hbajl Privacy Policy

1 Who We Are

hbajl ("we", "us", "our") operates the online casino and sports betting platform accessible at hbajl.io (the "Platform"). For the purposes of this Privacy Policy, hbajl acts as the data controller — meaning we determine the purposes and means by which your personal data is processed.

Our support team operates on Bangladesh Standard Time (BST, UTC+6) and communicates exclusively in English. Any privacy-related requests, corrections, or objections should be directed to our support team at the contact details provided in Section 13 of this policy.

This Privacy Policy applies to all personal data collected through the Platform, including data submitted during account registration, data generated through your gameplay and betting activity, and data collected automatically through your browser or device when you visit hbajl.io.

2 Data We Collect

hbajl collects personal data in three main ways: information you provide directly, information generated through your use of the Platform, and information collected automatically by our systems. The following table summarises the categories of data we collect and the context in which each category arises.

We do not collect sensitive special-category data such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data, except where a government-issued ID submitted for age verification incidentally contains such information — in which case it is used solely for identity verification and not processed for any other purpose.

3 How We Use Your Data

hbajl uses the personal data we collect for the following specific purposes:

• Account creation and management: To register your account, verify your identity, maintain your profile, and provide you with access to all Platform features.
• Payment processing: To process deposits and withdrawals in Bangladeshi Taka (৳ BDT) via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate transaction records.
• Anti-money-laundering (AML) and fraud prevention: To monitor account activity for signs of fraud, money laundering, or other financial crime, and to comply with applicable AML obligations.
• Identity and age verification: To confirm that you are at least 21 years of age and that the identity you have registered matches the payment methods used on your account.
• Customer support: To respond to your enquiries, resolve disputes, investigate complaints, and maintain a record of support interactions.
• Bonus and promotion management: To administer promotional offers, verify eligibility, track wagering requirements, and prevent bonus abuse.
• Platform improvement: To analyse usage patterns, identify technical issues, improve game performance, and develop new features based on how players interact with the Platform.
• Responsible gaming compliance: To apply deposit limits, session restrictions, self-exclusion settings, and other responsible gaming tools you have activated on your account.
• Marketing communications: To send you relevant promotional offers and updates about hbajl by email, where you have consented to receive such communications. You may withdraw this consent at any time by contacting [email protected].
• Legal and regulatory compliance: To comply with any applicable legal obligation, court order, or regulatory requirement to which hbajl is subject.

4 Legal Bases for Processing

hbajl processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to deliver the services you have signed up for — including account management, payment processing, and game delivery — is conducted on the basis that it is necessary to perform our contract with you.
• Legal obligation: Processing required to comply with AML regulations, age verification obligations, and any applicable legal or regulatory requirement is conducted on the basis of legal obligation.
• Legitimate interests: Processing for fraud prevention, platform security monitoring, analytics, and abuse detection is conducted on the basis of our legitimate interests as a platform operator, balanced against your privacy interests.
• Consent: Processing for direct marketing communications is conducted solely on the basis of your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Sharing Your Data

hbajl does not sell, rent, or trade your personal data to any third party for commercial purposes. We share data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment service providers: bKash, Nagad, Rocket, Upay, and card processing networks (Visa, Mastercard) receive the financial and identity data necessary to process your deposits and withdrawals securely.
• Identity verification partners: Third-party KYC (Know Your Customer) services receive identity documents submitted during account verification to confirm your identity and age. These partners are contractually bound to use your data only for verification purposes.
• Fraud prevention services: Automated fraud-detection systems may receive technical and transaction data to flag anomalous activity. No human at a fraud-prevention partner has access to your full profile without a specific investigation trigger.
• Game content providers: When you play a game provided by a third-party studio (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi), your gameplay session data is transmitted to that provider's game servers. These providers operate under contractual data processing agreements.
• Legal and regulatory authorities: We may disclose your personal data to law enforcement, regulatory bodies, or courts where we are legally required to do so, or where disclosure is necessary to protect the rights, safety, or property of hbajl or others.

All third-party data processors engaged by hbajl are subject to written data processing agreements that require them to implement appropriate technical and organisational security measures and to process data only on hbajl's documented instructions.

6 Cookies & Tracking Technologies

hbajl uses cookies and similar tracking technologies to operate core Platform functionality, remember your preferences, and analyse how players use the site. The categories of cookies used are as follows:

• Strictly necessary cookies: Essential to the operation of the Platform. These include session authentication cookies that keep you logged in during an active session, security tokens that prevent cross-site request forgery, and load-balancing cookies. These cannot be disabled without breaking Platform functionality.
• Functional cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming tool configurations. Disabling these cookies may reduce the quality of your experience but will not prevent you from using the Platform.
• Analytics cookies: Used to collect aggregate, anonymised data about how players navigate the Platform. This data helps us identify which pages are most visited, where users encounter difficulties, and how we can improve the overall experience. We do not use analytics data to build individual profiles.
• Performance cookies: Used to monitor Platform response times, detect errors, and support our technical operations team in maintaining Platform stability.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent the Platform from functioning correctly. For more information on managing cookies in the most common browsers, consult your browser's help documentation.

