abc1 Privacy Policy — How We Protect Your Personal Data

1Introduction

abc1 is committed to protecting the privacy and personal data of every player who uses our online betting and casino platform. This Policy applies to all data collected through the abc1 website, any mobile-optimised interface, customer support communications, and any other channel through which you interact with abc1 as a registered or prospective player.

We understand that sharing personal and financial information with any online platform requires trust. This Policy is designed to be transparent about exactly what data we hold, why we hold it, and what choices you have. We encourage you to read the full document rather than relying on the summary alone, as the full text governs our data practices in all cases.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and abc1.

2Data Controller

For the purposes of applicable data protection law, abc1 is the data controller responsible for the personal information collected through the Platform. As data controller, abc1 determines the purposes and means of processing your personal data and is accountable for ensuring that processing is lawful, fair, and transparent.

All data protection enquiries, subject access requests, and formal data complaints should be directed to our support team via the contact details set out in Section 16 of this Policy. We aim to respond to all privacy-related correspondence within 30 calendar days.

3Data We Collect

abc1 collects personal data in several categories. The table below provides a structured overview of the types of data we hold, why we hold it, and the legal basis for processing each category.

3.1 Sensitive Data

abc1 does not intentionally collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information. If you voluntarily disclose such information during a support interaction (for example, mentioning a health condition in relation to a responsible gaming request), we will treat it with the highest level of confidentiality and use it only to assist you with the specific request.

4How We Collect Data

abc1 collects personal data through the following channels:

• Direct Registration: Information you provide when creating an account, completing KYC verification, or updating your profile.
• Transactions: Data generated when you make deposits or withdrawal requests via bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, or City Bank.
• Platform Activity: Data automatically recorded as you browse, play, or bet on the Platform, collected via server logs and first-party analytics tools.
• Cookies and Similar Technologies: Session cookies, persistent cookies, and similar tracking technologies as described in Section 8.
• Customer Support: Records of all communications you initiate with the abc1 support team via live chat or email.
• Third-Party Identity Verification: Where we engage a KYC service provider to validate identity documents, that provider may return a verification result and risk score to abc1.
• Payment Providers: Confirmation data from payment processors regarding the outcome of transactions, including failure codes where relevant.

5How We Use Your Data

abc1 uses personal data collected from players for the following purposes:

• Account Management: Creating, maintaining, and securing your abc1 player account, including password resets and session management.
• Identity & Age Verification: Confirming that you meet the 21+ eligibility requirement and that the identity information you have provided is genuine, in accordance with our KYC obligations.
• Payment Processing: Executing deposits and withdrawals accurately and in compliance with anti-money-laundering requirements.
• Fraud & Risk Management: Detecting, investigating, and preventing fraudulent activity, collusion, bonus abuse, and other prohibited conduct described in our Terms & Conditions.
• Responsible Gaming: Monitoring gameplay patterns to identify indicators of problem gambling and proactively offering support tools such as deposit limits, cool-off periods, and self-exclusion where appropriate.
• Customer Support: Responding to enquiries, resolving disputes, and maintaining quality assurance records.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game offerings, interface design, and overall platform performance.
• Legal Compliance: Fulfilling obligations under applicable anti-money-laundering, counter-terrorism financing, and data retention laws.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates only to players who have opted in to receive such communications. You may opt out at any time by contacting support.

6Legal Basis for Processing

abc1 processes your personal data under one or more of the following legal bases, depending on the specific activity:

• Contractual Necessity: Processing required to fulfil the agreement between you and abc1, including account creation, KYC, and payment processing.
• Legal Obligation: Processing required to comply with anti-money-laundering regulations, age verification mandates, and data retention laws applicable to online gaming platforms.
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and internal analytics, where our interests do not override your fundamental privacy rights.
• Consent: Processing for marketing communications and optional personalisation features, where you have provided clear, informed, and freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7Sharing Your Data

abc1 does not sell your personal data. We share personal information only in the limited circumstances described below, and only to the minimum extent necessary for each purpose:

7.1 Payment Service Providers

To process deposits and withdrawals, abc1 shares relevant financial and identity data with our payment partners, including bKash, Nagad, Rocket, Upay, and banking partners such as Dutch-Bangla Bank and City Bank. These providers process your data solely to execute transactions and are contractually prohibited from using it for any other purpose.

