aec44 Privacy Policy

1 Introduction

aec44 is committed to protecting the privacy and personal data of every player who uses our platform. We understand that players in Bangladesh trust us with sensitive personal and financial information when they register, deposit, play, and withdraw, and we take that responsibility seriously.

This Policy applies to all personal data collected through the aec44 website, mobile-optimised browser experience, live chat support system, email correspondence, and any other interaction channel through which you provide us with personal information. It covers data collected both at the point of registration and throughout your ongoing use of the Platform.

This Policy is written in English and shall be interpreted in English. In the event of any inconsistency between this Policy and any translated version, the English version shall govern. All support communications related to privacy matters are handled in English.

2 Personal Data We Collect

2.1 Registration Data

When you create an aec44 account, we collect the following personal information:

• Full legal name (as it appears on your official identity document);
• Date of birth (for age verification — players must be 21 years of age or older);
• Residential address, including district and division within Bangladesh;
• Email address;
• Mobile phone number (primary contact and 2FA verification);
• Username and encrypted password credentials.

2.2 Identity Verification (KYC) Data

To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements, we may collect copies or images of the following documents:

• National Identity Card (NID) issued by the Bangladesh Election Commission;
• Valid passport (biographical data page);
• Proof of residential address (utility bill or bank statement, not more than three months old);
• Proof of payment method ownership (confirmation that the bKash, Nagad, Rocket, or Upay mobile wallet belongs to you).

2.3 Financial Transaction Data

We collect data relating to all financial transactions on your account, including:

• Deposit amounts, timestamps, and originating payment method identifiers;
• Withdrawal requests, amounts, processing status, and destination payment method identifiers;
• Account balance history and transaction ledger records;
• Bonus credits claimed, wagering activity, and promotional participation records.

2.4 Gaming and Betting Activity Data

We record your activity on the Platform, including games played, bets placed, wager amounts, game outcomes, session durations, and any responsible gaming limits you have set on your account. This data is used to provide the service, detect problem gambling patterns, investigate disputes, and improve the Platform.

2.5 Technical and Device Data

When you access the Platform, we automatically collect certain technical data, including:

• IP address and approximate geographic location derived from it;
• Device type, operating system, and browser type and version;
• Session timestamps, page views, and navigation paths;
• Cookie identifiers and similar tracking technologies (see Section 6).

2.6 Communications Data

We retain records of all communications between you and aec44, including live chat transcripts, email correspondence, and any information you submit through support forms or feedback channels. These records are used for quality assurance, dispute resolution, and compliance purposes.

3 How We Use Your Personal Data

aec44 uses the personal data we collect for the following specific purposes:

• Account Management: Creating, maintaining, and administering your player account, including processing login authentication, managing your balance and transaction history, and facilitating account recovery;
• Identity Verification: Conducting KYC checks to verify your age (21+), identity, and residential address in compliance with responsible gaming and AML obligations;
• Payment Processing: Processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and reconciling transaction records;
• Fraud and Security: Detecting, investigating, and preventing fraudulent activity, multi-accounting, bonus abuse, and other prohibited conduct as described in our Terms and Conditions;
• Responsible Gaming: Monitoring gaming behaviour to identify potential problem gambling indicators, applying player-requested account restrictions, and providing relevant support resources;
• Customer Support: Responding to your support enquiries, resolving disputes, and maintaining communication records for quality assurance;
• Legal Compliance: Fulfilling our obligations under applicable laws and regulations, including AML record-keeping requirements;
• Service Improvement: Analysing aggregated, anonymised platform usage data to improve game offerings, site performance, and the overall player experience;
• Direct Communications: Sending you account-related notifications, transaction confirmations, security alerts, and — where you have consented — promotional communications regarding bonuses and offers.

We do not use your personal data for automated decision-making that produces legal effects or similarly significant outcomes without human review, except where such processing is necessary for fraud detection and account security, in which case you have the right to request human review of any automated decision affecting your account.

