db234 Privacy Policy — Your Data, Your Rights

1. Introduction

db234 ("we", "us", "our") operates the online gaming platform at https://db234.org (the "Platform"). We are committed to protecting the privacy and personal data of all users ("you", "your") who access or use the Platform. This Privacy Policy explains the categories of personal data we collect, the purposes for which that data is processed, the parties with whom it may be shared, and the rights available to you in respect of your personal data.

This Privacy Policy forms part of the db234 Terms and Conditions, which are incorporated herein by reference. By registering on or using the Platform, you confirm 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 consent to this Privacy Policy, you must not use the Platform.

2. Personal Data We Collect

We collect personal data that you provide to us directly during the registration and account management process, as well as data that is generated automatically through your use of the Platform. The categories of personal data we collect include:

• Identity data: full name, date of birth, nationality, gender and national identity card or passport number as submitted during KYC verification.
• Contact data: registered mobile number, email address (where provided) and residential address as submitted for account registration or KYC.
• Financial data: deposit and withdrawal history, transaction amounts, payment method identifiers (for example the bKash or Nagad account number linked to your db234 account) and account balance records. Full payment credentials such as card numbers are not stored by db234 — they are processed directly by the relevant payment gateway.
• Gaming activity data: game history, bet amounts, win/loss records, session duration, bonus usage and responsible gaming tool settings.
• Technical and device data: IP address, device type, operating system, browser type and version, time zone, referring URL and pages visited on the Platform.

We may also collect data from third parties in the following circumstances:

• Identity verification agencies that we use to confirm the authenticity of KYC documents submitted during registration.
• Fraud prevention and anti-money laundering screening databases, which may flag account activity as requiring enhanced due diligence.
• Payment processors such as bKash, Nagad and Rocket, which may provide transaction confirmation data to reconcile your account balance records.

3. How We Use Your Personal Data

db234 processes your personal data only for specific, legitimate purposes. We do not process personal data in ways that are incompatible with the purposes described in this Privacy Policy. The primary purposes for which we process your data are:

• Account management: to create, verify and maintain your db234 account, process your registrations, authenticate your logins and manage your account settings and preferences.
• Payment processing: to process deposits and withdrawals via bKash, Nagad, Rocket and other supported Bangladesh payment methods, reconcile transaction records and prevent payment fraud.
• Legal compliance: to fulfil KYC obligations, conduct age verification to enforce the 21+ eligibility requirement, carry out anti-money laundering screening and comply with any applicable legal obligations.
• Platform improvement: to analyse aggregated and anonymised usage patterns to improve the performance, stability and user experience of the Platform, including game loading times, navigation flows and feature usability.
• Responsible gaming: to monitor account activity for indicators of problem gambling behaviour and to administer the responsible gaming tools you have activated, including deposit limits, session reminders and self-exclusion periods.
• Customer support: to respond to your enquiries, resolve disputes, process complaints and provide technical assistance through db234's 24/7 support team.

4. Legal Basis for Processing

db234 processes your personal data on the following legal grounds, depending on the specific processing activity:

• Contractual necessity: processing required to perform the services described in the Terms and Conditions — including account creation, payment processing and game delivery — is carried out because it is necessary for db234 to fulfil its contractual obligations to you.
• Legal obligation: processing required for KYC verification, age verification, anti-money laundering compliance and responses to lawful regulatory or law enforcement requests is carried out to fulfil db234's legal obligations.
• Legitimate interests: processing for fraud prevention, responsible gaming monitoring, platform security and aggregated analytics is carried out on the basis of db234's legitimate interest in operating a safe, fair and reliable platform.
• Consent: where processing is based on your consent — for example, receiving promotional communications — you may withdraw that consent at any time by contacting support, without affecting the lawfulness of processing carried out before your withdrawal.

5. Sharing Your Personal Data

db234 does not sell, rent or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances, and only to the extent necessary for the stated purpose:

• Service providers: third-party vendors who provide services on our behalf — including payment processors (bKash, Nagad, Rocket), KYC and identity verification providers, game technology providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) and customer support platform providers. These vendors are contractually bound to process your data only on db234's instructions and in accordance with this Privacy Policy.
• Legal and regulatory authorities: where we are required by law, court order, regulatory requirement or law enforcement request to disclose personal data, we will do so to the extent required and will endeavour to notify you where legally permissible.
• Fraud and crime prevention: where we have reasonable grounds to suspect fraudulent activity, money laundering or other criminal conduct, we may share relevant data with fraud prevention agencies or law enforcement authorities.
• Business transfers: in the event that db234 undergoes a merger, acquisition or sale of all or part of its business, your personal data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections remaining in place.

db234 does not transfer your personal data outside of the jurisdictions in which our service providers are contractually required to maintain equivalent data protection standards. Where data is processed by providers outside Bangladesh, we ensure that appropriate data transfer safeguards are in place.

6. Payment Data and Financial Information

db234 takes the security of financial data with the utmost seriousness. All deposit and withdrawal transactions on the Platform are processed via the secure APIs of certified payment partners including bKash, Nagad, Rocket and Upay, as well as major Bangladesh bank transfer networks. db234 does not at any point handle, store or have visibility of your full mobile banking PIN, banking password or card CVV number. Transaction records maintained by db234 include only the transaction reference, amount, date, payment method type and the partial identifier of the payment account used (for example, the last four digits of an account number).

