Your Privacy Matters at hbeje

1 Introduction

hbeje ("hbeje", "we", "us", "our") operates the online betting and casino platform available at hbeje.io. We understand that your privacy is important to you, and we take our responsibilities as a data controller seriously. This Privacy Policy describes what personal data we collect from you when you use the hbeje platform, how we use that data, who we may share it with, and the rights you hold in relation to your personal information.

This Privacy Policy applies to all users of the hbeje platform, including registered members and visitors who browse the site without registering. By accessing or using hbeje, you confirm that you have read and understood this Privacy Policy. This Policy should be read alongside our Terms & Conditions and Responsible Gaming guidelines, all of which form part of the agreement between you and hbeje.

2 Data We Collect

hbeje collects personal data in several ways: directly from you when you register and use the platform, automatically through your use of our website, and from third-party identity verification partners where applicable. The categories of data we collect are described below.

2.1 Registration Data

When you create a hbeje account, we collect the following information that you provide voluntarily:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Mobile phone number (used for account access and SMS notifications)
• Email address
• Residential address within Bangladesh (city, district, postal code)
• Preferred currency (Bangladeshi Taka — BDT)
• Username and encrypted password

2.2 Identity Verification (KYC) Data

To comply with our Know Your Customer (KYC) obligations and to process withdrawal requests, we may ask you to submit copies of the following documents:

• National Identity Card (NID)
• Passport (bio-data page)
• Birth certificate (for users who do not yet hold an NID)
• Proof of residential address (utility bill, bank statement, or similar document issued within the last three months)
• Proof of payment method ownership (e.g., a screenshot or statement confirming your bKash, Nagad, or Rocket account is registered in your name)

2.3 Financial Transaction Data

hbeje records all financial transactions associated with your account, including:

• Deposit amounts, dates, times, and payment methods used (bKash, Nagad, Rocket, Upay, Visa, Mastercard, bank transfer)
• Withdrawal requests and disbursement records
• Bonus credits and wagering activity
• Account balance history

hbeje does not store full payment card numbers or mobile banking PINs. Payment method references (such as the last four digits of a card or a partial mobile wallet number) are retained for record-keeping and fraud prevention purposes only.

2.4 Betting & Gaming Activity Data

We maintain a full record of your activity on the platform, including:

• Sports bets placed, including market selections, stake amounts, odds, and outcomes
• Casino game sessions, including game titles played, bet sizes, and session duration
• Crash game rounds participated in (e.g., Monster Crash)
• Fishing game sessions (e.g., All-Star Fishing)
• Slot game sessions including titles, spin frequency, and outcomes

This activity data is used for account management, responsible gaming monitoring, dispute resolution, and fraud prevention. It is not shared with third parties for marketing purposes.

2.5 Technical & Device Data

When you access hbeje, our servers automatically collect certain technical information about your device and connection:

Data Type	Purpose
IP address	Geographic restriction enforcement, fraud detection, security logging
Device type and operating system	Platform optimisation and technical support
Browser type and version	Compatibility testing and user experience improvement
Session timestamps and duration	Responsible gaming monitoring, session time reminders
Pages visited and navigation paths	Platform analytics and UX optimisation
Referral source (where applicable)	Marketing attribution and affiliate management

2.6 Communications Data

When you contact our support team — whether by email, live chat, or any other channel — we retain a record of the communication, including the content of your messages, the date and time of contact, and the resolution provided. This record is used to ensure consistency and quality in our customer support and to assist with dispute resolution.

