Privacy Policy

1Introduction

cd44c ("we", "us", "our") operates the online casino and sports betting platform accessible at https://cd44c.club. This Privacy Policy explains how we collect, use, store, and protect personal data relating to individuals who register for or use our platform ("Players", "Users", "you"). This policy applies to all data collected through the website, through our customer support channels, and through any other interaction you have with cd44c.

By registering an account on cd44c, you confirm that you have read and understood this Privacy Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree with any part of this policy, you should discontinue use of the platform immediately and may contact us to request account closure.

2Information We Collect

We collect several categories of personal data from and about you. The table below summarises the main data categories, specific data points within each category, and the primary reason we hold that data:

3How We Collect Your Data

cd44c collects your personal data through the following channels and interactions:

• Direct interactions: Data you provide when registering an account, completing KYC verification, contacting our support team, or responding to surveys or promotional communications.
• Automated technologies: Data collected automatically when you interact with our platform, including cookies, server logs, and similar tracking technologies that record your IP address, device characteristics, and browsing behaviour on our site.
• Payment processing partners: When you make a deposit or request a withdrawal through bKash, Nagad, Rocket, or Upay, those providers share transaction reference data with us to confirm and reconcile your payment.
• Identity verification providers: For KYC purposes, we may use third-party identity verification services that process identity documents on our behalf and return a verification result. They do not retain your documents beyond the verification process.
• Fraud prevention and analytics providers: We work with reputable fraud detection services that may analyse certain technical data points — such as IP addresses and device fingerprints — to assess risk. These providers process data strictly under our instructions.

4How We Use Your Data

We use the personal data we collect only for specific, legitimate purposes. The following list sets out the primary purposes for which we process your data, together with the legal basis that justifies each use:

• Account creation and management: To register your account, verify your identity, manage your profile, and ensure only one account exists per individual. (Legal basis: contract performance.)
• Payment processing: To process deposits and withdrawals via bKash, Nagad, Rocket, or Upay; to reconcile transactions; and to maintain accurate financial records. (Legal basis: contract performance and legal obligation.)
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests and deposit limits, and fulfil our duty of care obligations. (Legal basis: legitimate interest and legal obligation.)
• Fraud and AML compliance: To detect and prevent fraudulent activity, money laundering, and other criminal conduct; and to report suspicious activity to relevant authorities where legally required. (Legal basis: legal obligation and legitimate interest.)
• Customer support: To respond to your queries, investigate complaints, and resolve disputes fairly and promptly. (Legal basis: contract performance and legitimate interest.)
• Platform improvement: To analyse usage patterns, troubleshoot technical issues, and improve the performance, security, and features of the cd44c platform. (Legal basis: legitimate interest.)
• Promotional communications: To send you information about promotions, bonuses, and offers that may be relevant to you, where you have not opted out. (Legal basis: legitimate interest or consent, depending on applicable law.)

5Legal Basis for Processing

Each time we process your personal data, we rely on one or more of the following legal bases:

• Contract performance: Processing is necessary to perform the contract between you and cd44c — for example, to operate your account, process payments, and deliver the gaming service you have requested.
• Legal obligation: Processing is necessary to comply with a legal obligation to which cd44c is subject, including anti-money laundering laws, age verification requirements, and reporting obligations.
• Legitimate interests: Processing is necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your data protection rights. Legitimate interests include platform security, fraud prevention, and service improvement.
• Consent: Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6Sharing Your Data

cd44c does not sell your personal data to any third party under any circumstances. We may share your data only in the following limited situations:

• Service providers: We share data with carefully selected third-party service providers who process data on our behalf, including identity verification providers, fraud detection services, and payment processing partners. All such providers are bound by data processing agreements that restrict their use of your data to the specific purpose for which it was shared.
• Legal and regulatory authorities: We may disclose your data to law enforcement agencies, regulatory bodies, or courts when required by applicable law, or where disclosure is necessary to protect the rights, property, or safety of cd44c, our players, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of cd44c's business, player data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any resulting change to this Privacy Policy.
• With your explicit consent: We will share your data with any other third party only where you have given us your clear and specific consent to do so.

All third-party recipients of your data are required to handle it securely and in accordance with applicable data protection standards. cd44c remains responsible for ensuring that any sharing arrangement meets these standards.

