Privacy Policy — cd44ap Data Protection Commitment

For the purposes of this Privacy Policy, the data controller responsible for the collection and processing of your personal data is cd44ap, operating the platform accessible at cd44ap.app. As data controller, cd44ap determines the purposes and means by which your personal data is processed.

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data cd44ap holds about you, you may contact our dedicated Privacy team using the details below:

This Privacy Policy applies to all personal data collected through the cd44ap website, mobile browser experience, and any associated platform features including account registration, deposits, withdrawals, game play, sports betting, and customer support interactions.

By creating an account and using the cd44ap platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with any provision of this policy, you should cease using the platform and contact us to close your account.

cd44ap collects personal data through several channels: directly from you when you register an account or interact with the platform, automatically through your device and browser when you use the platform, and from third parties such as payment processors and identity verification services where required.

Registration and Account Data. When you create a cd44ap account, we collect the following information:

• Full legal name;
• Date of birth (used for age verification — players must be 18 or older);
• Bangladesh mobile phone number;
• Email address;
• Account username and encrypted password;
• City or district of residence (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi).

Identity Verification Data. When you request a withdrawal or where our fraud prevention systems flag a review requirement, we may request:

• National Identity Card (NID) number or photocopy;
• Passport or driving licence image;
• A selfie photograph for facial comparison;
• Proof of payment method ownership (e.g., screenshot of bKash or Nagad account showing registered name and number).

Financial Transaction Data. For each deposit and withdrawal, we record:

• Payment method type (e.g., bKash, Nagad, Rocket, Upay, Visa, Mastercard);
• Transaction amount in BDT (৳);
• Transaction date, time, and reference number;
• Payment method account number or card last-four digits (we do not store full card numbers).

Gameplay and Betting Activity Data. We maintain records of:

• All wagers placed, including game type, bet amount, outcome, and settlement;
• Cricket betting activity including markets selected, odds accepted, and match results;
• Session duration, game history, and platform navigation behaviour;
• Responsible gaming tool settings (deposit limits, session alerts, self-exclusion status).

Technical and Device Data. Automatically collected when you access the platform:

• IP address and approximate geographic location;
• Device type, operating system, and browser version;
• Session timestamps, page views, and click-path data;
• Cookies and similar tracking technologies (see Section 5).

Communications Data. When you contact cd44ap support via live chat or email, we retain records of those communications including the content of your messages and the date and time of contact.

cd44ap processes your personal data only for defined, legitimate purposes. We do not use your data in ways that are incompatible with the purposes disclosed below.

Account Management and Service Delivery. The primary purpose of data collection is to create and manage your cd44ap account, enable game play and sports betting activity, process deposits and withdrawals, and provide customer support. This processing is necessary for the performance of the contract between you and cd44ap.

Identity Verification and Age Verification. Verifying that players are 18 years of age or older is a non-negotiable legal and ethical obligation. We use the identity documents you provide to confirm your age, legal name, and payment method ownership before releasing withdrawal funds. This processing is necessary for legal compliance.

Fraud Prevention and Security Monitoring. We analyse account activity, IP data, device fingerprints, and betting patterns to detect and prevent fraud, money laundering, collusion, and the use of automated betting tools. This processing is necessary for our legitimate interests in protecting the integrity of the platform and safeguarding legitimate players.

Responsible Gaming Compliance. We use your gameplay and financial data to monitor for indicators of problem gambling behaviour (such as rapid escalation of deposit frequency or bet size) and to enforce the responsible gaming tools you have set (deposit limits, session alerts, self-exclusion). This processing is necessary for legal compliance and our duty of care to players.

Platform Improvement and Analytics. Aggregated, anonymised usage data helps us understand how players navigate the platform, which games are most popular, and where technical issues occur. This data is used to improve platform performance and user experience. It is anonymised such that individual players cannot be identified from this data.

Promotional Communications. If you have opted in to marketing communications during registration, we may send you information about promotions, bonuses, and platform updates relevant to your activity. You may opt out of marketing emails at any time by contacting [email protected] or by following the unsubscribe instruction in any marketing email.

Legal Obligations. We may be required to process and retain certain personal data to comply with applicable laws, regulatory requirements, or lawful requests from competent authorities. In such cases, processing is required by law and cannot be avoided regardless of consent status.

cd44ap does not sell your personal data to third parties. We share data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

Payment Processors. To process deposits and withdrawals, we share relevant transaction data with your chosen payment provider (such as bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, or card network operators). This data sharing is strictly necessary for payment execution. Payment providers are bound by their own privacy policies and applicable financial regulations.

Game Providers. cd44ap integrates slot and live casino games from third-party providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. To deliver these games within your session, your account session token and (in some cases) your username are passed to the game provider's system. These providers do not receive your full identity or financial data and are contractually obligated to use session data only to deliver the requested game.

Identity Verification Services. Where we engage a third-party service to assist with KYC (Know Your Customer) document verification, the identity documents you submit may be processed by that service on our behalf. Such providers act as data processors under contract with cd44ap and are prohibited from using your identity data for any purpose other than verification on our behalf.

Fraud Prevention and Security Providers. We may share IP address, device fingerprint, and behavioural data with specialist fraud prevention services to detect and prevent fraudulent account activity. These providers process data on our behalf under strict contractual data protection obligations.

Legal and Regulatory Disclosure. We may disclose personal data to competent authorities, law enforcement bodies, or regulatory agencies where we are legally required to do so or where disclosure is necessary to protect the safety of users or the public. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement.

Business Transfers. In the event that cd44ap undergoes a restructuring, merger, or transfer of business assets, your personal data may form part of the transferred assets. In such an event, the acquiring party will be bound by the terms of this Privacy Policy or an equivalent standard of data protection, and you will be notified of any material change in data controller.

