hbajl Privacy Policy — How We Protect Your Personal Data

1. Data Controller and Scope

hbajl ("hbajl", "we", "us", "our") is the data controller responsible for the personal information collected through the hbajl.app platform, including all associated subdomains, mobile-optimised pages, and any communications sent from [email protected]. This Privacy Policy applies to all registered players, visitors browsing the platform without an account, and any individual who contacts hbajl support.

This policy governs the collection, use, storage, disclosure, and protection of personal data in connection with your use of hbajl's sports betting, live casino, slots, and related services. It should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which form part of your agreement with hbajl.

2. Information We Collect

hbajl collects personal data through several distinct channels. The categories of data we hold, and the typical source of each, are described below.

2.1 Account Registration Data

When you register an account on hbajl, you provide us with the following information directly:

• Full legal name as it appears on your government-issued identity document
• Date of birth (used for age verification — hbajl is an 18+ platform)
• Residential address, including city (Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, or other)
• Mobile phone number
• Email address
• Username and encrypted password

2.2 Identity Verification (KYC) Documents

Before processing any withdrawal, hbajl requires you to complete our Know Your Customer (KYC) verification process. Documents collected at this stage may include:

• National Identity Card (NID) or passport scan or photograph
• Proof of address document (utility bill, bank statement, or official correspondence dated within three months)
• Proof of payment method ownership (screenshot of your bKash, Nagad, Rocket, Upay, or bank account registered in your name)

2.3 Financial Transaction Data

When you deposit or withdraw funds, hbajl records transaction reference numbers, amounts in BDT, timestamps, payment method type, and the outcome of each transaction. hbajl does not store full payment card numbers, mobile banking PINs, or mobile banking passwords — these are handled exclusively by the relevant payment processor (bKash, Nagad, Rocket, Upay, or the respective bank).

2.4 Platform Usage and Betting Data

hbajl automatically records data about how you interact with the platform, including bets placed (sport, market, odds, stake, outcome), casino games played (game title, provider, wager size, result), session duration, features accessed, and promotional offers viewed or claimed.

2.5 Technical and Device Data

Our servers automatically collect certain technical data when you access hbajl.app, including your IP address, browser type and version, operating system, device type (desktop, mobile, or tablet), referring URL, and page navigation paths during each session.

2.6 Communications Data

When you contact hbajl support by email, we retain the content of that correspondence, your email address, and the date and time of the communication for support quality and dispute resolution purposes.

3. How We Use Your Data

hbajl uses the personal data it holds for the following purposes. Each purpose is grounded in a specific legal basis — either contractual necessity, legal obligation, legitimate interest, or your explicit consent.

hbajl does not use automated decision-making processes that produce legally significant outcomes for players without human review. Where automated tools are used — for example, to flag unusual betting patterns or deposit behaviour — a member of the compliance team reviews flagged cases before any account action is taken.

4. Data Sharing and Third Parties

hbajl does not sell, rent, or trade your personal data to any third party for marketing purposes. We share data with external parties only in the following strictly defined circumstances:

4.1 Payment Processors

To process deposits and withdrawals, hbajl shares the minimum necessary transaction data with our payment partners including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank. Each payment partner operates under its own privacy and data protection framework. hbajl is not responsible for the data practices of third-party payment providers once data has been passed to their systems.

4.2 Game Providers

To deliver live casino, slots, and other game content, hbajl shares a player session token with game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. This token allows the game provider to authenticate your session and record game results. Game providers do not receive your full name, NID, or payment details.

4.3 Legal and Regulatory Disclosure

hbajl may be required to disclose personal data in response to a lawful request from a court, law enforcement authority, or other government body. We will comply with such requests to the extent required by applicable law and will inform affected users where legally permitted to do so.

4.4 Anti-Fraud and Compliance Services

hbajl may engage third-party identity verification and fraud detection services to assist with KYC checks and ongoing transaction monitoring. These providers process data exclusively on hbajl's behalf, under contractual obligations that restrict them from using the data for any purpose other than providing the contracted service.

5. Cookies and Tracking Technologies

hbajl uses cookies and similar technologies on hbajl.app. A cookie is a small text file placed on your device by a website to remember information about your session and preferences. The cookies hbajl uses fall into the following categories:

5.1 Strictly Necessary Cookies

These cookies are essential for the platform to function and cannot be disabled. They include your session authentication token (which keeps you logged in during a session), CSRF security tokens (which protect form submissions from cross-site attacks), and load-balancing cookies that ensure your requests are routed to the correct server. No consent is required for strictly necessary cookies.

5.2 Analytics Cookies

With your consent, hbajl uses analytics tools to understand how players navigate the platform — which pages are visited most, where users drop off during registration, and how different game categories perform. This data is used in aggregate and anonymised form to improve the platform experience. You may decline analytics cookies without affecting your ability to use hbajl.

5.3 Preference Cookies

These cookies remember your platform preferences such as your preferred language setting (English) and display options. They improve your experience across sessions but are not essential to platform functionality.

5.4 Managing Cookies

You can manage or delete cookies at any time through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in and using the platform. Most modern browsers — including Chrome, Firefox, Safari, Edge, and Samsung Internet (popular in Bangladesh) — provide straightforward cookie management tools in their privacy settings.

