Your Privacy Matters at 11bd — Data We Collect and How We Use It

1 Introduction and Scope

This Privacy Policy ("Policy") describes how 11bd ("we", "us", "our") collects, uses, stores, and protects the personal data of users ("you", "the player", "the user") who access or use the 11bd platform located at 11bd.io (the "Platform"), including all associated gaming, betting, and account management services.

This Policy applies to all personal data collected through the Platform, regardless of the device or method used to access it. By registering an account or continuing to use 11bd, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated by reference into this document.

2 Data Controller Information

For the purposes of data protection law, 11bd operates as the data controller in respect of the personal data it collects from players using the Platform. As data controller, 11bd determines the purposes for which and the means by which personal data is processed.

All data protection enquiries, access requests, and complaints should be directed to:

• Platform: 11bd.io
• Contact Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week

3 What Personal Data We Collect

The categories of personal data that 11bd may collect from you include, but are not limited to, the following:

Data Category	Examples	When Collected
Identity Data	Full name, date of birth, nationality, NID or passport number	Registration and KYC verification
Contact Data	Email address, mobile phone number, residential address	Registration and account updates
Financial Data	bKash/Nagad/Rocket account number, transaction records, deposit and withdrawal history	Deposits, withdrawals, KYC
Gaming Activity Data	Bet history, game sessions, win/loss records, bonus usage	Ongoing platform use
Technical Data	IP address, device type, browser type, operating system, session timestamps	Automatically on platform access
Communications Data	Live chat transcripts, support email history, survey responses	When you contact support
Preference Data	Language preferences, notification settings, responsible gaming limits	Account settings updates

We do not intentionally collect sensitive personal data beyond what is required for identity verification, fraud prevention, and responsible gaming obligations (such as self-exclusion records).

4 How We Collect Your Data

11bd collects personal data through the following channels:

• Direct interactions: Data you provide when creating an account, completing KYC, making a deposit or withdrawal, contacting support, or responding to a survey or promotion.
• Automated technologies: Technical data collected automatically when you access the Platform, including cookies, server logs, and similar tracking technologies. See Section 8 for more details on cookies.
• Third-party sources: Identity and fraud-risk data received from KYC service providers, payment processors (such as bKash, Nagad, Rocket, and Upay), and anti-fraud data partners, used solely to verify your identity and protect the integrity of your account.
• Game providers: Aggregated gaming session data shared by third-party game studios (such as Pragmatic Play, Evolution Gaming, and Spribe) integrated into the Platform, limited to the data necessary to display your game history and resolve disputes.

5 Why We Process Your Data

11bd processes your personal data for the following specific purposes:

• Account management: Creating, maintaining, and operating your player account, including processing deposits and withdrawals in Bangladeshi Taka (BDT) via bKash, Nagad, Rocket, and Upay.
• Identity verification and KYC: Confirming that you meet the 21+ age requirement and verifying your identity in accordance with our responsible gaming and anti-fraud obligations.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, money laundering, and other prohibited conduct as defined in our Terms & Conditions.
• Customer support: Responding to your queries, resolving disputes, and processing complaints submitted via live chat or email.
• Responsible gaming: Monitoring player activity to identify signs of problem gambling, applying deposit limits and self-exclusion measures, and fulfilling our responsible gaming obligations.
• Platform improvement: Analysing aggregated usage patterns to improve the design, performance, and content of the Platform. This analysis is conducted on anonymised or aggregated data wherever possible.
• Legal compliance: Meeting our obligations under applicable financial crime regulations, data protection law, and any court or regulatory orders we are subject to.
• Marketing communications: Sending you promotional offers and updates about 11bd, where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.

6 Legal Basis for Processing

Every processing activity carried out by 11bd is based on one or more of the following legal grounds:

• Contract performance: Processing necessary to fulfil our obligations under the Terms & Conditions you have agreed to — primarily account operation, transaction processing, and customer support.
• Legal obligation: Processing required to comply with applicable law, including KYC/AML requirements and responsible gaming mandates.
• Legitimate interests: Processing carried out in furtherance of 11bd's legitimate business interests, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained. You may withdraw consent at any time by contacting support.