We do not share your personal data with advertising networks, data brokers, social media platforms, or any third party for purposes of targeting you with advertisements.

cd44ap uses cookies and similar technologies (including local storage and session storage) to operate the platform effectively and to improve your experience. This section explains what cookies we use, why we use them, and how you can manage them.

What Are Cookies? Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognise your device, maintain your session state, and store limited preferences. Cookies cannot execute code or transmit viruses.

Strictly Necessary Cookies. These cookies are essential for the platform to function. Without them, core features such as login sessions, account navigation, game loading, and deposit flows would not work correctly. These cookies cannot be disabled without preventing your use of the platform. Examples include session authentication tokens and CSRF protection tokens.

Performance and Analytics Cookies. These cookies collect anonymised information about how players interact with the platform — which pages are visited most, where errors occur, and how navigation flows are used. This data helps cd44ap improve the platform. These cookies do not identify individual users.

Fraud Detection Cookies. To protect legitimate players and the integrity of the platform, we use device fingerprinting and behavioural cookies to detect automated activity, account sharing, and other suspicious patterns. The data collected is used exclusively for security purposes.

Preference Cookies. These cookies store your platform preferences such as language settings and responsible gaming tool configurations (e.g., your active deposit limit) so that your settings persist between sessions.

What We Do NOT Use. cd44ap does not use third-party advertising cookies, retargeting pixels, social media tracking scripts, or any technology designed to build profiles of your browsing behaviour across sites other than cd44ap.app.

Managing Cookies. You may manage or delete cookies through your browser settings. Instructions for the most common browsers are available on the browser developer's support pages. Please note that disabling strictly necessary or fraud detection cookies will impair your ability to use the cd44ap platform.

Retention Principle. cd44ap retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. When the retention period for a given category of data expires, that data is securely deleted or anonymised.

Account Data. Personal data associated with your cd44ap account (name, date of birth, contact details, identity documents) is retained for the duration of your account's active status and for a period of 5 years following account closure. This retention period reflects our legal obligation to maintain records for anti-money-laundering (AML) compliance purposes.

Transaction Records. All records of financial transactions (deposits, withdrawals, and bet settlements) are retained for a minimum of 5 years from the date of each transaction. This is required for financial compliance, dispute resolution, and fraud investigation purposes.

Communications Records. Records of support interactions (live chat transcripts and email correspondence) are retained for 2 years from the date of the interaction. These records are used to ensure consistent support quality and to evidence dispute resolution outcomes.

Technical and Device Data. Server log data including IP addresses and session records is retained for 12 months from the date of collection. After this period, logs are deleted or permanently anonymised.

Marketing Data. If you have opted into marketing communications, your marketing consent record and contact details used for marketing are retained for the duration of your active account and deleted within 30 days of any opt-out request.

Data Storage Security. All personal data held by cd44ap is stored on secure servers with access controls, encryption at rest, and regular security auditing. Access to personal data is restricted to authorised cd44ap personnel with a legitimate operational need. All staff with access to personal data are subject to confidentiality obligations.

Data Breach Response. In the event of a data breach that poses a risk to players' personal data, cd44ap will notify affected players without undue delay via their registered email address, detailing the nature of the breach, the data categories affected, and the steps taken to address the breach.

As a cd44ap player, you hold the following rights in respect of the personal data we process about you. To exercise any of these rights, contact [email protected] with your account username and a description of your request. We will respond within 30 days.

Right of Access. You have the right to request a copy of all personal data cd44ap holds about you, along with information about how it is being processed. This is commonly referred to as a Subject Access Request (SAR). We will provide this information in a structured, readable format within 30 days of your verified request.

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. You may update some information directly within your account settings; for corrections to identity or payment data, contact support.

Right to Erasure. Subject to our legal retention obligations (particularly the 5-year AML record-keeping requirement), you have the right to request the deletion of your personal data. Where erasure is not possible due to a legal retention requirement, we will inform you of this and restrict processing of the relevant data to the minimum required for compliance purposes.

Right to Restriction of Processing. You may request that we temporarily restrict the processing of your personal data while a correction request or objection is under review. During a processing restriction, we will continue to store your data but will not actively process it beyond storage.

Right to Object. You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis. If you object, we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, or the processing is required for legal claims.

Right to Withdraw Consent. Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

Right to Data Portability. Where processing is carried out by automated means and based on your consent or contractual necessity, you may request that we provide your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV), or that we transmit it directly to another controller where technically feasible.

cd44ap reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, platform features, legal obligations, or regulatory guidance. The "Last Reviewed" date displayed at the top of this page and in the hero section will be updated whenever a revision is made.

Notification of Material Changes. Where a change to this policy is material — meaning it significantly alters how your personal data is collected, used, or shared — cd44ap will notify you via the email address registered to your account at least 14 days before the change takes effect. For non-material clarifications or corrections, the policy will be updated without individual notification.

Continued Use as Acceptance. Your continued use of the cd44ap platform following notification of a policy update constitutes your acceptance of the revised Privacy Policy. If you do not accept the updated terms, you should cease using the platform and request account closure by contacting [email protected].

Historical Versions. Prior versions of this Privacy Policy are available on request by contacting [email protected]. If a dispute arises concerning data processing that occurred prior to a policy update, the version of the policy in effect at the time of the relevant processing will apply.

We encourage you to review this Privacy Policy periodically to stay informed about how cd44ap protects your personal data. If you have any questions about this policy or about our data practices generally, our Privacy team is available at [email protected] and our support team is available 24/7 via live chat with an average response time of under 90 seconds.