Privacy Policy — dbt111 Data Commitment

Section 1

Data We Collect

dbt111 collects personal data through several channels: directly from you when you register an account or interact with the platform, automatically as you browse and use our services, and from third-party sources where permitted by law. The categories of data we collect are described below.

1.1 Account Registration Data

When you create a dbt111 account, we collect the following information:

• Your chosen username and the email address used to register;
• Your date of birth, which we use to verify that you meet the 18+ age eligibility requirement;
• Your country and city of residence — this helps dbt111 apply the correct terms, payment methods, and responsible gaming rules relevant to players in Bangladesh;
• Your preferred currency (Bangladeshi Taka, BDT);
• The phone number optionally provided at registration, used for two-factor authentication and account recovery.

1.2 KYC Verification Data

Before processing withdrawals, dbt111 is required to verify your identity. During the KYC process, we collect copies of identity documents you submit, which may include your Bangladeshi National Identity Card (NID), passport, a recent utility bill or bank statement for address verification, and in some cases a live selfie photograph. These documents are used exclusively for identity and age verification and fraud prevention.

1.3 Payment and Transaction Data

When you make a deposit or request a withdrawal on dbt111, we collect transaction data including the payment method used (e.g., bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, or Mastercard), the transaction amount in Bangladeshi Taka, the transaction reference number provided by the payment provider, and the timestamp of the transaction. We do not store full card numbers or mobile wallet PINs.

1.4 Technical and Usage Data

When you access dbt111, our servers and analytics systems automatically collect the following technical data:

• Your IP address and approximate geographic location derived from it;
• The type of device, operating system, and browser you use to access the platform;
• Session duration, pages visited, games launched, and betting activity logs;
• Referring website URL (if you arrived at dbt111 from another site);
• Crash and error logs generated during your session, used for technical debugging.

1.5 Communications Data

If you contact dbt111's support team by email at [email protected] or through any in-platform messaging feature, we retain records of those communications — including the content of your messages, the time they were sent, and any attachments — for a minimum of twelve (12) months. These records are used to resolve disputes, improve support quality, and maintain an audit trail.

1.6 Responsible Gaming Data

Where you voluntarily set deposit limits, loss limits, session time limits, or request a self-exclusion through dbt111's responsible gaming tools, we record these preferences and restrictions as part of your account profile. This data is treated with particular sensitivity and is used solely to enforce the limits and protections you have requested.

Section 2

How We Use Your Data

dbt111 processes your personal data only where there is a lawful basis for doing so. The lawful bases we rely on are: the performance of a contract with you (operating your account), compliance with legal obligations, our legitimate interests in running a safe and fair platform, and in specific cases your explicit consent. The table below summarises the primary purposes for which dbt111 uses your data.

2.1 Account Management and Service Delivery

The most fundamental use of your data is to create and maintain your dbt111 account, process your deposits and withdrawals, credit bonus funds, record your gaming and betting history, and provide you with access to all platform features. Without this processing, dbt111 cannot deliver its services to you.

2.2 Identity Verification and Fraud Prevention

dbt111 uses your registration data and KYC documents to verify that you are who you say you are, that you meet the 18+ age requirement, and that you are not on any self-exclusion or restricted-player list. We also use transaction data and usage patterns to detect and investigate suspected fraud, collusion, bonus abuse, and money laundering. This processing is both a legal obligation and a legitimate interest of dbt111.

2.3 Legal and Regulatory Compliance

dbt111 retains certain categories of data — particularly financial transaction records — for the minimum periods required under applicable anti-money-laundering (AML) and financial record-keeping standards. We may be required to disclose data to law enforcement, financial intelligence units, or other competent authorities where legally compelled to do so. In such cases, dbt111 will disclose only the minimum data necessary and will, where legally permitted, notify the affected player.

2.4 Responsible Gaming Enforcement

Where you have set deposit limits, time-out periods, or self-exclusion orders, dbt111 uses your account data to actively enforce those restrictions. dbt111 may also use behavioural data — such as session frequency, time spent playing, and deposit escalation patterns — to identify players who may be showing signs of problem gambling and to proactively offer responsible gaming support tools.