3 How We Use Your Data

hbeje uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and administering your hbeje account, including processing deposits, withdrawals, and bonus allocations.
• Identity Verification: Confirming that you are 21 years of age or older, that you are resident in Bangladesh, and that your account details are accurate and genuine.
• Transaction Processing: Facilitating deposits via bKash, Nagad, Rocket, and other accepted payment methods, and processing withdrawal requests to your verified payment account.
• Fraud Prevention & Security: Monitoring account activity for suspicious patterns, preventing multiple account registrations, detecting and blocking unauthorised access attempts, and complying with anti-money laundering (AML) obligations.
• Responsible Gaming: Tracking your gaming activity to identify patterns that may indicate problem gambling behaviour, applying deposit limits or self-exclusion restrictions where requested, and delivering session time reminders and reality check notifications.
• Customer Support: Responding to your enquiries, processing complaints, and resolving disputes in relation to your hbeje account.
• Platform Improvement: Analysing aggregated, anonymised usage data to understand how members use hbeje, identify technical issues, and improve the platform's features and performance.
• Legal Compliance: Fulfilling our obligations under applicable law, responding to lawful requests from regulatory or law enforcement authorities, and maintaining records required for audit and compliance purposes.
• Marketing Communications (opt-in only): Sending you information about promotions, bonuses, new game launches, and seasonal offers — including Eid specials, Pohela Boishakh promotions, and BPL cricket betting offers — where you have opted in to receive such communications.

4 Legal Basis for Processing

hbeje processes your personal data on the following legal grounds:

• Contract Performance: Processing that is necessary to deliver the services you have requested by registering a hbeje account, including account management, transaction processing, and KYC verification.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including AML obligations, age verification requirements, and responses to lawful regulatory requests.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where those interests are not overridden by your rights and interests.
• Consent: Processing for direct marketing communications, where you have given explicit opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Data Sharing & Disclosure

hbeje does not sell, rent, or share your personal data with third parties for their own commercial purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

5.1 Payment Service Providers

To process deposits and withdrawals, we share the minimum necessary transaction data with your chosen payment service provider (e.g., bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, Islami Bank, or Visa/Mastercard processing networks). These providers are contractually required to handle your data securely and in accordance with applicable financial regulations.

5.2 Identity Verification Partners

Where hbeje uses third-party KYC verification technology to assist with identity and age verification, your submitted identity documents may be processed by that partner on our behalf. Such partners are bound by strict data processing agreements and may not use your data for any purpose beyond the specific verification service they provide to hbeje.

5.3 Game Technology Providers

Certain game session data (such as bet amounts and game outcomes) may be transmitted to third-party game studios — including Evolution Gaming, Pragmatic Play, Spribe, Ezugi, and Microgaming — as part of the technical operation of their games within the hbeje lobby. This data exchange is required to record game results accurately and to support dispute resolution. Game providers operate under their own privacy frameworks; hbeje is not responsible for their independent data practices.

5.4 Legal & Regulatory Authorities

hbeje may disclose your personal data to law enforcement agencies, regulatory bodies, or other competent authorities when required to do so by applicable law, court order, or where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or other illegal activity.

5.5 Business Transfers

In the event that hbeje undergoes a merger, acquisition, or sale of all or a substantial part of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify registered members of any such transfer and of any material changes to the privacy terms that apply to their data.

6 Cookies & Tracking Technologies

hbeje uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyse usage patterns. The types of cookies used on hbeje are as follows:

• Strictly Necessary Cookies: These cookies are essential for the platform to function and cannot be disabled. They include session authentication cookies, security tokens, and load-balancing identifiers. Without these cookies, features such as logging in, maintaining your session, and placing bets would not be possible.
• Functional Cookies: These cookies remember your preferences, such as your preferred language, odds display format, and notification settings, so that you do not need to reconfigure them on every visit.
• Analytics Cookies: hbeje uses analytics tools to understand aggregate platform usage — such as which game categories are most popular, which pages have high exit rates, and how users navigate between sections. Analytics data is processed in aggregated, anonymised form and is not linked to individual user identities.
• Marketing & Attribution Cookies: Where you have arrived at hbeje via a partner or affiliate link, an attribution cookie may be set to record this referral. This cookie does not track your activity across third-party websites and is used solely for the purpose of crediting the correct affiliate partner with your registration.

You may manage or disable non-essential cookies through your browser settings at any time. Note that disabling strictly necessary cookies will impair the functionality of the hbeje platform and may prevent you from logging in or completing transactions.

