hlbjee Privacy Policy

1. Who We Are and How to Contact Us

hlbjee operates the online casino and sports betting platform available at hlbjee.app, serving players in Bangladesh. For all privacy-related enquiries, requests, or complaints, please contact our data team using the email address displayed in plain text at the foot of this page. We aim to respond to all privacy requests within 30 days of receipt.

2. Legal Basis for Processing Your Data

hlbjee processes your personal data on the following legal bases:

• Contract performance: Processing necessary to create and manage your account, process deposits and withdrawals, settle bets, and deliver the services you have requested.
• Legal obligation: Processing required to comply with anti-money-laundering (AML) obligations, age verification requirements, fraud prevention duties, and record-keeping requirements under applicable law.
• Legitimate interests: Processing carried out to protect the security and integrity of the Platform, prevent fraud, improve Platform performance, and conduct responsible gaming monitoring — provided such interests are not overridden by your own rights.
• Consent: Processing of your data for direct marketing communications, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

3. How We Use Your Personal Data

The personal data we collect is used for the following purposes:

• Creating, verifying, and maintaining your hlbjee account.
• Processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, and bank transfer, and reconciling transaction records.
• Verifying your age and identity as required by our responsible gaming and compliance obligations. Players must be 21 years of age or older, and we take this requirement seriously.
• Detecting, investigating, and preventing fraudulent activity, collusion, money laundering, and other prohibited conduct on the Platform.
• Administering bonuses, free bets, and promotional offers, including verifying eligibility and enforcing wagering conditions.
• Providing customer support and resolving complaints or disputes.
• Sending you transactional communications such as deposit confirmations, withdrawal notifications, and security alerts. These are not optional as they are necessary for account management.
• Sending marketing communications about hlbjee promotions, new games, or seasonal offers — only where you have provided consent or where we have a legitimate interest that is not overridden by your preferences.
• Monitoring your gameplay to identify patterns that may indicate problem gambling, and applying responsible gaming tools where appropriate.
• Improving and personalising the Platform through analysis of usage data and session behaviour.
• Complying with any lawful request from a relevant regulatory or law enforcement authority.

4. Cookies and Tracking Technologies

hlbjee uses cookies and similar technologies to operate the Platform, remember your session, and analyse usage patterns. The categories of cookies we use are:

• Essential cookies: Required for the Platform to function. They maintain your login session, remember language and currency preferences, and support security features. These cannot be disabled without breaking core functionality.
• Analytics cookies: Used to understand how visitors interact with the Platform — which pages are visited most, where sessions end, and how features are used. This data is aggregated and anonymised where possible.
• Functional cookies: Store preferences such as your last-viewed game category, display settings, and notification opt-ins so you do not need to re-enter them on each visit.
• Marketing cookies: Used where you have consented to receive personalised promotional content. These help us show you offers that are relevant to your betting and gaming history on the Platform.

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from logging in or using certain features of the Platform. We do not use third-party advertising networks that place tracking cookies for the benefit of external advertisers.

5. Sharing Your Data with Third Parties

hlbjee does not sell your personal data. We share data with third parties only in the following limited circumstances:

• Payment processors: Your financial data is shared with the payment provider you select (e.g., bKash, Nagad, Rocket) solely to process your transaction. These providers operate under their own privacy policies and are bound by confidentiality obligations.
• Identity verification providers: Where document-based age or identity verification is required, your identity documents may be shared with a specialist verification service provider under a data processing agreement.
• Game providers: Certain technical data (such as player session identifiers) may be shared with game studio partners (e.g., Pragmatic Play, Evolution Gaming, Spribe) to facilitate game delivery and resolve disputes. No directly identifiable personal data such as your name or national ID is passed to game providers.
• Legal and regulatory authorities: We will disclose personal data to law enforcement or regulatory bodies where we are legally required to do so, or where disclosure is necessary to protect the safety of individuals or the integrity of the Platform.
• Business transfers: In the event of a merger, acquisition, or transfer of the hlbjee business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

All third parties with whom hlbjee shares personal data are required to handle that data securely, use it only for the purpose for which it was shared, and comply with applicable data protection standards.

6. International Data Transfers

Some of hlbjee's technology partners and game studio providers operate servers located outside Bangladesh. Where personal data is transferred internationally, hlbjee takes steps to ensure that adequate protections are in place — including contractual safeguards equivalent to internationally recognised data protection standards. By using the Platform, you acknowledge that your data may be processed in jurisdictions outside Bangladesh, subject to these protections.

7. Data Retention

hlbjee retains personal data for as long as is necessary for the purpose for which it was collected, or as required by applicable law. The following retention guidelines apply:

• Active accounts: Personal and transactional data is retained for the lifetime of the account plus a minimum of 5 years following account closure, in compliance with anti-money-laundering record-keeping obligations.
• Identity verification documents: Retained for a minimum of 5 years from the date of verification, or longer where required by law.
• Marketing consent records: Retained for the duration of consent plus 12 months following withdrawal, to demonstrate compliance.
• Technical and log data: Generally retained for 12 months and then deleted or anonymised, unless a specific investigation requires extended retention.
• Self-excluded players: Basic identifying data for self-excluded players is retained for the duration of the exclusion period to prevent re-registration. It is not used for any other purpose during this time.

8. Security Measures

hlbjee employs a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data fields — including passwords and payment identifiers — at rest in our databases.
• Access controls that limit data visibility to personnel with a genuine operational need.
• Regular security reviews and vulnerability assessments of Platform infrastructure.
• Two-factor authentication options available to all registered account holders.

While hlbjee takes all reasonable precautions, no online platform can guarantee absolute security. You are responsible for keeping your own login credentials confidential and for notifying us promptly if you suspect any unauthorised use of your account.

9. Your Rights

As a registered user of hlbjee, you have the following rights in relation to your personal data:

• Right of access: You may request a copy of the personal data we hold about you, free of charge, within 30 days of your request.
• Right to rectification: You may ask us to correct inaccurate or incomplete personal data held in your account.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, and where no legal obligation requires us to retain it.
• Right to restrict processing: You may ask us to pause processing of your data in certain circumstances, such as while a rectification request is being resolved.
• Right to data portability: You may request a machine-readable export of the personal data you have provided to hlbjee.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that took place before withdrawal.
• Right to object: You may object to processing based on legitimate interests, including profiling for marketing purposes. We will cease such processing unless we can demonstrate compelling grounds that override your interests.

To exercise any of these rights, contact us at the email address shown at the bottom of this page. We will acknowledge your request within 5 business days and aim to resolve it within 30 days. We may ask you to verify your identity before fulfilling a data request.

10. Children and Minors

The hlbjee Platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we discover that an account has been created by or on behalf of a minor, that account will be suspended immediately, all data associated with it will be deleted, and any funds held in the account will be returned to the deposit source following identity verification. If you believe a minor has registered on the Platform, please notify us immediately at the contact address below.

11. Changes to This Privacy Policy

hlbjee may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. Where changes are material, we will notify registered users by email or via a prominent notice on the Platform before the revised policy takes effect. The date at the top of this page indicates when the policy was last updated. Continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated policy.

12. Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise a data right, or want to raise a privacy concern, please contact our data team. We will do our best to address your query promptly and fairly.

Email (plain text — not a clickable link): [email protected]

Response target: within 5 business days for acknowledgement; 30 days for full resolution. All communications are handled during Bangladesh Standard Time (BST, UTC+6) business hours.