7 Sharing Your Data with Third Parties

11bd does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing purposes. We may share your data with the following categories of third-party recipients, strictly on a need-to-know basis and under contractual data protection obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, SureCash, and Tap receive the minimum data necessary to process your deposits and withdrawals. These providers have their own privacy policies governing how they handle transaction data.
• KYC and identity verification providers: Third-party services that assist with identity document verification and age confirmation as part of our KYC process.
• Game providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive session-level data required to operate their games on our Platform.
• IT infrastructure and hosting providers: Secure hosting and cloud infrastructure providers that store Platform data on our behalf under strict data processing agreements.
• Anti-fraud and security services: Third-party risk management and fraud detection tools that help us protect your account and the integrity of the Platform.
• Legal and regulatory authorities: Law enforcement agencies, courts, and regulatory bodies, where we are legally required to disclose personal data by applicable law or valid legal process.

8 Cookies and Tracking Technologies

11bd uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and improve your experience. The following categories of cookies may be active when you use the Platform:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in during a gaming session and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core Platform functionality.
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits, and display options so you do not need to re-enter them on each visit.
• Analytics cookies: Collect anonymised information about how users navigate the Platform, which pages are visited most frequently, and where errors occur, to help us improve the user experience. These are not used to identify individual users.
• Marketing cookies: Used to track the effectiveness of our promotional campaigns and deliver relevant offers where you have consented to receive marketing communications. These may be disabled by contacting our support team.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the Platform, including logging in and placing bets.

9 Data Retention

11bd retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. The following general retention guidelines apply:

• Account data: Retained for the duration of your active account relationship with 11bd, and for a period of up to 5 years following account closure, in accordance with financial crime and responsible gaming record-keeping requirements.
• Transaction records: Financial transaction data, including deposits and withdrawals, is retained for a minimum of 5 years from the date of the transaction.
• KYC documents: Identity verification documents are retained for a minimum of 5 years following the end of the business relationship.
• Support communications: Live chat transcripts and email correspondence are retained for up to 2 years from the date of the interaction, unless they are relevant to an ongoing dispute or legal matter.
• Technical and log data: Server logs, IP addresses, and session data are retained for up to 12 months, after which they are deleted or anonymised.

When data is no longer required under the applicable retention period, 11bd securely deletes or anonymises it so that it can no longer be associated with an individual player.

10 Data Security Measures

11bd implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These include:

• SSL 256-bit encryption on all pages and data transmission channels between your browser and our servers.
• Encrypted data storage for all sensitive personal and financial data held on our infrastructure.
• Access controls limiting internal access to personal data on a strict need-to-know basis, with role-based permissions and audit logging.
• Regular security assessments and penetration testing conducted by qualified third-party security professionals.
• Incident response procedures to detect, contain, and report data security incidents within required timeframes.
• Staff training on data protection obligations and secure data handling practices.

11 Your Data Rights

As a player registered on 11bd, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected].

We aim to respond to all data rights requests within 30 calendar days. In complex cases, we may extend this period by a further 60 days, in which case we will notify you of the extension within the initial 30-day window. We will not charge a fee for processing data rights requests unless they are manifestly unfounded or excessive.

12 Children and Minors

The 11bd platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. If we become aware that a minor has provided us with personal data or has created an account on the Platform, we will take immediate steps to close the account, delete the associated data, and report the matter in accordance with our responsible gaming procedures.

If you are a parent or guardian and believe that a person under 21 in your care may have registered an account on 11bd, please contact us immediately at [email protected]. We treat all such reports as a high priority.

13 Changes to This Policy

11bd may update this Privacy Policy periodically to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or an in-platform notification at least 7 days before the updated Policy takes effect.

The "Last Reviewed" date at the top of this document will always reflect when the Policy was most recently updated. We encourage you to review this Policy periodically to stay informed about how we handle your data. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.

Previous versions of this Privacy Policy are available upon request by contacting our support team.

14 Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or our data handling practices, please contact the 11bd support team using the details below:

• Email: [email protected]
• Support Hours: 24 hours a day, 7 days a week, 365 days a year
• Live Chat: Available on the Platform for all registered players
• Response Time: Within 3 minutes via live chat; within 24 hours via email

If you are not satisfied with our response to a privacy concern or complaint, you have the right to escalate the matter to the relevant data protection authority or seek independent legal advice. 11bd will cooperate fully with any investigation conducted by a competent authority.