Your Privacy Matters to 22bb — Our Commitment to You

Article 1

Introduction

22bb is an internationally licensed online casino and sports betting platform serving players in Bangladesh and other eligible markets. We are committed to handling your personal data with transparency, integrity, and care. This Privacy Policy sets out our practices with respect to the collection, use, storage, disclosure, and protection of your personal information in connection with the 22bb platform and all related services.

The policy applies to all individuals who interact with 22bb, including registered players, visitors who browse the platform without registering, and individuals who contact us via our support channels. It covers data collected through the 22bb website, mobile-optimised browser interface, and any other digital touchpoints operated by 22bb.

This policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference. Where this policy uses defined terms from the Terms & Conditions without separately defining them here, those terms carry the same meaning as defined therein.

Article 2

Data Controller

For the purposes of applicable data protection law, 22bb is the data controller in respect of your personal data. This means that 22bb determines the purposes for which, and the manner in which, your personal data is processed. As data controller, 22bb is responsible for ensuring that processing activities are conducted lawfully and in accordance with the principles set out in this policy.

Where 22bb engages third-party service providers to process data on its behalf — such as payment processors, KYC verification providers, and analytics platforms — those parties act as data processors under 22bb's instructions and are bound by contractual obligations that prohibit them from using your data for any purpose other than the specific service they provide to 22bb.

For all data-related enquiries, correction requests, deletion requests, or complaints, please contact the 22bb data team at: [email protected]

Article 3

Data We Collect

3.1 Registration Data

When you create a 22bb account, we collect the information you provide during registration. This typically includes your full legal name, date of birth, residential address, email address, and mobile phone number. This data is required to create and manage your account and to verify that you meet the minimum age requirement of 21 years.

3.2 Identity Verification (KYC) Data

To comply with our anti-money laundering and responsible gaming obligations, we may request identity verification documents at registration or prior to processing a withdrawal. Documents collected may include a copy of your National Identity Card (NID), passport, driver's licence, or a recent utility bill or bank statement for proof of address. Biometric data contained within these documents is processed only to the extent necessary for identity verification.

3.3 Financial Data

When you make a deposit or request a withdrawal, we collect transaction data including the payment method used (e.g., bKash, Nagad, Rocket, Upay, Visa, Mastercard), the transaction amount in BDT, the date and time of the transaction, and a transaction reference number. We do not store full payment card numbers or mobile wallet PINs — these are handled exclusively by our licensed payment partners.

3.4 Gaming Activity Data

We collect records of your activity on the 22bb platform, including games played, bets placed, amounts wagered, winnings, bonus usage, and session duration. This data is used for account management, dispute resolution, responsible gaming monitoring, and platform improvement. It is retained as part of your account history for the duration of the retention periods specified in Article 8.

3.5 Technical & Device Data

When you visit the 22bb platform, we automatically collect certain technical information about your device and connection. This includes your IP address, browser type and version, operating system, device type, screen resolution, referring URL, and pages visited. This data is used to ensure platform security, prevent fraud, and improve the user experience.

3.6 Communications Data

If you contact us via our support email or live chat, we retain records of those communications, including the content of your messages, the date and time of contact, and the resolution outcome. This data is used for quality assurance, dispute resolution, and ongoing support.

Article 4

How We Use Your Data

22bb uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, and securing your 22bb account; processing logins; and managing account settings and preferences.
• Identity and age verification: Confirming that you are at least 21 years of age and that the identity information you have provided is accurate and genuine, in accordance with our KYC obligations.
• Payment processing: Facilitating deposits and withdrawals through your chosen payment method; verifying that payment instruments are registered in your name; and maintaining accurate transaction records.
• Fraud prevention and security: Detecting and investigating suspicious activity, unauthorised account access, money laundering, bonus abuse, and other forms of fraudulent conduct that may harm you, other players, or the integrity of the platform.
• Responsible gaming: Monitoring gaming patterns to identify signs of problem gambling; administering self-exclusion, deposit limit, and cool-off requests; and complying with responsible gaming obligations applicable to the platform.
• Customer support: Responding to your enquiries, complaints, and disputes; managing escalations; and maintaining records of support interactions for quality assurance and compliance purposes.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the design, performance, and features of the 22bb platform.
• Legal compliance: Fulfilling our obligations under applicable law, including anti-money laundering requirements, financial reporting obligations, and responses to lawful requests from competent authorities.
• Marketing communications: Sending you promotional offers, bonus notifications, game updates, and seasonal promotions — but only where you have given explicit consent to receive such communications. See Article 13 for full details.

Article 5

Legal Basis for Processing

22bb processes your personal data on the following legal bases:

5.1 Contractual Necessity

The majority of our processing activities are necessary for the performance of the contract between you and 22bb — specifically, the Terms & Conditions you accepted upon registration. Without processing your registration data, KYC documents, financial data, and gaming activity records, we cannot provide the services you have requested.

