09 det Privacy Policy — How We Handle Your Personal Data

1. Information We Collect

1.1 Information You Provide Directly

When you register an account on the 09 det Platform, we collect the following personal data that you provide to us directly:

• Identity data: Full legal name, date of birth, gender, and nationality.
• Contact data: Email address, mobile phone number, and residential address (including city, district, and postal code — for example, a Dhaka or Chittagong address).
• Account credentials: Your chosen username and a hashed (never plain-text) version of your password.
• KYC documents: Copies of government-issued identity documents such as your National Identity Card (NID), passport, or driving licence, and proof-of-address documents such as a utility bill or bank statement.
• Payment data: Your bKash, Nagad, Rocket, or Upay account number; bank account details for bank transfer requests; and the last four digits of any Visa or Mastercard used. We do not store full card numbers — these are handled by our PCI-DSS-compliant payment processing partners.
• Communication data: The content of any messages you send to our support team via email or live chat, including any attachments you provide during a support interaction.

1.2 Information Collected Automatically

When you visit or use the 09 det Platform, we automatically collect certain technical and behavioural data, including:

• Device and connection data: IP address, device type (mobile, tablet, desktop), operating system, browser type and version, and internet service provider.
• Usage data: Pages visited, time spent on each page, game sessions started and completed, bet history, deposit and withdrawal history, and session timestamps in Bangladesh Standard Time (BST, UTC+6).
• Location data: Country and approximate region derived from your IP address. We do not collect precise GPS location data.
• Cookie and tracking data: As described in Section 4 below.

1.3 Information from Third Parties

In limited circumstances, 09 det may receive personal data about you from trusted third parties, including:

• Payment processors (bKash, Nagad, Rocket, Upay, bank partners) confirming transaction status and account ownership for fraud prevention purposes.
• Identity verification partners who help us validate KYC documents.
• Fraud prevention and anti-money-laundering screening services.

In each case, we only receive the minimum data necessary for the specific purpose and handle it in accordance with this Policy.

2. How We Use Your Data

09 det uses the personal data we collect for the following purposes. For each purpose, we identify the legal basis on which we rely:

We will never use your personal data for purposes that are incompatible with those listed above without first obtaining your explicit consent. If you have provided consent for a particular use (such as marketing emails) and wish to withdraw it, please contact [email protected].

3. Data Sharing & Disclosure

3.1 Categories of Recipients

09 det does not sell your personal data. We may share your data with the following categories of trusted third parties, strictly for the purposes described in this Policy:

• Payment service providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — to process your deposit and withdrawal transactions.
• Identity verification partners: Third-party KYC and AML screening services used to verify your identity documents and screen for fraud or money-laundering risk.
• Game technology providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other studio partners — who receive anonymised session and wager data to power game mechanics and return-to-player calculations. These providers do not receive your name, address, or payment details.
• Cloud infrastructure providers: Hosting and data-centre partners who store encrypted copies of platform data under strict data processing agreements.
• Legal and regulatory authorities: Where we are required by applicable law to disclose personal data — for example, in response to a lawful request from a financial intelligence unit, court order, or regulatory authority.

3.2 International Data Transfers

Some of 09 det's technology partners operate infrastructure outside Bangladesh. Where personal data is transferred to processors in other countries, we ensure that appropriate safeguards are in place — such as contractual data processing agreements containing standard data protection clauses — to protect your data to a standard equivalent to that applied within Bangladesh.

3.3 Business Transfers

In the event that 09 det undergoes a merger, acquisition, or sale of substantially all of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify registered players by email at least 30 days before any such transfer takes place, and the acquiring entity will be required to honour the commitments in this Policy.

4. Cookies & Tracking

4.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to remember information about your visit — such as your preferred language, session authentication token, or the items in a shopping cart — so that your next visit is smoother and more personalised. 09 det uses cookies responsibly and only for the purposes described below.