6. Data Retention

hbajl retains personal data only for as long as it is necessary to fulfil the purpose for which it was collected, or as required to meet our legal and compliance obligations. The following retention periods apply:

• Active account data: Held for the duration of your account plus a minimum of five years following account closure, to comply with anti-money laundering record-keeping requirements.
• KYC documents (NID, address proof): Retained for a minimum of five years from the date of verification, or from the date of account closure, whichever is later.
• Transaction records: Retained for a minimum of five years in accordance with financial record-keeping best practice.
• Support correspondence: Retained for three years from the date of the last interaction, for dispute resolution purposes.
• Analytics and usage data: Aggregated and anonymised after 13 months; raw session-level data is deleted on a rolling 13-month basis.
• Marketing preferences: Retained until you withdraw consent or close your account, whichever comes first.

When data reaches the end of its retention period, hbajl securely deletes or irreversibly anonymises it so that it can no longer be linked to an identifiable individual. Deletion requests submitted under your right to erasure (see Section 8) will be processed subject to any mandatory retention obligations that override the request.

7. Security Measures

hbajl implements technical and organisational security measures appropriate to the risk level of the personal data we hold. Our current security framework includes the following controls:

7.1 Encryption

All data transmitted between your browser or app and hbajl.app is encrypted using TLS 1.2 or higher. Passwords are stored using a strong one-way hashing algorithm — hbajl staff cannot retrieve or view your password in plain text. KYC documents are stored in encrypted object storage with access restricted to authorised compliance personnel only.

7.2 Access Controls

Access to personal data within hbajl's internal systems is restricted on a strict need-to-know basis. Staff members are granted the minimum data access required to perform their role. Access permissions are reviewed regularly and revoked immediately upon the departure of any team member.

7.3 Intrusion Detection and Monitoring

hbajl operates continuous monitoring of its platform infrastructure for unusual access patterns, login anomalies, and indicators of compromise. Automated alerts notify the security team of potential incidents in real time. Login attempts from unrecognised devices or unusual locations may trigger additional verification steps.

7.4 Data Breach Response

In the event of a confirmed data breach affecting the personal data of hbajl players, we will notify affected users at the email address registered to their account within a commercially reasonable timeframe. Notifications will describe the nature of the breach, the categories of data affected, and the steps hbajl has taken or is taking to address the incident.

8. Your Privacy Rights

As a player on hbajl, you hold the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact hbajl at [email protected] with your registered username and a clear description of your request. We will acknowledge all requests within two business hours (BST, UTC+6) and aim to fulfil them within 30 days.

• Right of access: You may request a copy of all personal data hbajl holds about you, including your account details, transaction history, KYC records, and any support correspondence.
• Right to rectification: If any personal data held by hbajl is inaccurate or out of date, you have the right to request that it be corrected. For example, if your residential address has changed, you may request an update.
• Right to erasure: You may request that hbajl delete personal data it no longer needs to hold. Note that we cannot delete data that we are legally required to retain — for example, KYC and transaction records that fall within our five-year compliance retention window.
• Right to restriction of processing: You may request that hbajl temporarily suspend processing of your personal data — for example, while a dispute about data accuracy is being resolved.
• Right to data portability: You may request that hbajl provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to withdraw marketing consent: If you have previously consented to receive promotional communications from hbajl, you may withdraw that consent at any time by contacting [email protected]. Withdrawal of marketing consent does not affect the lawfulness of any processing that occurred before the withdrawal.
• Right to object: You may object to hbajl's processing of your personal data where that processing is based on legitimate interest, including profiling for responsible gaming monitoring. hbajl will consider and respond to objections on a case-by-case basis.

9. Minors and Age Verification

hbajl is strictly an 18+ platform. We do not knowingly collect personal data from any person under the age of 18. Age verification is a mandatory step before any withdrawal can be processed, and hbajl reserves the right to request proof of age at any point during the account lifecycle.

If hbajl discovers that a registered account belongs to a person under the age of 18, the account will be closed immediately. Any deposits made on the account will be returned to the original deposit source following identity confirmation. All data associated with the under-age account will be deleted promptly, except where retention is required for legal or compliance purposes related to the incident itself.

Parents or guardians who believe a minor may have registered an account on hbajl should contact [email protected] immediately. hbajl will investigate and act on all such reports as a priority.

10. Policy Updates and Contact

10.1 Changes to This Policy

hbajl may update this Privacy Policy periodically to reflect changes in our data practices, platform features, or applicable legal requirements. The effective date at the top of this document and in the page header will be updated to reflect the date of the most recent revision.

Where changes to this policy are material — for example, where we introduce a new category of data collection or a new third-party data processor — hbajl will notify registered players by email at least seven days before the change takes effect. Continued use of the platform after notification constitutes acceptance of the updated Privacy Policy.

10.2 Contacting hbajl About Privacy

If you have any questions about this Privacy Policy, wish to exercise any of your data rights as described in Section 8, or want to raise a concern about how hbajl handles your personal data, please contact the hbajl privacy team at:

Email: [email protected]
Response time: within 2 business hours (Bangladesh Standard Time, UTC+6)
Available: 24 hours a day, 7 days a week

All privacy-related requests and complaints are handled by hbajl's dedicated compliance team. We take every enquiry seriously and aim to resolve all matters fairly, transparently, and within the timeframes set out in this policy.