hhbaje Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how hhbaje ("hhbaje", "we", "us", "our"), the operator of the online betting and casino platform accessible at https://hhbaje.net ("Platform"), collects, processes, stores, and protects the personal data of individuals ("Player", "User", "you") who register accounts, place bets, access live casino services, or otherwise interact with any part of the Platform.

hhbaje is committed to handling personal data responsibly, transparently, and in accordance with applicable data protection principles. This Policy is designed to give you a clear and complete understanding of what information hhbaje holds about you, why we hold it, how it is used, and what rights you have in relation to it.

This Policy should be read in conjunction with the hhbaje Terms & Conditions and Responsible Gaming policy, both of which form part of the overall agreement between you and hhbaje. In the event of any conflict between this Policy and the Terms & Conditions, the Terms & Conditions shall prevail to the extent of the inconsistency.

2 Data We Collect

hhbaje collects the following categories of personal data from players during registration, account management, transactions, and general use of the Platform:

hhbaje does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information unless expressly required for responsible gaming purposes (such as self-exclusion or problem gambling support), in which case such data is handled with additional protections.

3 How We Collect Data

hhbaje collects personal data through the following means:

• Direct Interactions: Data you voluntarily provide when creating an account, completing identity verification, making a deposit or withdrawal request, submitting a support enquiry, or responding to a promotional communication.
• Automated Technologies: Technical and usage data collected automatically when you access the Platform, including via cookies, server logs, session tracking, and analytics tools. See Section 9 (Cookies & Tracking) for further detail.
• Third-Party Payment Providers: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Visa, and Mastercard when you initiate a deposit or withdrawal. hhbaje receives only the data necessary to reconcile the transaction — full payment credentials are not stored by hhbaje.
• Identity Verification Partners: Where hhbaje engages a third-party identity verification service to assist with Know Your Customer (KYC) checks, that partner may return a verification result and a risk score to hhbaje. The underlying documents you submit are handled in accordance with that partner's data processing terms, which hhbaje reviews for compliance before engagement.
• Publicly Available Sources: In limited circumstances, hhbaje may cross-reference publicly available information (such as publicly listed sanctions databases) as part of its fraud prevention and responsible gaming obligations.

4 Purpose of Processing

hhbaje processes your personal data for the following clearly defined purposes. We do not use your data for any purpose that is incompatible with those listed below without first obtaining your consent or establishing a separate legal basis.

• Account Creation and Management: To register your player account, verify your identity, maintain your account settings, and ensure the accuracy of your profile information throughout your relationship with hhbaje.
• Service Delivery: To process bets, settle wagers, operate live casino functionality, credit and debit account balances, process deposits via bKash, Nagad, Rocket, and Upay, and deliver the full range of hhbaje Platform services.
• Identity and Age Verification: To confirm that you are aged 18 or above and that the information you have provided is genuine, as required by hhbaje's player protection obligations. hhbaje strictly enforces its 18+ policy and will not knowingly process data relating to a minor.
• Financial Transaction Processing: To facilitate, record, and reconcile all deposits, withdrawals, and balance adjustments associated with your account, including communicating with payment providers on your behalf.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other forms of platform misuse. This includes automated screening and risk-scoring processes.
• Responsible Gaming Compliance: To administer deposit limits, self-exclusion requests, reality check reminders, and other responsible gaming tools selected by you or applied by hhbaje in accordance with its player protection framework.
• Customer Support: To respond to your enquiries, resolve disputes, and maintain a record of all support interactions for quality assurance and audit purposes.
• Marketing Communications: To send you promotional offers, bonus notifications, and seasonal campaigns that may be of interest to you, where you have given consent or where a legitimate interest exists. You may opt out of marketing communications at any time by contacting [email protected].
• Platform Improvement: To analyse usage patterns, identify technical issues, optimise the user experience, and develop new features and services on the Platform.
• Legal and Regulatory Compliance: To comply with applicable laws, respond to lawful requests from regulatory or law enforcement authorities, and maintain records as required by applicable financial crime and data protection obligations.