All financial records maintained by db234 are subject to strict access controls. Only authorised db234 personnel with a legitimate operational need are permitted to view financial transaction records, and all such access is logged and audited. Financial data is retained for the period required by applicable anti-money laundering and financial record-keeping obligations, after which it is securely deleted or anonymised.

7. Data Retention

db234 retains your personal data only for as long as it is necessary for the purposes for which it was collected or as required by applicable law. The standard retention periods applied by db234 are as follows: account data (identity, contact and gaming activity data) is retained for the duration of your account and for a period of five years following account closure; financial transaction records are retained for a minimum of seven years in accordance with applicable financial compliance requirements; KYC documents are retained for the period required by applicable anti-money laundering regulations following the completion of the verification process.

Where personal data is no longer required for the purposes for which it was collected and no legal retention obligation requires its continued storage, db234 will securely delete or irreversibly anonymise that data so that it can no longer be associated with any individual. You may request information about the retention periods applicable to specific categories of your data by contacting [email protected].

8. Cookies and Tracking Technologies

db234 uses cookies and similar tracking technologies on the Platform to ensure the site functions correctly, to remember your session and preferences, and to collect anonymised analytics data that helps us improve the Platform. A cookie is a small text file placed on your device by the Platform when you visit. Cookies do not contain your personal login credentials and cannot be used to execute transactions on your account.

• Essential cookies: required for the Platform to function. These include session cookies that keep you logged in during a visit and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Functional cookies: used to remember your preferences such as language selection and responsible gaming settings so you do not need to re-enter them on every visit.
• Analytics cookies: used to collect anonymised, aggregated data about how users interact with the Platform — for example, which pages are visited most frequently and where users encounter errors. This data is used solely to improve the Platform and is never linked back to individual user accounts.

Most mobile browsers allow you to control cookie settings through the browser's privacy or settings menu. Disabling essential cookies may impair your ability to use certain features of the Platform, including account login and payment processing. db234 does not currently use third-party advertising or retargeting cookies.

9. Your Data Rights

You have the following rights in respect of your personal data held by db234. To exercise any of these rights, please contact [email protected] with your registered mobile number and a description of the right you wish to exercise. db234 will respond to all valid requests within a reasonable timeframe:

• Right of access: you may request a copy of the personal data db234 holds about you and information about how that data is being processed.
• Right of rectification: if any personal data db234 holds about you is inaccurate or incomplete, you may request that it be corrected or completed.
• Right of erasure: in certain circumstances you may request that db234 delete the personal data it holds about you. This right is subject to db234's legal retention obligations — for example, transaction records required to be retained under applicable anti-money laundering rules cannot be deleted on request.
• Right to restrict processing: you may request that db234 restrict the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of data is being resolved.
• 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 carried out before withdrawal.

db234 will not charge a fee for responding to data rights requests unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply. db234 may request additional information from you to verify your identity before processing a data rights request.

10. Data Security

db234 implements industry-standard 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 on all data transmissions between your device and db234's servers; one-way cryptographic hashing of account passwords so that plaintext passwords are never stored; strict role-based access controls limiting data access to db234 personnel with a demonstrated operational need; regular internal security reviews and vulnerability assessments of the Platform; and secure physical and logical controls on the servers and infrastructure that host your data.

While db234 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the security of your own device and account credentials. If you suspect that your account has been compromised, please contact db234 support immediately at [email protected] so that protective action can be taken without delay.

11. Minors and Age Verification

db234 strictly prohibits the use of the Platform by individuals under the age of 21. We do not knowingly collect personal data from anyone under 21. During the registration process, db234 collects date of birth information and conducts KYC age verification checks to enforce this restriction. If db234 discovers that an account has been registered by a person under 21 — whether through automated checks, document review or any other means — the account will be permanently closed, any balance forfeited and any personal data collected in relation to that account deleted in accordance with our legal obligations. If you believe that a minor may have registered on db234, please notify us immediately at [email protected].

12. Changes to This Privacy Policy

db234 reserves the right to update or amend this Privacy Policy at any time. When we make material changes to this Privacy Policy, we will update the "Last updated" date at the top of this page and, where the changes are significant, endeavour to provide notice to registered users via their registered mobile number or a prominent notice on the Platform. The most current version of this Privacy Policy is always available at https://db234.org/privacy-policy.

Your continued use of the db234 Platform following the posting of any changes to this Privacy Policy constitutes your acceptance of the revised Privacy Policy. If you do not agree with any revised Privacy Policy, you must stop using the Platform and may request account closure by contacting db234 support.

13. Contact and Data Enquiries

If you have questions, concerns or requests relating to this Privacy Policy or the processing of your personal data by db234, please contact our support team. All privacy-related enquiries are handled with full confidentiality by db234's data handling team.

Contact email: [email protected]. Please include your registered mobile number and specify that your message concerns a privacy or data protection matter so our team can route it to the appropriate handler promptly. db234 aims to respond to all privacy enquiries within 2 business days.