Privacy Policy — How tkbt Safeguards Your Personal Data

tkbt collects personal data in the following categories. The specific data points collected may vary depending on the features you use and the actions you take on the platform.

1.1 Registration and Account Data

When you create a tkbt account, we collect the information you provide during the registration process, including:

• Full legal name as it appears on your government-issued identity document.
• Date of birth, for the purpose of age verification (players must be 21 years or older).
• Residential address, including city (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi) and postal code.
• Mobile phone number and email address, used for account communications and two-factor authentication.
• Username and encrypted password credentials.
• National ID (NID) number or passport number, collected as part of KYC identity verification.

1.2 Financial and Transaction Data

To facilitate deposits and withdrawals, tkbt collects financial information including:

• bKash mobile wallet number, Nagad account number, Rocket account number, or Upay account number registered in your name.
• Bank account details (account number, bank name, branch) where bank transfer is the chosen payment method, including Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank.
• Visa or Mastercard card details (card number, expiry date, cardholder name) — stored in tokenised form only; full card numbers are never stored on tkbt servers.
• Full transaction history, including deposit amounts, withdrawal requests, bet amounts, game results, and bonus credits, denominated in Bangladeshi Taka (BDT).
• Source of funds documentation where requested as part of enhanced KYC or AML checks.

1.3 Identity Verification (KYC) Documents

As part of our KYC programme, we collect scanned copies or photographs of identity documents such as your National ID card, passport, or driving licence, as well as proof-of-address documents. These documents are stored securely and handled in accordance with Section 8 of this Policy.

1.4 Usage and Technical Data

When you use the tkbt platform, we automatically collect certain technical and behavioural data, including:

• IP address, device type, operating system, and browser version.
• Pages visited, time spent on each page, and clickstream data.
• Game session data including games played, bets placed, game duration, and win/loss outcomes.
• Login timestamps and session duration.
• Geolocation data (country and region level) derived from your IP address.

1.5 Communications Data

If you contact tkbt support via email, live chat, or any other channel, we retain records of those communications, including your messages, our responses, and any attachments you submit. This data is used to resolve your queries and improve our support quality.

tkbt collects personal data through the following means:

• Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal, place a bet, contact support, or participate in a promotion.
• Automatically: Through cookies, session tracking technologies, and server-side logging when you interact with the tkbt website or mobile interface. See Section 7 for full details on cookies.
• From payment processors: When you initiate a payment via bKash, Nagad, Rocket, Upay, or a Bangladeshi bank, our payment processing partners provide transaction confirmation data necessary to credit your account.
• From identity verification services: Where tkbt uses a third-party identity verification provider to assist with KYC processing, that provider may share the results of document verification checks with us.
• From fraud detection services: Our fraud and risk management systems may receive data signals from third-party fraud detection providers to help identify and prevent account abuse.

tkbt uses the personal data it collects for the following specific purposes:

tkbt does not use your personal data for automated profiling that produces legal or similarly significant effects on your account, except where this is necessary to prevent fraud or comply with anti-money laundering obligations. Where automated decision-making is used for fraud detection, you retain the right to request human review of any decision that adversely affects your account.

tkbt processes personal data on the following legal bases:

• Contractual necessity: The majority of data processing described in this Policy is necessary to perform the contract between tkbt and you — namely, to operate your account, process your bets, and facilitate payments. Without this processing, tkbt could not provide its services to you.
• Legal obligation: Certain processing activities — including KYC identity verification, transaction record-keeping, and anti-money laundering monitoring — are required by applicable laws and regulations. tkbt processes this data to comply with these obligations regardless of your consent.
• Legitimate interests: tkbt processes certain data — such as usage analytics, fraud detection signals, and platform security monitoring — on the basis of its legitimate interest in operating a secure, fair, and commercially viable platform. We conduct a balancing test to ensure these legitimate interests do not override your rights and freedoms.
• Consent: Where tkbt sends you marketing communications, personalised promotions, or non-essential cookies, it does so on the basis of your explicit consent. You may withdraw this consent at any time by contacting [email protected] or updating your account communication preferences.

tkbt does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances:

• Payment processors: We share the minimum necessary financial data with payment partners — including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — to process your deposits and withdrawals. These providers act as independent data controllers for their own transaction records and are bound by their own privacy policies.
• Game providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised session identifiers and bet data necessary to deliver game content and calculate outcomes. These providers do not receive your full identity or financial details.
• Identity verification providers: Where a third-party KYC or age verification service is used to process your submitted documents, that provider receives the relevant document images and personal data solely for the purpose of identity verification.
• Fraud prevention and risk management services: We may share device fingerprint data, IP addresses, and transaction patterns with fraud detection service providers to identify and prevent account abuse and money laundering.
• Legal and regulatory authorities: tkbt will disclose personal data to law enforcement agencies, financial intelligence units, or regulatory bodies where required to do so by law, court order, or regulatory directive. We will notify you of such disclosures where legally permitted to do so.
• Corporate transactions: In the event of a merger, acquisition, sale of assets, or restructuring of the tkbt business, personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any changes to the privacy arrangements applicable to your data.