7 Data Retention

hbajl retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The general retention periods we apply are as follows:

• Active account data: Retained for the lifetime of your account. If your account is closed at your request, we retain your data for a minimum of five (5) years following closure to comply with AML record-keeping obligations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, in line with standard financial record-keeping requirements.
• Identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship, as required for AML compliance purposes.
• Customer support communications: Retained for a minimum of three (3) years from the date of the last interaction, to support dispute resolution and quality assurance.
• Marketing consent records: Retained until you withdraw your consent, plus a further one (1) year to maintain evidence of the consent having been properly managed.
• Technical and analytics data: Aggregated analytics data with no personally identifiable information is retained indefinitely. Raw technical logs containing IP addresses are retained for a maximum of ninety (90) days.

When data reaches the end of its retention period, it is securely deleted or anonymised in a manner that prevents reconstruction of the original personal information.

8 Data Security

hbajl implements a layered security architecture to protect your personal data against unauthorised access, loss, alteration, or disclosure. Our key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your browser or device and our servers, including login sessions, deposit flows, and account management pages.
• Password hashing using industry-standard one-way algorithms. Your password is never stored in plain text and cannot be retrieved by any hbajl employee.
• Role-based access controls that restrict employee access to personal data strictly to those whose job function requires it, with all access logged and auditable.
• Continuous system monitoring for anomalous login attempts, unusual transaction patterns, and potential intrusion indicators, with automated alerts triggering rapid human review.
• Regular security assessments of our infrastructure, code, and third-party integrations to identify and remediate vulnerabilities before they can be exploited.

Despite these measures, no online system can guarantee absolute security. If you believe your account has been compromised, contact our support team at [email protected] immediately so we can take protective action.

9 Your Rights

As a player on the hbajl Platform, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact our support team at [email protected] with the subject line "Privacy Rights Request — [Your Account Username]".

• Right of access: You may request a copy of all personal data we hold about you, along with information about how it is being processed.
• 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 without undue delay.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (see Section 7).
• Right to restriction of processing: In certain circumstances, you may request that we restrict the processing of your data — for example, while the accuracy of data you have contested is being verified.
• Right to data portability: Where processing is based on your consent or the performance of a contract and is carried out by automated means, you may request that we provide your data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing of your personal data carried out on the basis of our legitimate interests, including profiling. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

We aim to respond to all privacy rights requests within thirty (30) days of receipt. If the complexity or volume of requests requires more time, we will notify you within the initial thirty-day period and provide an estimated completion date.

10 Children & Minors

The hbajl Platform is strictly for adults aged 21 and over. We do not knowingly collect personal data from any person under the age of 21. If you are under 21, you must not use the Platform or submit any personal information to hbajl.

If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data from our systems and close the associated account. If you are a parent or guardian and believe that your child has submitted personal data to hbajl, please contact us at [email protected] without delay.

11 Third-Party Links

The hbajl Platform may contain references to or integrations with third-party services, including payment providers such as bKash, Nagad, and Rocket, and game content platforms operated by providers such as Pragmatic Play, Evolution Gaming, and Spribe. When you interact with these third-party services, you are subject to their own privacy policies and terms of service, not this Privacy Policy.

hbajl has no control over the content, privacy practices, or data-handling procedures of third-party services and accepts no responsibility or liability for them. We encourage you to review the privacy policy of any third-party service you interact with through or alongside the Platform.

12 Policy Updates

hbajl may update this Privacy Policy from time to time to reflect changes in our data practices, Platform features, or applicable legal requirements. When we make material changes, we will notify registered players by email to their registered address and update the "Effective" date displayed at the top of this page and in the hero section above.

We encourage you to review this Privacy Policy periodically. Your continued use of the Platform following the effective date of any update constitutes your acknowledgement of the revised policy. If you disagree with any material change, you may close your account and request withdrawal of any remaining balance before ceasing use.

13 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the personal data hbajl holds about you, please contact our English-speaking support team:

• Email: [email protected] (plain text — not a clickable link)
• Subject line for privacy requests: "Privacy Rights Request — [Your Account Username]"
• Support Hours: 24 hours a day, 7 days a week
• Response Timezone: Bangladesh Standard Time (BST, UTC+6)
• Target response time: Within 30 days of receiving a verifiable request

Written privacy rights requests submitted via email will receive an acknowledgement within 48 hours of receipt. We may ask you to verify your identity before actioning a request to ensure we are disclosing or modifying data only to the rightful account holder.