4.2 Types of Cookies We Use

4.3 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from logging in and using the Platform. Disabling functional cookies may affect your experience — for example, your preferred settings may not be saved between sessions. Disabling analytics cookies will not affect platform functionality.

09 det does not use cross-site tracking cookies, social media pixels, or any third-party advertising cookies. The cookies we deploy are first-party and serve only the purposes described in the table above.

5. Data Security Measures

09 det maintains a layered approach to data security. The technical and organisational measures we have implemented include, but are not limited to:

• 256-bit SSL/TLS encryption on all data in transit between your device and our servers.
• AES-256 encryption for sensitive data stored at rest in our databases, including identity documents and payment method details.
• Password hashing using a modern one-way hashing algorithm. We never store your password in plain text and our staff cannot retrieve it.
• Two-factor authentication (2FA) available for player accounts and mandatory for all internal administrative access.
• Regular penetration testing conducted by independent third-party security firms to identify and remediate vulnerabilities.
• Role-based access control (RBAC) ensuring that employees can only access the data required for their specific job function.
• Automated intrusion detection systems that monitor for unusual login patterns, abnormal data access, or other indicators of a potential breach.
• Secure data centres with physical access controls, redundant power, and off-site encrypted backups.

Despite these measures, no digital platform can guarantee absolute security. In the unlikely event of a data breach that is likely to result in a risk to your rights, 09 det will notify affected players by email within 72 hours of becoming aware of the breach, in accordance with applicable data protection obligations.

6. Data Retention

09 det retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

When a retention period expires, personal data is either securely deleted from our systems or irreversibly anonymised so that it can no longer be linked to you. We review our data holdings annually to ensure that data no longer required is promptly disposed of in a secure manner.

7. Your Privacy Rights

As a 09 det player, you have a number of rights with respect to the personal data we hold about you. These rights are described below. To exercise any of them, please contact us at [email protected]. We will respond to all verified rights requests within 30 days.

Please note that some rights are subject to limitations. For example, we cannot erase transaction data that we are legally required to retain for anti-money-laundering compliance, even if you request erasure. In such cases, we will explain clearly which data cannot be deleted and why, and we will delete every other piece of data that is not subject to a legal retention obligation.

To verify your identity before processing a rights request, we will ask you to confirm your registered email address and may ask for one additional piece of identity information. This step protects you against someone else making requests using your name.

8. Policy Updates & Contact

8.1 Changes to This Policy

09 det reviews this Privacy Policy at least annually and whenever there is a material change to the way we handle personal data. When we make a significant change — such as adding a new category of data collection or a new type of third-party sharing — we will notify all registered players by email at least 14 days before the change takes effect. The updated Policy will be published at 09-det.club/privacy-policy with a revised version number and effective date shown in the header bar at the top of this page.

Minor changes (such as correcting a typographical error or clarifying existing wording without changing its meaning) may be published without prior notice. We recommend bookmarking this page and reviewing it periodically.

8.2 Children's Privacy

The 09 det Platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from any person under the age of 18. If we discover that a minor has created an account, we will immediately close the account, delete all associated personal data (except records required for legal compliance purposes), and report the matter to relevant authorities where required. If you believe that a minor may have used or attempted to use the 09 det Platform, please contact us at [email protected] immediately.

8.3 Links to Third-Party Sites

The 09 det Platform may contain references to third-party payment providers (bKash, Nagad, Rocket, Upay) whose own privacy policies govern how they process your data on their side of a transaction. 09 det is not responsible for the privacy practices of these third-party providers. We recommend reviewing the privacy policy of any third-party service you use in connection with your 09 det account.

8.4 Contact Us About Privacy

If you have any questions about this Privacy Policy, wish to exercise any of the rights described in Section 7, or want to raise a concern about how your data is being handled, please contact the 09 det Data Protection team directly:

• Email: [email protected] — include "Privacy Request" in the subject line
• Response time: Within 2 business days for general queries; within 30 days for formal rights requests
• Language: English (our primary support language for privacy matters)