All third parties with whom tkbt shares personal data are required to handle that data in accordance with applicable data protection standards and are prohibited from using it for any purpose other than that for which it was shared.

tkbt retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to the following minimum retention periods required by applicable law and sound operational practice:

• Account and registration data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of the last transaction on the account, or as required by applicable financial compliance regulations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction. This includes deposit records, withdrawal records, bet history, and bonus transaction logs.
• Game session data: Retained for a minimum of three (3) years to support dispute resolution, responsible gaming monitoring, and game integrity investigations.
• Customer support communications: Retained for a minimum of two (2) years from the date of each interaction, or longer where the communication relates to an ongoing dispute or compliance matter.
• Technical and usage data (logs): Retained for up to twelve (12) months from the date of collection, after which they are automatically purged or anonymised.
• Marketing consent records: Retained for the duration of the consent and for a period of two (2) years following withdrawal of consent, as evidence that consent was properly obtained.

At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Where anonymisation is used rather than deletion, the resulting anonymised data may be retained indefinitely for analytical purposes.

tkbt uses cookies and similar tracking technologies on the platform to enhance your user experience, maintain your session, and gather analytical data. This section describes the types of cookies we use and how you can manage your cookie preferences.

7.1 Types of Cookies Used

• Strictly necessary cookies: These cookies are essential for the platform to function. They enable core features such as account login sessions, security tokens, and basket/bet-slip state. The platform cannot function without these cookies and they cannot be disabled.
• Performance and analytics cookies: These cookies collect anonymised information about how users interact with the platform — such as which pages are most visited, how long sessions last, and which features are used most frequently. This data helps tkbt improve platform performance and usability.
• Functional cookies: These cookies remember your preferences such as language settings, display preferences, and previously used payment methods to provide a more personalised experience on subsequent visits.
• Marketing and targeting cookies: With your consent, tkbt may use cookies to understand your interests and deliver relevant promotional content. These cookies may also be used by our promotional partners to track conversions. You may opt out of marketing cookies at any time.

7.2 Managing Your Cookie Preferences

You can control cookies through your browser settings. Most modern browsers allow you to block, delete, or be notified when cookies are set. Please note that disabling strictly necessary cookies will impair the functionality of the tkbt platform and may prevent you from accessing your account or placing bets. To manage cookies, access the settings or preferences panel of your browser (Chrome, Firefox, Safari, Edge, or other) and navigate to the privacy or security section.

7.3 Third-Party Cookies

Third-party game providers integrated into the tkbt platform may set their own cookies when you load a game. These cookies are governed by the respective provider's privacy policy. tkbt does not control third-party cookies and is not responsible for the data practices of third-party game studios.

tkbt employs a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and tkbt servers is encrypted using current-generation TLS protocols. The padlock symbol and "https://" prefix in your browser address bar confirm that your connection is encrypted.
• Data-at-rest encryption: Personal data stored on tkbt servers is encrypted at rest using AES-256 encryption. Encryption keys are stored separately from the data they protect and are rotated regularly.
• Access controls: Access to systems containing personal data is restricted to authorised personnel only. Access is granted on a minimum-necessary basis and is reviewed regularly. Multi-factor authentication is required for all administrative access.
• Password security: User passwords are stored using industry-standard one-way cryptographic hashing with individual salts. Plain-text passwords are never stored or transmitted.
• Fraud monitoring systems: Real-time fraud detection systems monitor all transactions and login events for signs of suspicious activity, including credential stuffing, account takeover attempts, and unusual transaction patterns.
• Penetration testing: The tkbt platform is subject to periodic security assessments and penetration testing by qualified security professionals to identify and remediate vulnerabilities before they can be exploited.
• Employee training: All tkbt staff with access to personal data receive regular data protection and information security training. Confidentiality obligations are embedded in all staff employment contracts.

Despite these measures, no internet-based platform can guarantee absolute security against all threats. In the event of a data breach that poses a risk to your rights and freedoms, tkbt will notify affected users and relevant authorities in accordance with applicable data breach notification requirements as promptly as practicable.

You play an important role in keeping your account secure. You must maintain the confidentiality of your login credentials and must not share them with any third party. If you believe your account has been compromised, contact [email protected] immediately so that we can take protective action.

As a registered user of the tkbt platform, you hold the following rights in relation to your personal data. tkbt is committed to facilitating these rights promptly and without undue burden on you.

