hlbaee Privacy Policy

When you create an account on hlbaee, we collect the following personal information:

• Full legal name
• Date of birth (to verify you are aged 21 or above)
• Residential address, including city and district within Bangladesh
• Mobile phone number
• Email address
• Preferred language and currency (Bangladeshi Taka / ৳ / BDT)

This information is required to open and maintain your account. Without it, we are unable to provide our services.

To comply with our Know Your Customer (KYC) obligations and to process withdrawal requests, hlbaee may request one or more of the following identity documents:

• National Identity Card (NID)
• Passport (bio page)
• Driver's licence
• Utility bill or bank statement confirming residential address (dated within 90 days)
• Screenshot or confirmation of the payment method (bKash, Nagad, Rocket, or Upay) registered in your name

Document images submitted for KYC purposes are stored securely and are accessible only by our compliance team. They are not shared with third parties except where required by law.

Each time you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, or any other supported payment method, hlbaee records the following transaction data:

• Transaction reference number and timestamp
• Amount in Bangladeshi Taka (৳)
• Payment method used and the registered mobile wallet number
• Transaction status (pending, completed, failed, reversed)

Transaction records are retained for a minimum of five years in accordance with standard financial record-keeping requirements.

When you access the hlbaee platform, our servers automatically record certain technical information, including:

• IP address and approximate geographic location
• Device type, operating system, and browser version
• Pages visited, time spent on each page, and navigation path
• Session duration and login timestamps
• Referring URL (the link or search result that directed you to hlbaee)

This technical data is used for platform security, fraud prevention, and to improve the overall user experience. It is not used to build personal marketing profiles.

hlbaee uses cookies and browser local storage to maintain your login session, remember your preferences, and measure platform performance. The categories of cookies we use are:

• Essential cookies — required for the platform to function; cannot be disabled.
• Analytics cookies — help us understand aggregate usage patterns to improve the platform.
• Preference cookies — store your language and display settings between sessions.

We do not use third-party advertising or retargeting cookies. You may clear cookies via your browser settings at any time, though doing so may affect your session experience.

hlbaee may send you promotional messages about current offers, seasonal bonuses (for example, around Eid, Pohela Boishakh, or Bangladesh Premier League season), and platform updates via SMS or email — but only if you have actively opted in to receive such communications. You may opt out at any time by contacting support at [email protected] or by following the unsubscribe instructions in any marketing message.

hlbaee works with a small number of carefully selected third-party service providers who assist us in delivering our platform. These providers may process certain personal data on our behalf, strictly under written data processing agreements that prohibit them from using your data for their own purposes. Categories of providers include:

• Payment processing partners (bKash, Nagad, Rocket, Upay gateway operators)
• Identity verification and KYC solution providers
• Game content suppliers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi)
• Cloud hosting and infrastructure providers
• Fraud detection and cybersecurity vendors

hlbaee may disclose personal data to law enforcement agencies, regulatory authorities, or other competent bodies where we are legally required to do so, or where we reasonably believe disclosure is necessary to prevent fraud, money laundering, or harm to our players or the public. In such cases, we will disclose only the minimum data required to satisfy the lawful request.

hlbaee does not sell, rent, exchange, or otherwise commercially transfer your personal data to any third party for their own marketing or commercial purposes. This commitment applies without exception to all categories of personal data collected by hlbaee.

hlbaee retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. General retention periods are as follows:

• Active account data — retained for the lifetime of the account plus 5 years after closure.
• Transaction records — retained for a minimum of 5 years from the date of each transaction.
• KYC and identity documents — retained for 5 years after account closure or last transaction, whichever is later.
• Technical and usage logs — retained for up to 12 months then anonymised or deleted.
• Support correspondence — retained for 3 years from the date of the last communication.

After the applicable retention period expires, data is securely deleted or permanently anonymised so that it can no longer be linked to any individual.

You have the right to request a copy of all personal data hlbaee holds about you. Upon receiving a valid access request, we will provide a structured summary of your data within 30 days. This summary will include the categories of data held, the purposes for which it is processed, and any third parties with whom it has been shared.

If any personal data we hold about you is inaccurate or out of date, you have the right to request that it be corrected without undue delay. You may update certain account details directly within your account settings; for changes to core identity data, please contact support with appropriate supporting documentation.

In certain circumstances, you may request that hlbaee delete your personal data. We will honour erasure requests where the data is no longer necessary for the purposes for which it was collected and where no overriding legal obligation requires us to retain it. Please note that active accounts with outstanding balances or open wagering requirements cannot be fully erased until those obligations are resolved.

Where hlbaee processes your data on the basis of your consent (for example, for 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 prior to the withdrawal. To withdraw consent, email [email protected] with the subject line "Withdraw Marketing Consent".

hlbaee implements industry-standard technical measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• Encryption of sensitive data fields (passwords, payment details) at rest in our databases
• Multi-factor authentication options for account login
• Automated intrusion detection and 24/7 security monitoring
• Regular penetration testing and security audits by independent specialists
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis

In the event of a personal data breach that poses a risk to your rights and freedoms, hlbaee will notify affected account holders within 72 hours of becoming aware of the breach, where technically feasible. The notification will describe the nature of the breach, the categories of data affected, the likely consequences, and the steps we are taking to mitigate harm. You are encouraged to change your password immediately and contact support if you notice any suspicious activity on your account.

hlbaee reserves the right to update this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered account holders by email or via an in-platform notification. We encourage you to review this Policy periodically to stay informed about how we are protecting your information. Your continued use of the hlbaee platform after any update constitutes your acceptance of the revised Policy.