abc1 Privacy Policy — How We Protect Your Personal Data

1. Data We Collect

1.1 Information You Provide Directly

When you register an abc1 account, make a deposit, request a withdrawal, or contact our support team, you voluntarily provide us with certain personal information. The categories of data you provide directly include:

• Identity data: Full legal name, date of birth, nationality, and gender;
• Contact data: Email address, mobile phone number, and residential address (including city and district — e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi);
• Account credentials: Username and encrypted password;
• Identity verification documents: National Identity Card (NID), passport, driving licence, or other government-issued photo ID submitted during KYC;
• Payment data: bKash account number, Nagad account number, Rocket wallet number, Upay details, or bank account details for Dutch-Bangla Bank, City Bank, or BRAC Bank transactions. We do not store full payment card numbers;
• Communications: Messages, chat transcripts, and email correspondence sent to the abc1 support team.

1.2 Data Collected Automatically

When you access and use the abc1 platform, certain technical information is collected automatically by our systems. This includes:

• Device and technical data: IP address, browser type and version, operating system, device type, screen resolution, and device identifiers;
• Usage data: Pages visited, features used, games played, bets placed, session duration, click patterns, and in-platform navigation behaviour;
• Transaction data: A complete record of all deposits, withdrawals, bets, game rounds, and bonus transactions associated with your account;
• Location data: General geographic location inferred from your IP address. abc1 does not collect precise GPS location data.

1.3 Data from Third Parties

abc1 may receive personal data about you from third-party sources in limited circumstances, including identity verification agencies used during KYC, fraud prevention and anti-money laundering (AML) screening providers, and payment processing partners. Data received from third parties is handled in accordance with this Privacy Policy and the contractual obligations governing those third-party relationships.

2. How We Use Your Data

2.1 Primary Purposes

abc1 uses the personal data we collect for the following primary purposes, each of which is necessary for the delivery of our services to you:

Purpose	Data Used	Legal Basis
Account registration & management	Identity, contact, credentials	Contract performance
Processing deposits & withdrawals	Identity, payment data	Contract performance
KYC identity verification	Identity documents, address	Legal obligation
Fraud prevention & AML compliance	Transaction, device, identity	Legal obligation
Customer support	Communications, account data	Contract performance
Responsible gaming monitoring	Usage, transaction data	Legal obligation / Legitimate interest
Platform improvement & analytics	Usage, device data	Legitimate interest
Promotional communications (with consent)	Contact, usage data	Consent

2.2 Responsible Gaming Use

abc1 uses player transaction and usage data to monitor for indicators of problem gambling behaviour. This includes analysing deposit frequency, bet sizing patterns, session duration, and self-exclusion history. Where our monitoring identifies a player who may be experiencing gambling-related harm, we may reach out proactively with information about responsible gaming tools and support resources. This processing is carried out in the interest of player welfare and is a core element of our responsible gaming commitment.

2.3 Marketing Communications

abc1 may send you promotional communications about new games, bonuses, and platform features by email or SMS if you have given your explicit consent to receive such communications. You may withdraw your consent and opt out of marketing messages at any time by updating your account notification preferences or by contacting support at [email protected]. Opting out of marketing will not affect the delivery of transactional communications relating to your account, such as deposit confirmations and withdrawal notifications.

3. Data Sharing & Third Parties

3.1 Categories of Recipients

abc1 does not sell your personal data. We share your data only with the following categories of trusted third parties, and only to the extent necessary for the stated purpose:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and BRAC Bank, for the processing of deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and screen against sanctions lists;
• Game software providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other game studios whose software is integrated into the abc1 platform. Game providers receive only the data necessary to deliver gameplay sessions and may record game outcomes for dispute resolution;
• IT and hosting providers: Cloud infrastructure and server hosting partners who store and process platform data on our behalf under strict data processing agreements;
• Analytics providers: Platform performance and usage analytics tools that help us understand how players interact with the abc1 platform;
• Legal and regulatory authorities: Law enforcement, financial intelligence units, or regulatory bodies where we are required to disclose data by applicable law, court order, or legal process.

3.2 Data Processing Agreements

All third-party service providers who process personal data on behalf of abc1 are required to enter into a formal data processing agreement that obligates them to handle your data in accordance with applicable data protection law, maintain appropriate technical and organisational security measures, process data only on abc1's documented instructions, and not engage sub-processors without abc1's prior written authorisation.

3.3 International Data Transfers

Some of abc1's third-party service providers operate outside Bangladesh. Where personal data is transferred internationally, abc1 ensures that appropriate safeguards are in place, such as standard contractual clauses, to maintain the protection of your data. By using the abc1 platform, you acknowledge that your data may be transferred to and processed in countries other than your country of residence.

4. Cookies & Tracking Technologies

4.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. abc1 uses cookies and similar technologies (such as web beacons and local storage) to ensure the platform functions correctly, to remember your session and preferences, and to gather anonymised analytics data about how players use the platform.