• Right of access: You may request a copy of all personal data tkbt holds about you. We will provide this in a structured, commonly used format within 30 days of receiving a verified request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. Minor corrections (such as a misspelled name) can be addressed by contacting support. Changes to identity-linked data (such as your NID number or date of birth) require supporting documentation.
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you object to processing and there is no overriding legitimate basis. Note that this right is subject to our legal obligations to retain certain data under anti-money laundering and financial record-keeping laws, which take precedence.
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances — for example, while you contest the accuracy of data we hold, or while we assess an objection you have raised.
• Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that we provide your data in a machine-readable format, or that we transmit it directly to another controller where technically feasible.
• Right to object: You may object at any time to processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, though tkbt may continue processing where it can demonstrate compelling legitimate grounds that override your rights.
• Right to withdraw consent: Where processing is based on your consent (for example, marketing communications or non-essential cookies), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Rights Request" and include your registered username or account reference number. We will verify your identity before processing any data rights request. tkbt will respond within 30 days of receiving a complete and verified request. In complex cases, this period may be extended by an additional 30 days, and you will be notified if this extension is required.

The tkbt platform integrates with a range of third-party service providers to deliver core platform functionality. While tkbt carefully selects its partners and applies contractual data protection obligations to them, each third-party provider operates under its own privacy policy. tkbt is not responsible for the data practices of third parties beyond the scope of the data processing agreements in place between tkbt and those providers.

Third-party service categories currently integrated into the tkbt platform include:

• Game studios: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi deliver certified game content to the platform. Game session data is processed within the secure environment of each studio's certified game server.
• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard process financial transactions. Each payment provider is an independent data controller for its own transaction and customer data.
• Identity verification services: Third-party KYC providers assist tkbt in verifying the identity and age of new players. Document images submitted for KYC are processed by these providers in accordance with their own security standards.
• Customer support platform: Our support team may use a third-party helpdesk or live chat platform to manage customer communications. Communications data processed through such tools is subject to data processing agreements between tkbt and the relevant provider.

The tkbt website does not contain hyperlinks to external third-party websites. However, if you navigate to any third-party website independently, please review that website's privacy policy, as tkbt has no control over and accepts no responsibility for the content, security, or data practices of any external site.

The tkbt platform is strictly intended for adults aged 21 years and above. tkbt does not knowingly collect, process, or retain personal data from any individual under the age of 21. Age verification is a mandatory step in the account registration process, and access to the platform is denied to any applicant who cannot demonstrate that they meet the minimum age requirement.

As part of our KYC programme, tkbt requires all new players to submit a valid government-issued identity document — such as a Bangladesh National ID card, passport, or driving licence — that confirms their date of birth. Accounts are subject to suspension and permanent closure if identity verification reveals that the account holder is under 21 years of age at the time of registration or at any subsequent point.

Any funds deposited by a player who is subsequently found to be under the age of 21 will be returned via the original payment method, less any amounts that cannot be recovered due to irreversible transaction processing. tkbt will not retain any net winnings generated by an underage player and reserves the right to report underage gambling activity to the relevant authorities where required to do so by law.

If you have reason to believe that a minor has accessed or registered an account on the tkbt platform, please contact our support team immediately at [email protected]. tkbt takes underage access seriously and will investigate all such reports promptly.

Parents and guardians who are concerned about minors accessing online gambling content are encouraged to use parental control software tools that can restrict access to gambling websites. tkbt recommends reputable parental control solutions available for desktop and mobile devices to help protect minors in shared household environments.

tkbt reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, the services we offer, applicable laws and regulations, or best-practice standards in data protection. The version date displayed at the top of this document will be updated whenever a change is made.

Where a proposed change is material — meaning it significantly affects how we collect, use, or share your personal data, or materially alters your rights — tkbt will provide advance notice of the change by:

• Displaying a prominent notification on the tkbt platform for a period of at least 14 days before the change takes effect; and/or
• Sending a notification to your registered email address or mobile number at least 14 days before the effective date of the change.

Your continued use of the tkbt platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should cease using the platform and may request account closure by contacting [email protected].

Non-material changes — such as corrections to typographical errors, clarifications of existing practices that do not alter the substance of the Policy, or updated contact details — may be made without advance notice. In all cases the current, authoritative version of this Policy is the version published on the tkbt website at the time of your access.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way in which tkbt handles your personal data, please contact our dedicated data support team using the details below. All correspondence must be submitted in English.

Email: [email protected]

Subject line for data rights requests: "Data Rights Request — [your username or account reference]"

Support Hours: 24 hours a day, 7 days a week, including public holidays observed in Bangladesh such as Eid, Victory Day (16 December), Independence Day (26 March), and Pohela Boishakh.

Response Time: General privacy queries are typically acknowledged within 24 hours and resolved within 7 business days. Formal data rights requests (access, erasure, portability, objection) are acknowledged within 48 hours and resolved within 30 calendar days of receipt of a verified, complete request. Complex requests may be extended by a further 30 days with prior notification to you.

When submitting a data rights request, please include your registered username or account reference number, a clear description of the right you wish to exercise, and sufficient information to verify your identity. tkbt will not act on data rights requests that cannot be authenticated, as this protects against unauthorised access to or deletion of your data by third parties.