5.2 Legal Obligation

Certain processing activities are required by applicable law, including anti-money laundering regulations, age verification requirements, and financial record-keeping obligations. We are required to conduct these processing activities regardless of your preferences.

5.3 Legitimate Interests

We process technical and device data, and gaming activity data for fraud prevention and platform security purposes, on the basis of our legitimate interest in maintaining a secure, fair, and well-functioning platform for all players. We have assessed that these interests are not overridden by your privacy rights in this context.

5.4 Consent

Where we process your data for marketing communications or for non-essential cookies and tracking technologies, we do so on the basis of your explicit consent. You may withdraw this consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

Article 6

Data Sharing

22bb does not sell your personal data to third parties. We share your data only in the following limited circumstances:

6.1 Payment Processors

To process deposits and withdrawals, we share relevant transaction data with our licensed payment partners, including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard. Each payment partner operates under its own privacy policy and is independently responsible for the data it holds. Data shared with payment partners is limited to what is necessary to complete the specific transaction.

6.2 KYC and Verification Providers

We use accredited third-party identity verification services to assist with KYC processing. These providers receive only the documents and data necessary for verification purposes and are contractually prohibited from retaining or using your data for any other purpose.

6.3 Analytics and Technology Providers

We use third-party analytics and infrastructure providers to operate and improve the platform. These providers process technical and usage data in aggregated or pseudonymised form and are bound by data processing agreements that restrict their use of the data to the specific services they provide to 22bb.

6.4 Game Studios

Game content on the 22bb platform is provided by licensed third-party studios including Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, Spribe, and Jili. To facilitate game delivery and ensure fair play compliance, limited technical data (such as session identifiers and game round results) may be shared with these studios. No directly identifiable personal data beyond what is technically required for game delivery is shared with game studios.

6.5 Legal and Regulatory Authorities

We may disclose your personal data to law enforcement agencies, financial intelligence units, regulatory authorities, or courts where we are required to do so by applicable law, or where such disclosure is necessary to protect the rights, property, or safety of 22bb, its players, or the public. We will notify you of such disclosures where we are legally permitted to do so.

6.6 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 22bb's business, your personal data may be transferred as part of that transaction. We will take reasonable steps to ensure that any acquiring entity commits to treating your data in a manner consistent with this Privacy Policy and will notify you of any material change to data controller identity.

Article 7

Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work efficiently, remember your preferences, and provide information to site operators. 22bb uses cookies and similar tracking technologies (including local storage and session storage) to ensure the platform functions correctly and to improve your experience.

7.2 Types of Cookies We Use

• Essential cookies: These cookies are strictly necessary for the platform to function. They maintain your login session, remember your language and currency settings, and ensure platform security. Essential cookies cannot be disabled without significantly impairing your ability to use the platform.
• Performance and analytics cookies: These cookies collect information about how visitors use the platform — such as which pages are visited most often and where error messages are received. All data collected is aggregated and anonymised. We use this data to improve platform performance.
• Functionality cookies: These cookies allow the platform to remember choices you make (such as your preferred game category or table stake level) to provide a more personalised experience.
• Marketing and targeting cookies: These cookies track your browsing activity to deliver relevant promotional content. They are set only with your explicit consent and may be used to show you personalised bonus offers relevant to your gaming preferences.

7.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies, or to receive a warning before a cookie is stored. Please note that blocking essential cookies will impair the functionality of the 22bb platform and may prevent you from logging in or completing transactions. Detailed guidance on managing cookies is available in your browser's help documentation.

Article 8

Data Retention

22bb retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, and for as long as required by applicable legal and regulatory obligations. The following retention periods apply as a general guide:

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with our internal data disposal procedures. Where data cannot be immediately deleted due to ongoing legal proceedings or regulatory investigations, it will be restricted from active processing until deletion becomes possible.

Article 9

Your Rights

As a player on the 22bb platform, you have the following rights in respect of your personal data. To exercise any of these rights, contact us at [email protected] with your full name, registered email address, and a clear description of your request.

• Right of access: You have the right to request a copy of all personal data 22bb holds about you. We will respond to access requests within 30 days of receipt.
• 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. We will action rectification requests promptly.
• Right to erasure ("right to be forgotten"): You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (for consent-based processing), or where you object to processing on legitimate interest grounds. Note that we may not be able to fulfil erasure requests where retention is required by law.
• Right to restriction of processing: You may request that we restrict the processing of your data in certain circumstances — for example, while a rectification request is being assessed, or where you have objected to processing and we are considering that objection.
• Right to data portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on our legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease that processing immediately. Where you object on legitimate interest grounds, we will assess whether our interests override your rights.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

Article 10

Children & Minors

The 22bb platform is strictly for adults aged 21 and above. We do not knowingly collect personal data from any person under the age of 21. Age verification checks are applied at registration, and 22bb reserves the right to request proof of age at any point during a player's use of the platform.