7 Data Retention

hbeje retains your personal data for as long as your account is active and for a period thereafter as required by our legal and regulatory obligations. The specific retention periods that apply to different categories of data are as follows:

• Account Registration Data: Retained for the lifetime of your account and for a minimum of 5 years following account closure, in accordance with financial record-keeping requirements.
• KYC Identity Documents: Retained for a minimum of 5 years from the date of submission or from the date of account closure, whichever is later, in compliance with anti-money laundering regulations.
• Transaction Records: All deposit and withdrawal records are retained for a minimum of 7 years following the date of the transaction.
• Betting & Gaming History: Retained for a minimum of 3 years from the date of each transaction for responsible gaming monitoring and dispute resolution purposes.
• Customer Support Communications: Retained for 2 years from the date of the final communication in each support thread.
• Marketing Preferences & Consent Records: Retained for as long as you hold an active account, and for 2 years following account closure or opt-out, to demonstrate consent compliance.

When data is no longer required under any applicable retention period, hbeje will securely delete or anonymise that data in a manner that makes re-identification impossible.

8 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and hbeje's servers.
• Encryption at rest for all stored personal data and KYC documents within our secure data infrastructure.
• Access controls that restrict access to personal data to authorised personnel only, based on the principle of least privilege.
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals.
• Multi-factor authentication requirements for administrative access to systems that contain personal data.
• Automated intrusion detection and alerting systems that monitor for unusual access patterns or potential breaches in real time.
• Staff training on data protection obligations and secure handling of personal information.

9 Your Rights

As a user of the hbeje platform and a data subject whose personal information we process, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request — [Your Username]".

• Right of Access: You may request a copy of the personal data that hbeje holds about you. We will respond to verified access requests within 30 days.
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Many details can be updated directly from within your Account Settings panel.
• Right to Erasure: In certain circumstances, you may request that we delete your personal data. This right is subject to limitations — for example, we may be required by law to retain certain records (such as transaction history and KYC documents) for defined periods even after account closure.
• Right to Restrict Processing: You may ask hbeje to suspend the processing of your personal data in specific circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to Data Portability: Where processing is based on your consent or on contract performance, you may request that we provide your personal data in a structured, machine-readable format so that it can be transferred to another service provider.
• Right to Object: You may object to processing that is based on legitimate interests, including profiling for responsible gaming monitoring. Note that certain processing activities are mandatory for the operation of your account and cannot be objected to without resulting in account closure.
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

10 Children & Minors

The hbeje platform is strictly restricted to adults aged 21 years or older. hbeje does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register an account, submit any personal information, or attempt to access any part of the hbeje platform.

If hbeje becomes aware that personal data has been collected from a user who is under 21 years of age, that account will be immediately suspended, any funds held in the account will be returned to the verified payment source (subject to AML checks), and all associated personal data will be securely deleted from our systems. If you are a parent or guardian and believe that a minor in your care has registered a hbeje account, please contact us immediately at [email protected].

11 Third-Party Links & Services

The hbeje platform may contain references to or integrations with third-party services — such as the game studios whose titles appear in our casino lobby or the payment networks used to process your transactions. hbeje is not responsible for the privacy practices of any third party, and this Privacy Policy does not apply to any website, application, or service operated by a third party, even if it is accessible through the hbeje platform.

We encourage you to review the privacy policies of any third-party service you interact with through hbeje, including your mobile wallet provider (bKash, Nagad, Rocket), your bank, and any game studio whose live games you access via our casino lobby.

12 Updates to This Privacy Policy

hbeje reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, changes in applicable law, or operational changes to the platform. When we make material changes to this Policy, we will notify registered members via the email address associated with their account and will display a notice on the hbeje platform for at least 14 days following the update.

The "Last Updated" date at the top of this document reflects the date on which the most recent revision was published. We encourage you to review this Privacy Policy periodically to stay informed about how hbeje handles your personal data. Your continued use of the hbeje platform following the publication of any revised Policy constitutes your acceptance of the updated terms.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way hbeje handles your personal data, please contact our Data Protection team using the following details. We aim to respond to all privacy-related enquiries within 5 business days.

• Email: [email protected]
• Subject Line: "Privacy Policy Enquiry — [Your Account Username]"
• Support Hours: 24/7 — Bangladesh Standard Time (BST, UTC+6)
• Languages: English and Bengali

For data rights requests specifically (access, rectification, erasure, portability, objection), please include your full registered name, your hbeje username, and a clear description of your request. We may ask you to verify your identity before processing a data rights request to ensure that we disclose or amend data only to the correct account holder.