2.5 Customer Support

When you contact dbt111 support, we use your account data and communication history to respond to your query accurately and efficiently, to investigate complaints, and to improve our support processes. Communications may be reviewed by quality assurance staff for training purposes, subject to appropriate confidentiality safeguards.

2.6 Platform Improvement and Analytics

Aggregated, anonymised usage data is used by dbt111 to understand how players navigate the platform, which games are most popular, where technical friction occurs, and how to improve the overall user experience. This analytics processing does not identify individual players and is used solely for platform development purposes.

2.7 Promotional Communications

With your consent at the time of registration, dbt111 may send you promotional emails about new games, seasonal bonus offers (such as those tied to Eid, Pohela Boishakh, BPL cricket season, or Victory Day), and platform updates. You may withdraw consent for promotional communications at any time by contacting [email protected]. Withdrawal of marketing consent does not affect transactional or account communications, which dbt111 is entitled to send as part of the service contract.

Section 3

Data Sharing and Disclosure

dbt111 does not sell your personal data. We share personal data with third parties only in the limited circumstances described in this section, and only to the extent necessary for the specific purpose.

3.1 Payment Processors

To process your deposits and withdrawals, dbt111 must share relevant transaction data with the payment service providers you use — including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and card networks such as Visa and Mastercard. Each of these providers operates under its own privacy policy and data security standards. dbt111 shares only the minimum transaction data necessary to complete the payment instruction.

3.2 Game Software Providers

Games on dbt111 are powered by third-party software providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others. When you launch a game, a session token and your anonymised player identifier are passed to the relevant provider's game server to initiate the game session. Full personal details such as your name, email address, or payment information are not shared with game providers.

3.3 Identity Verification Services

dbt111 may use third-party identity verification services to assist with KYC processing. Where such services are used, your submitted identity documents are shared with the verification provider under a strict data processing agreement that prohibits the provider from using your data for any purpose other than completing the verification task on dbt111's behalf.

3.4 Legal Authorities

dbt111 will disclose personal data to law enforcement bodies, financial intelligence units, courts, or regulatory authorities when legally required to do so — for example, in response to a valid court order, subpoena, or statutory information request. dbt111 will not disclose data to authorities on an informal or voluntary basis without legal compulsion, except where there is an immediate and credible risk to the safety of a person.

3.5 Business Transfers

In the event that dbt111's business or assets are acquired, merged, or transferred to another entity, personal data held by dbt111 may be transferred to the successor entity as part of that transaction. Players will be notified of any such transfer via the email address registered on their account no less than thirty (30) days before the transfer takes effect, and will be given the opportunity to close their account and withdraw their balance before the transfer if they object.

Section 4

Cookies and Tracking Technologies

dbt111 uses cookies and similar tracking technologies to operate the platform, maintain your login session, remember your preferences, and gather anonymised analytics. This section explains the types of cookies dbt111 uses and how you can manage them.

4.1 What Are Cookies?

Cookies are small text files placed on your device by the dbt111 website when you visit. They allow the site to recognise your device on subsequent visits, remember your logged-in state, and deliver a consistent user experience. Cookies cannot execute code, carry viruses, or access any files on your device.

4.2 Types of Cookies Used by dbt111

4.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies via the browser's privacy or security settings menu. Please note that disabling strictly necessary cookies will prevent you from logging into or using the dbt111 platform. Disabling functional cookies will mean your preferences are not remembered between sessions.

dbt111 does not use third-party advertising cookies or cross-site tracking cookies. The analytics cookies we use collect data in an aggregated, anonymised form that does not identify individual players.

Section 5

Data Retention and Storage

dbt111 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. The retention periods applied to each category of data are set out in the table in Section 1. The general principles governing dbt111's data retention approach are as follows.

5.1 Active Account Data

While your dbt111 account is active, all account, transaction, KYC, and communications data associated with it is retained in full. This data is necessary to operate your account, process transactions, resolve disputes, and comply with ongoing legal obligations.