If 22bb becomes aware that personal data has been collected from a person under the age of 21, that data will be deleted immediately, the associated account will be closed, and any balance held in that account will be forfeited. If you believe that a minor has registered on the 22bb platform, please notify us immediately at [email protected] so that we can investigate and take appropriate action without delay.

Parents and guardians of minors are encouraged to use parental control tools and internet filtering software to prevent underage access to gambling platforms. Resources on responsible gaming and underage access prevention are available on our Responsible Gaming page.

Article 11

Data Security

22bb implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes the following measures:

• SSL/TLS encryption: All data in transit between your device and the 22bb platform is encrypted using industry-standard SSL/TLS protocols.
• Access controls: Access to personal data within 22bb's systems is restricted to authorised personnel on a need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Secure payment handling: Payment credentials are processed exclusively by licensed payment partners operating under PCI DSS standards. 22bb does not store full card numbers or mobile wallet credentials on its own servers.
• Intrusion detection and monitoring: 22bb's infrastructure is monitored continuously for unusual activity, intrusion attempts, and anomalous patterns that may indicate a security threat.
• Incident response: In the event of a data security incident that is likely to result in a risk to your rights and freedoms, 22bb will notify you and relevant authorities without undue delay in accordance with applicable data breach notification requirements.
• Regular security reviews: Our security posture is reviewed regularly against industry best practices and updated in response to emerging threats.

While 22bb takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are advised to use a strong, unique password for your 22bb account and to enable any available two-factor authentication features. Do not share your login credentials with anyone.

Article 12

Third-Party Links

The 22bb platform may contain references to third-party services, game studios, and payment partners. This Privacy Policy applies only to data processed by 22bb in connection with the 22bb platform. It does not apply to third-party websites, applications, or services that you may access through or in connection with 22bb.

22bb does not control the privacy practices of third-party game studios, payment processors, or any other external service, and we are not responsible for their data handling. We encourage you to review the privacy policies of any third-party service you interact with directly, particularly in the context of payment transactions processed by your chosen mobile wallet or bank provider.

Article 13

Marketing Communications

22bb may send you promotional communications — including bonus offers, new game announcements, seasonal promotions tied to events like Eid, Pohela Boishakh, BPL season launches, and IPL tournament periods — where you have given explicit consent to receive such communications at the time of registration or subsequently through your account settings.

Marketing communications are sent via email to your registered address. We do not send unsolicited SMS marketing messages. The frequency and content of marketing communications are tailored where possible to your gaming preferences and activity on the platform, using the gaming activity data described in Article 3.4.

You may opt out of all marketing communications at any time by:

• Clicking the "Unsubscribe" link included at the bottom of every marketing email we send.
• Emailing [email protected] with the subject line "Marketing Opt-Out" from your registered email address.
• Updating your communication preferences through your 22bb account settings panel.

Opting out of marketing communications will not affect the delivery of transactional communications that are essential for the operation of your account, such as deposit confirmations, withdrawal notifications, KYC requests, and security alerts.

Article 14

International Data Transfers

As an internationally licensed platform, 22bb may transfer your personal data to countries outside Bangladesh in connection with the operation of the platform, including for the purposes of payment processing, KYC verification, game content delivery, and cloud infrastructure hosting. Where such transfers occur, 22bb takes appropriate steps to ensure that your data receives a level of protection consistent with this policy.

Such steps may include reliance on standard contractual clauses, binding corporate rules, or other appropriate safeguards recognised under applicable data protection frameworks. By using the 22bb platform, you acknowledge that your data may be transferred to, stored in, and processed in countries that may have different data protection standards than Bangladesh.

If you have questions about specific international transfer mechanisms applied by 22bb, please contact us at [email protected].

Article 15

Policy Changes

22bb reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When we make material changes to this policy, we will notify registered players via email to the address on file and will display a prominent notice on the platform for a reasonable period following the update.

The effective date of the current version of this policy is displayed at the top of this page. The most current version is always available at https://22bb.io/privacy-policy. Your continued use of the 22bb platform following notification of a policy update constitutes your acceptance of the revised policy. If you do not accept any update to this policy, you should cease using the platform and contact [email protected] to close your account.

Article 16

Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 22bb processes your personal data, please contact us using the details below. We are committed to responding to all data-related enquiries promptly and in good faith.

• Email: [email protected]
• Subject line for data requests: "Privacy Policy Enquiry — [nature of enquiry]"
• Response time: Within 30 minutes during peak hours; within 24 hours at all other times
• Availability: 24 hours a day, 7 days a week, including all Bangladesh public holidays
• Time zone: Bangladesh Standard Time (BST, UTC+6)

For requests to exercise your data rights (access, rectification, erasure, portability, restriction, objection), please refer to Article 9 for full instructions and the information you need to include in your request.