4.2 Types of Cookies We Use

• Essential cookies: Required for the platform to function. These include session authentication cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cookies cannot be disabled without breaking the platform.
• Functional cookies: These remember your preferences such as language settings, preferred payment method, and display options, so you do not need to re-enter them on each visit.
• Analytics cookies: These collect anonymised data about how players navigate the abc1 platform, which pages are most visited, and where players encounter errors. This data is used exclusively to improve platform performance and user experience.
• Responsible gaming cookies: abc1 uses session tracking to monitor time spent on the platform as part of our responsible gaming commitment. This data is not shared with advertising networks.

4.3 Managing Cookies

You can manage and delete cookies at any time through your browser settings. Most modern browsers allow you to block all cookies, block third-party cookies only, or delete existing cookies. Please note that disabling essential cookies will impair the functionality of the abc1 platform and you may be unable to log in or complete transactions. abc1 does not use third-party advertising cookies or retargeting pixels.

5. Data Retention

5.1 Retention Periods

abc1 retains different categories of personal data for different periods depending on the purpose for which the data was collected and applicable legal requirements. Our general retention framework is as follows:

• Account data and transaction records: Retained for the duration of your account relationship with abc1 and for a minimum of five years following account closure, in compliance with anti-money laundering and financial record-keeping obligations;
• KYC identity documents: Retained for five years from the date of submission or from the date of account closure, whichever is later, in accordance with AML requirements;
• Customer support communications: Retained for three years from the date of the last interaction, to support dispute resolution;
• Technical and usage logs: Retained for up to 12 months for security monitoring and platform improvement purposes, after which they are deleted or anonymised;
• Marketing consent records: Retained for the duration of your consent and for two years following withdrawal of consent, to demonstrate compliance.

5.2 Deletion and Anonymisation

Once the applicable retention period for a category of data has expired, abc1 will securely delete the data or, where deletion is not technically feasible in the short term, anonymise it so that it can no longer be associated with your identity. You may also request deletion of your personal data by contacting our support team, subject to the retention obligations described above.

6. Data Security Measures

6.1 Technical Safeguards

abc1 implements a comprehensive set of technical security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. These measures include 256-bit SSL/TLS encryption for all data in transit, AES-256 encryption for sensitive data at rest, multi-factor authentication for internal administrative access, regular automated vulnerability scanning and penetration testing, and real-time intrusion detection and prevention systems.

6.2 Organisational Safeguards

In addition to technical controls, abc1 applies strict organisational measures including role-based access controls that limit employee access to personal data on a strict need-to-know basis, mandatory data protection training for all staff who handle player data, documented data processing procedures and internal privacy policies, and regular internal audits of data handling practices.

6.3 Data Breach Response

In the event of a personal data breach that poses a risk to the rights and freedoms of affected players, abc1 will take immediate steps to contain the breach and assess its scope. Affected players will be notified as soon as reasonably practicable with information about the nature of the breach, the categories of data affected, and the steps they should take to protect themselves. abc1 maintains a documented incident response plan that is reviewed and tested regularly.

7. Your Privacy Rights

7.1 Summary of Your Rights

As an abc1 player, you have the following rights with respect to your personal data. You may exercise any of these rights at any time by contacting our support team at [email protected]:

• Right of access: You have the right to request a copy of the personal data that abc1 holds about you, together with information about how it is being used;
• Right to rectification: You have the right to request that inaccurate or incomplete personal data held by abc1 be corrected or completed;
• Right to erasure: You have the right to request that abc1 delete your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations;
• Right to restriction: You have the right to request that abc1 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data;
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format and to transfer it to another service provider;
• Right to object: You have the right to object to processing of your personal data where that processing is based on abc1's legitimate interests. You also have an unconditional right to object to processing for direct marketing purposes;
• Right to withdraw consent: Where abc1's processing of your data is based on your consent (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

7.2 How to Exercise Your Rights

To exercise any of the rights listed above, please send a written request to [email protected] with the subject line "Privacy Rights Request". Please include your full name, registered email address, and a clear description of the right you wish to exercise. abc1 will acknowledge your request promptly and respond within a reasonable timeframe. We may need to verify your identity before processing certain requests to protect against unauthorised access to your data.

7.3 Minors

The abc1 platform is strictly for adults aged 18 and above. abc1 does not knowingly collect personal data from any person under the age of 18. If you believe that a minor has provided personal data to abc1, please contact us immediately at [email protected] and we will take prompt steps to delete that data from our systems.

8. Contact & Complaints

8.1 Privacy Queries

If you have any questions about this Privacy Policy, about the way abc1 handles your personal data, or about how to exercise your privacy rights, please contact our support team. Our data protection contact is available via email at [email protected]. We aim to respond to all privacy-related queries within a reasonable timeframe. When contacting us about a privacy matter, please include your registered account email address so we can locate your data records efficiently.

8.2 Updates to This Policy

abc1 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to our platform. When material changes are made, the "Last Updated" date at the top of this page will be revised. We encourage you to review this Privacy Policy periodically. Continued use of the abc1 platform following any amendment constitutes your acceptance of the revised Privacy Policy.

8.3 Entire Privacy Framework

This Privacy Policy should be read in conjunction with the abc1 Terms & Conditions and our Responsible Gaming Policy, all of which together form the complete framework governing the relationship between abc1 and its players in Bangladesh. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions on a privacy matter, this Privacy Policy shall prevail.