7.2 KYC and Fraud Prevention Providers

abc1 may engage third-party identity verification and fraud detection services to assist with KYC compliance and risk management. These providers receive identity data only to perform the specific verification task and are bound by strict data processing agreements.

7.3 Game Content Providers

Licensed game studios and content providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may receive a session token and anonymised player identifier to initialise game sessions. These providers do not receive your full identity or financial data.

7.4 Legal and Regulatory Disclosure

abc1 may disclose personal data to law enforcement agencies, regulatory bodies, or judicial authorities when required to do so by law, court order, or as part of a lawful investigation into financial crime or fraud. In such cases, abc1 will disclose only the minimum data required by the relevant legal obligation.

7.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of abc1's business assets, player data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and the privacy practices of the new controller before the transfer takes effect, with at least 30 days' advance notice.

8Cookies & Tracking Technologies

abc1 uses cookies and similar first-party tracking technologies to operate the Platform effectively. We do not use third-party advertising cookies or cross-site tracking networks.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without severely impairing your ability to use abc1.
• Functional Cookies: Remember your preferences such as language settings, last-visited game category, and display options. These cookies improve your experience but are not essential.
• Analytics Cookies: First-party analytics cookies help abc1 understand how players navigate the Platform — which pages are most visited, where players encounter difficulties, and how game sessions flow. This data is aggregated and anonymised before analysis.
• Security Cookies: Used to detect unusual login patterns, simultaneous sessions from different locations, or bot-like behaviour, supporting our fraud prevention programme.

8.2 Cookie Control

You can control non-essential cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Note that disabling cookies may affect Platform functionality, particularly session management and game loading. Strictly necessary cookies are not subject to browser-level opt-out as they are required for the Platform to operate.

9Data Retention

abc1 retains personal data for as long as your account remains active and for a defined period after account closure, as set out below:

• Active Account Data: Retained for the full duration of the account relationship, subject to periodic review to remove data no longer required for active account management.
• Identity & KYC Documents: Retained for a minimum of five (5) years following account closure, in line with standard anti-money-laundering record-keeping obligations.
• Transaction Records: Retained for a minimum of five (5) years following the date of each transaction, for financial compliance and dispute resolution purposes.
• Support Communications: Retained for three (3) years following the close of each support interaction, for quality assurance and dispute resolution purposes.
• Marketing Preferences: Retained for the duration of the account relationship plus one (1) year, to maintain an accurate record of consent and opt-out history.
• Technical & Log Data: Typically retained for 90 days in identifiable form, after which it is aggregated and anonymised for long-term analytics.

Upon expiry of the applicable retention period, personal data is securely deleted from our systems or irreversibly anonymised so that it can no longer be attributed to an individual. Anonymised, aggregated data may be retained indefinitely for statistical analysis.

10Data Security

abc1 implements a layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your browser or device and the abc1 Platform is encrypted in transit using TLS 1.2 or higher.
• At-Rest Encryption: Sensitive stored data, including identity documents and payment method details, is encrypted at rest using AES-256.
• Access Controls: Internal access to personal data is granted on a strict need-to-know basis. Customer support staff can access account data only within their authorised scope. All internal access is logged and subject to periodic audit.
• Two-Factor Authentication: abc1 encourages all players to enable two-factor authentication (2FA) on their accounts. 2FA significantly reduces the risk of unauthorised access even if login credentials are compromised.
• Regular Security Audits: abc1's security infrastructure is reviewed by internal and third-party specialists on a scheduled basis to identify and remediate vulnerabilities.
• Incident Response: In the event of a data breach that poses a risk to your rights and freedoms, abc1 will notify affected players without undue delay, providing details of the nature of the breach, the data affected, and the steps taken to contain it.

