platform functionality including user authentication, session management, and security token validation. These cannot be disabled without preventing the Platform from functioning.
• Preference cookies: store non-sensitive user settings such as language preference and notification settings to personalise your experience on return visits.
• Analytics cookies: collect anonymised usage data (page views, session duration, navigation paths) to help us understand how players use the Platform and identify areas for improvement. No personally identifiable information is shared with analytics providers.

Managing Cookie Preferences

You may manage or disable non-essential cookies at any time through your browser's settings. Instructions for managing cookies are available in the help documentation for all major browsers. Please be aware that disabling certain cookies may limit the functionality of the Platform or prevent some features from working correctly. Strictly necessary cookies cannot be disabled without logging out of the Platform.

8. Your Data Rights

As a player using the bq44 Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team at [email protected] with your full name, registered mobile number, and a description of the right you wish to exercise. We will respond within a reasonable period and in any event within 30 days of receiving your request.

Right of Access and Rectification

You have the right to request a copy of the personal data bq44 holds about you (subject access request). If any data we hold is inaccurate or incomplete, you have the right to request that we correct or complete it. We will verify your identity before processing any subject access or rectification request.

Right to Erasure and Restriction

You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. Please note that certain data must be retained to comply with legal obligations (see Section 5) and erasure requests cannot override these obligations. You may also request that we restrict our processing of your data in certain circumstances — for example, while a rectification request is being evaluated.

• The right to object to processing carried out on the basis of legitimate interests, including direct marketing.
• The right to withdraw consent at any time for processing activities that are based on your consent (such as marketing communications), without affecting the lawfulness of processing carried out before withdrawal.
• The right to data portability — to receive a copy of your personal data in a structured, commonly used, machine-readable format where technically feasible and where processing is based on consent or contract.
• The right to lodge a complaint with a relevant data protection authority if you believe your personal data has been processed in a manner that does not comply with applicable data protection law.

9. Children and Minors

The bq44 Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from any person under the age of 21. Age verification is applied at the point of registration and, where required, through our KYC process. If we become aware that we have collected personal data from a person under 21 without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account.

Reporting Concerns

If you have reason to believe that a person under the age of 21 has registered on the bq44 Platform or has provided personal data to us, please contact our support team immediately at [email protected] so that we can investigate and take appropriate action.

Parental Guidance

Parents and guardians are encouraged to monitor the online activities of children in their care and to use available parental control tools to prevent access to gambling platforms. bq44 supports parental control software and recommends its use on any shared device accessible to minors.

10. Changes to This Policy

bq44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When we make material changes to this Policy, we will publish the updated version on this page with a revised effective date and, where appropriate, notify you directly via SMS or the email address registered to your account.

Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must stop using the Platform and contact [email protected] to request account closure.

11. Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way bq44 handles your personal data, please contact our support team. We are committed to addressing privacy queries promptly and transparently.

How to Contact Us

You may reach our support team using the following channels:

• Email (preferred for privacy queries): [email protected] — please include your full name, registered mobile number, and a clear description of your query or request.
• Live chat: available through the bq44 Platform during operating hours (Bangladesh Standard Time, UTC+6).
• Response time target: we aim to respond to all privacy-related queries within five business days.
• For data subject access requests (SAR) or erasure requests, please clearly state the nature of your request in the subject line of your email to help us route it to the correct team.
• If you are not satisfied with our response to your privacy complaint, you have the right to escalate the matter to a relevant data protection supervisory authority in your jurisdiction.

12. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws applicable to the operation of the bq44 Platform. Any dispute arising out of or in connection with this Policy that cannot be resolved through our internal complaints process shall be subject to the dispute resolution procedures set out in the bq44 Terms and Conditions.

If any provision of this Privacy Policy is found to be invalid or unenforceable, the remaining provisions shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its original intent.