5.2 Post-Closure Retention

Following closure of your dbt111 account — whether initiated by you or by dbt111 — personal data is not immediately deleted. We are required to retain financial transaction records for a minimum of seven (7) years for AML compliance purposes. Account registration data and KYC documents are retained for five (5) years post-closure to allow dbt111 to respond to regulatory inquiries and to enforce lifetime self-exclusion orders where applicable.

5.3 Data Storage Location

dbt111's primary data infrastructure is hosted on secure servers. All data is stored and processed in encrypted form. Access to production databases is restricted to authorised technical personnel, and all access events are logged and monitored. dbt111 does not store personal data on portable or unsecured media.

5.4 Data Deletion Requests

If you request deletion of your personal data under the rights described in Section 6, dbt111 will delete or anonymise data that is not subject to a mandatory legal retention obligation. Data that must be retained under AML, financial regulation, or responsible gaming requirements cannot be deleted on request but will be placed in a restricted archive accessible only to compliance personnel. You will be informed of any data that cannot be deleted and the reason for its continued retention.

Section 6

Your Privacy Rights

As a user of dbt111, you hold the following rights with respect to your personal data. To exercise any of these rights, contact [email protected] with the subject line "Privacy Rights Request" and provide your registered email address and a brief description of the right you wish to exercise. dbt111 will respond within five (5) business days during Bangladesh Standard Time (BST, UTC+6) working hours.

dbt111 will not charge a fee for the exercise of any of the above rights in ordinary circumstances. If a request is manifestly unfounded or excessive — for example, a repeated request for the same data export — dbt111 reserves the right to charge a reasonable administrative fee or to decline the request, with written explanation provided to the player.

Section 7

Data Security Measures

Protecting your personal data from unauthorised access, loss, alteration, or disclosure is a top operational priority at dbt111. The following technical and organisational measures are in place to safeguard your information.

7.1 Encryption in Transit and at Rest

All data transmitted between your device and dbt111's servers is protected by 256-bit TLS/SSL encryption. Sensitive data stored in dbt111's databases — including KYC documents, payment references, and account credentials — is encrypted at rest using industry-standard encryption protocols. Encryption keys are managed under strict access controls and are rotated on a regular schedule.

7.2 Access Controls

Access to systems containing personal data is restricted to dbt111 personnel who have a legitimate operational need. All staff with data access undergo background screening and receive privacy and data handling training. Privileged access to production databases is subject to multi-factor authentication and all access events are logged in a tamper-evident audit trail.

7.3 Network Security

dbt111's platform infrastructure is protected by firewalls, intrusion detection systems, and DDoS mitigation services. Penetration testing is conducted periodically by independent security specialists. Identified vulnerabilities are triaged and remediated according to a defined severity-based patching schedule.

7.4 Incident Response

In the unlikely event of a data security incident that affects your personal data, dbt111 has a documented incident response procedure. Affected players will be notified by email without undue delay if the incident is assessed to pose a significant risk to their rights or freedoms. The notification will describe the nature of the incident, the categories of data affected, the steps dbt111 has taken to contain it, and any recommended actions for affected players.

7.5 Your Role in Security

While dbt111 implements robust technical safeguards, the security of your account also depends on the strength of your password and the confidentiality with which you maintain your login credentials. dbt111 recommends using a unique, complex password for your account and enabling two-factor authentication where available. If you suspect your account credentials have been compromised, contact [email protected] immediately.

Section 8

Updates to This Privacy Policy

dbt111 may update this Privacy Policy from time to time to reflect changes in our data practices, new legal obligations, or improvements to the platform. The effective date at the top of this page indicates when the current version was last revised.

Where an update involves a material change to how we collect, use, or share your personal data, dbt111 will notify registered players via the email address associated with their account no less than fourteen (14) calendar days before the change takes effect. Minor clarifications or corrections that do not affect the substance of your rights or our obligations may be made without advance notice.

Continued use of the dbt111 platform after the effective date of a revised Privacy Policy constitutes acceptance of the updated terms. If you do not agree with the revised policy, you may close your account by contacting [email protected] before the effective date of the revision.

Previous versions of this Privacy Policy are available on request by contacting [email protected]. dbt111 retains archived copies of all prior policy versions for internal reference and regulatory purposes.