11Your Privacy Rights

As a player on abc1, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected] from your registered email address with the subject line "Privacy Rights Request".

• Right of Access: You have the right to request a copy of the personal data abc1 holds about you, along with information about how it is used and with whom it is shared.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data. For minor corrections (such as a phone number update), you can make changes directly within your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent (and no other legal basis applies), or where the processing is unlawful. This right is subject to our legal obligation to retain certain data for anti-money-laundering compliance.
• Right to Restrict Processing: You may request that we limit how we use your data while a rectification or objection request is being resolved.
• Right to Data Portability: You may request a structured, machine-readable export of the personal data you have directly provided to abc1, where processing is based on consent or contractual necessity.
• Right to Object: You may object to processing based on legitimate interests — including profiling for responsible gaming monitoring — where your individual circumstances outweigh our legitimate interest. You may also object to direct marketing at any time, unconditionally.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

abc1 will respond to all valid privacy rights requests within 30 calendar days. In complex cases, this period may be extended by a further 60 days, in which case we will notify you of the extension and the reason for it within the initial 30-day window.

12Children & Minors

abc1 does not knowingly collect personal data from any person under the age of 21. Our platform is strictly intended for adult players aged 21 and above. Age verification is a mandatory step in the registration process, and we actively monitor for indicators of underage use.

If abc1 discovers or is notified that personal data has been collected from a person under 21 without the intent to verify their actual age, we will immediately close the associated account, delete the collected data, and return any deposited funds to the original payment source. Parents or guardians who believe their child may have registered on abc1 should contact us immediately at [email protected].

13Third-Party Links

The abc1 Platform does not include outbound links to third-party websites for advertising or general browsing purposes. However, in limited contexts — such as game provider loading screens or payment gateway redirects — you may briefly interact with a third-party interface.

abc1 is not responsible for the privacy practices of third-party providers whose interfaces you interact with as part of the payment or game-loading flow. We recommend reviewing the privacy notices of those providers independently. Our payment partners and game content providers are selected in part based on their own data protection standards, and all are subject to contractual data processing obligations when handling data on our behalf.

14International Data Transfers

abc1 primarily stores and processes player data on servers located in regions with appropriate data protection standards. Where it is necessary to transfer personal data to a third-party service provider located in a different jurisdiction — for example, a global KYC verification provider or a game content platform — abc1 ensures that appropriate safeguards are in place before any such transfer occurs.

Safeguards for international transfers may include: contractual clauses that require the recipient to apply equivalent data protection standards to those we observe; certification under recognised international privacy frameworks; or the recipient being located in a jurisdiction that the relevant authorities have deemed to provide an adequate level of data protection.

You may request information about the specific safeguards governing any international transfer of your personal data by writing to [email protected] with the subject line "International Transfer Enquiry".

15Policy Amendments

abc1 reserves the right to update this Privacy Policy at any time. Where changes are material — meaning they significantly affect how we collect, use, or share your personal data, or alter your privacy rights — we will provide at least 7 days' advance notice by email to your registered address and through a notice on the Platform prior to the change taking effect.

Non-material changes (such as typographical corrections or structural reorganisation that does not alter the substance of any provision) may take effect immediately and without specific notification. The "Last Updated" date at the top of this document always reflects the most recent revision.

Your continued use of the abc1 Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not accept the revised Policy, you should cease using the Platform and may request account closure via our support team.

16Contact & Data Requests

For any question, concern, or formal request related to this Privacy Policy or the personal data abc1 holds about you, please contact our data protection team using the details below. All correspondence must be sent from your registered email address to enable us to verify your identity before processing any request.

Support & Data Protection Email: [email protected]

Subject Line for Data Requests: Use "Data Protection Request" for access, rectification, erasure, or portability requests; "Privacy Rights Request" for objections or consent withdrawal; or "Formal Complaint" for escalated privacy complaints.

Response Times: General privacy queries — within 5 business days. Subject access requests and rights requests — within 30 calendar days. Formal complaints — acknowledged within 24 hours, resolved within 10 business days.