5 Legal Basis for Processing

hhbaje processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Performance of a Contract: Processing that is necessary to deliver the Platform services you have contracted for — including account management, bet processing, and payment transactions — is carried out on the basis that it is necessary for the performance of the contract between you and hhbaje.
• Compliance with a Legal Obligation: Certain processing activities — including identity verification, anti-money laundering screening, and record-keeping — are carried out because hhbaje is legally required to do so under applicable law.
• Legitimate Interests: hhbaje processes certain data on the basis of its legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and business analytics. In each case, hhbaje has assessed that its legitimate interests are not overridden by your rights and freedoms as a data subject.
• Consent: Where hhbaje relies on consent as the basis for processing — for example, for optional marketing communications — you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6 Data Sharing

hhbaje does not sell, rent, or trade your personal data to third parties. We share personal data only in the limited circumstances described below, and only to the extent necessary to fulfil the stated purpose:

• Payment Processors: Your financial data is shared with payment service providers — including bKash, Nagad, Rocket, Upay, Visa, and Mastercard — to the extent necessary to process transactions initiated by you. These providers operate under their own privacy policies and are independently responsible for their data handling practices.
• Identity Verification Partners: Where a third-party KYC provider is used, your identity documents and verification data may be transmitted to that provider for processing. hhbaje engages only providers that implement appropriate data security standards.
• Game Content Providers: Technical session data (such as a session token and game outcome records) may be shared with game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi to the extent required to deliver their games on the Platform. These providers do not receive your full identity or financial profile.
• Analytics and Platform Technology Partners: Aggregated or pseudonymised usage data may be shared with technology partners who assist hhbaje in operating and improving the Platform. Such sharing is subject to data processing agreements that restrict the partner's use of the data to the agreed purpose.
• Legal and Regulatory Authorities: hhbaje may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required by applicable law or a valid legal order. hhbaje will, where legally permitted, notify affected players of such disclosure.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of hhbaje's business, your personal data may be transferred to the successor entity as part of that transaction. hhbaje will provide reasonable notice of such a transfer and ensure that the recipient is bound by privacy obligations no less protective than those in this Policy.

7 Data Retention

hhbaje retains personal data only for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law. The following general retention periods apply:

• Active Account Data: Personal data associated with an active player account is retained for the duration of the account relationship plus a minimum of five years following account closure, to satisfy anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of seven years from the date of the transaction in accordance with applicable financial record-keeping obligations.
• Identity Verification Documents: Copies of identity documents submitted for KYC verification are retained for the duration of the account relationship and for a minimum of five years following account closure.
• Support Communications: Records of support interactions are retained for three years from the date of the last interaction, unless a longer period is required in connection with an ongoing dispute or legal matter.
• Marketing Consent Records: Records of marketing consent and opt-out requests are retained for three years from the date of the consent or opt-out, as evidence of compliance with communication preferences.
• Technical and Usage Logs: Server logs and session data are retained for a maximum of 13 months and are then deleted or anonymised, unless a specific incident investigation requires a longer retention period.

When personal data is no longer required for any lawful retention purpose, hhbaje will delete or irreversibly anonymise it so that it can no longer be associated with an identifiable individual.

8 Data Security

hhbaje takes the security of your personal data seriously and implements a range of technical and organisational measures designed to protect it against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL Encryption: All data transmitted between your device and the hhbaje Platform is encrypted using industry-standard TLS/SSL protocols, preventing interception by third parties during transmission.
• Password Hashing: Account passwords are stored as salted cryptographic hashes. hhbaje staff cannot view your password in plain text, and passwords are never stored in a reversible format.
• Access Controls: Access to personal data within hhbaje's systems is restricted to staff and contractors who require it to perform their specific role. All access is logged and subject to regular review.
• Secure Payment Handling: hhbaje does not store full payment card numbers or mobile wallet PINs on its own systems. Payment credentials are processed exclusively through the secure environments of the relevant payment providers.
• Regular Security Reviews: hhbaje conducts periodic reviews of its security infrastructure and responds promptly to identified vulnerabilities. Players who discover a potential security issue are encouraged to report it to [email protected].