7Cookies and Tracking Technologies

cd44c uses cookies and similar technologies to operate the platform, enhance your experience, and maintain security. The following types of cookies are used on our platform:

• Essential cookies: Required for the platform to function. They enable core features such as user authentication, session management, and security checks. These cookies cannot be disabled without breaking the service.
• Analytics cookies: Help us understand how players interact with the platform, which pages are visited most frequently, and where technical errors occur. This data is used in aggregate form to improve our service.
• Security and fraud prevention cookies: Used to identify unusual or suspicious activity patterns, detect bot traffic, and protect players from unauthorised account access.
• Preference cookies: Store your platform preferences such as display settings and notification preferences, so you do not need to re-enter them on each visit.

You may manage cookie preferences through your device's browser settings. Disabling essential cookies will impair platform functionality and certain features may become unavailable. Disabling analytics or preference cookies will not affect your ability to play games or process transactions.

8Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Active account data: Retained for the duration of your account's active status plus five (5) years following account closure, to meet legal and regulatory obligations including AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with financial record-keeping obligations.
• Support and complaint records: Retained for three (3) years from the date the matter was resolved, to allow for any subsequent regulatory inquiry or legal proceedings.

When data is no longer required for any of the above purposes, it is securely deleted or anonymised so that it can no longer be linked to an individual player. Anonymised aggregated data may be retained indefinitely for statistical and analytical purposes.

9Data Security

cd44c takes the security of your personal data seriously. We implement a range of technical and organisational security measures to protect your data from unauthorised access, accidental loss, destruction, or disclosure:

• 256-bit SSL/TLS encryption is applied to all data transmitted between your device and our servers, ensuring that your login credentials, personal information, and transaction data are protected in transit.
• Access to personal data is restricted on a strict need-to-know basis. Only cd44c personnel with a specific operational requirement to access your data may do so, and all such access is logged and audited.
• Our servers and databases are protected by industry-standard firewalls, intrusion detection systems, and regular security patching. We conduct periodic internal security reviews to identify and address vulnerabilities.
• All cd44c personnel who handle personal data receive regular data protection and security training. Staff are required to adhere to strict confidentiality obligations as a condition of their engagement.

10Your Data Rights

As a player on cd44c, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with your registered mobile number and a description of your request:

• Right of access: You may request a copy of the personal data we hold about you, together with information about how it is being processed.
• Right to rectification: You may request that we correct any inaccurate or incomplete personal data we hold about you. We will action such requests within a reasonable timeframe.
• Right to erasure: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and no other legal basis for processing exists. This right is subject to our legal obligations to retain certain data.
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances, for example while the accuracy of data is disputed or while a complaint is under investigation.
• Right to object: You may object to the processing of your personal data where we rely on legitimate interests as the legal basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time by contacting us. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

We will respond to all data rights requests within 30 calendar days of receipt. Complex requests may require additional time; in such cases we will notify you of the extension and the reason for it. There is no fee for submitting a data rights request unless a request is manifestly unfounded or excessive.

11Children's Privacy

cd44c is strictly an adult platform. Access is limited to individuals aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21. If we become aware that we have inadvertently collected data from a person under the age of 21, we will immediately delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on cd44c or provided us with personal data, please contact us immediately at [email protected]. We take underage gambling extremely seriously and will act without delay on any credible report.

12Third-Party Links

The cd44c platform may reference third-party services such as payment providers (bKash, Nagad, Rocket, Upay) and game software providers (Pragmatic Play, Evolution Gaming, and others). These third parties operate under their own privacy policies and terms. cd44c is not responsible for the data practices of any third-party provider. We encourage you to review the privacy policies of any third-party service you use in connection with your cd44c account.

13Changes to This Policy

cd44c reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the effective date shown at the top of this page. Where a change is significant, we may additionally notify registered players via their mobile number or through an on-platform notification at our discretion.

Your continued use of the cd44c platform after any update to this Privacy Policy constitutes your acceptance of the revised policy. If you do not accept the revised policy, you should discontinue use of the platform and may contact us to request account closure.

14Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a complaint about how we have handled your personal data, please contact the cd44c data support team. We aim to resolve all privacy-related queries and complaints within 30 calendar days of receipt.