In the event of a data security incident that is likely to result in a high risk to your rights and freedoms, hhbaje will notify affected players without undue delay, describing the nature of the incident and the steps being taken to address it.

9 Cookies & Tracking Technologies

The hhbaje Platform uses cookies and similar tracking technologies to operate effectively, remember your preferences, and gather analytical data about how players use the Platform. The following types of cookies are used:

• Essential Cookies: These cookies are strictly necessary for the Platform to function. They maintain your session state, authenticate your login, and enable core features such as account balance display and bet placement. The Platform cannot function without these cookies and they cannot be disabled.
• Functional Cookies: These cookies remember your preferences — such as your preferred language settings and notification configurations — so that you do not need to re-enter them each session. They are set on the basis of your implicit consent through continued use of the Platform.
• Analytical Cookies: hhbaje uses analytics tools to collect aggregated data about page visits, session durations, game popularity, and navigation patterns. This data is used exclusively to improve the Platform and is not linked to your individual identity in its processed form.
• Security Cookies: Certain cookies are used as part of hhbaje's fraud detection and account security systems, helping to identify anomalous login behaviour or suspicious session patterns.

You may control cookie settings through your browser's built-in preferences. Note that disabling essential cookies will prevent you from accessing core Platform functionality, including logging in to your account. hhbaje does not use third-party advertising cookies or retargeting pixels that track your activity across external websites.

10 Your Rights

As a player whose personal data is processed by hhbaje, you have the following rights in relation to that data. To exercise any of these rights, please contact hhbaje at [email protected] with the subject line "Data Rights Request" and your registered username:

• Right of Access: You have the right to request a copy of the personal data hhbaje holds about you, together with information about how it is being processed.
• Right to Rectification: If any personal data hhbaje holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated without undue delay.
• Right to Erasure: In certain circumstances, you have the right to request that hhbaje delete personal data it holds about you. This right is subject to hhbaje's legal obligations to retain certain data — for example, transaction records required for anti-money laundering compliance — and will not apply where such obligations exist.
• Right to Restrict Processing: You have the right to request that hhbaje restricts its processing of your personal data in certain circumstances, such as while a rectification request is being assessed.
• Right to Data Portability: Where processing is based on your consent or on the performance of a contract, you have the right to receive a structured, machine-readable copy of the personal data you have provided to hhbaje.
• Right to Object: You have the right to object to processing carried out on the basis of hhbaje's legitimate interests, including profiling for responsible gaming purposes. hhbaje will assess your objection and cease processing unless compelling legitimate grounds exist that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time by contacting [email protected]. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

hhbaje will respond to all data rights requests within 30 days of receipt. Where a request is complex or numerous, this period may be extended by a further 60 days, in which case hhbaje will notify you of the extension and the reason for it within the initial 30-day window.

11 Minors & Age Verification

The hhbaje Platform is strictly for adults aged 18 and above. hhbaje does not knowingly collect or process personal data relating to individuals under the age of 18. Age verification is a mandatory step in the account registration and KYC process, and hhbaje reserves the right to request documentary proof of age at any point during a player's use of the Platform.

If you believe that a minor has registered an account on the hhbaje Platform, please contact [email protected] immediately so that the account can be investigated and closed without delay.

12 Changes to This Policy

hhbaje reserves the right to update or amend this Privacy Policy at any time. When material changes are made — meaning changes that significantly affect how your personal data is collected, used, or shared — hhbaje will post an updated version of this Policy on the Platform with a revised effective date and, where reasonably practicable, notify registered players via their registered email address.

Your continued use of the hhbaje Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of those changes. If you do not agree with the updated Policy, you should cease using the Platform and request account closure by contacting [email protected]. It is your responsibility to review this Policy periodically to remain informed of any updates.

13 Contact & Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data hhbaje holds about you, please contact our support team using the details below. All data-related enquiries are handled by staff operating in Bangladesh Standard Time (UTC+6), 24 hours a day, seven days a week.

When submitting a data rights request, please include your registered username and a clear description of your request so that hhbaje can verify your identity and process your request efficiently. hhbaje may ask you to provide additional verification before actioning a data rights request, to ensure that personal data is not disclosed to an unauthorised party.