4 Legal Basis for Processing

aec44 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between aec44 and you, including operating your account, processing transactions, and delivering gaming services;
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC identity verification and AML transaction monitoring;
• Legitimate Interests: Processing carried out for aec44's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and service analytics — provided that these interests are not overridden by your privacy rights;
• Consent: Processing for purposes where you have provided explicit consent, such as receiving promotional communications. You may withdraw consent for marketing communications at any time by contacting [email protected].

5 Data Sharing and Disclosure

5.1 Service Providers

aec44 shares personal data with carefully selected third-party service providers who assist us in delivering the Platform. These providers are contractually required to process data only on our instructions and only for the purposes described in this Policy. Categories of service providers include:

• Payment processing partners (bKash, Nagad, Rocket, Upay, and card processing networks);
• Identity verification and KYC service providers;
• Game software providers (Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, Spribe, Ezugi — who may process gameplay data to deliver their games);
• Fraud detection and cybersecurity service providers;
• Cloud infrastructure and data hosting providers;
• Customer support platform providers.

5.2 Legal Disclosure

aec44 may disclose personal data to law enforcement agencies, regulatory authorities, or other government bodies where we are legally required to do so, or where disclosure is necessary to protect the rights, safety, or property of aec44, its players, or the public. We will notify affected players of any such disclosure where we are legally permitted to do so.

5.3 No Sale of Data

aec44 does not sell, rent, exchange, or otherwise transfer your personal data to third-party advertisers, data brokers, or marketing platforms. Your data is not used to build advertising profiles or to target you with third-party advertising.

6 Cookies and Tracking Technologies

6.1 What Cookies We Use

aec44 uses cookies and similar tracking technologies (including local storage and session tokens) to operate the Platform and deliver a functional, secure, and personalised experience. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, security cookies, and load-balancing identifiers. These cannot be disabled without impairing Platform functionality;
• Functional Cookies: Enable personalised features such as remembering your language preference (English), storing responsible gaming limit settings, and maintaining your session state across pages;
• Analytics Cookies: Used to collect anonymised data about how players navigate and use the Platform, helping us identify performance issues and improve the user experience. This data is aggregated and does not identify individual players;
• Security Cookies: Used to detect and prevent fraudulent access attempts, multi-accounting, and other security threats by identifying unusual access patterns.

6.2 Managing Cookies

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging into your account or using core Platform features. Disabling analytics cookies will not affect your ability to use the Platform but will limit our ability to improve the service based on usage data.

7 Data Retention

aec44 retains personal data for the following periods:

• Active Account Data: Retained for the full duration of your account's active status plus a minimum of five (5) years following account closure, to comply with AML record-keeping obligations;
• KYC Documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction;
• Support Communications: Retained for three (3) years from the date of the last communication in each support case;
• Technical Logs: Retained for twelve (12) months from the date of collection, except where a longer period is required for a specific security investigation;
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.

Following the expiry of the applicable retention period, data is securely deleted or anonymised so that it can no longer be associated with any individual player.

8 Data Security

aec44 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL Encryption: All data transmitted between your browser or device and the aec44 platform is encrypted using current TLS protocols;
• AES-256 Encryption at Rest: Sensitive data including KYC documents, payment identifiers, and account credentials are encrypted at rest using AES-256 encryption;
• Access Controls: Access to player personal data within aec44's internal systems is restricted to authorised personnel on a strict need-to-know basis, with role-based access controls and multi-factor authentication required for all staff access;
• Regular Security Audits: aec44 conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited;
• Incident Response: A documented data breach response procedure is in place, enabling rapid containment, investigation, and player notification in the event of a security incident.

9 Your Privacy Rights

aec44 respects your rights in relation to your personal data. You have the following rights, which you may exercise at any time by contacting us at [email protected] with the subject line "Privacy Rights Request":

• Right of Access: You have the right to request a copy of the personal data aec44 holds about you, along with information about how it is used and with whom it is shared;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations which may override this right in certain circumstances;
• Right to Restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while a dispute about its accuracy is being resolved;
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format where processing is based on your consent or on a contract between us;
• Right to Object: You have the right to object to processing of your personal data carried out on the basis of legitimate interests, where your individual circumstances warrant it;
• Right to Withdraw Consent: Where processing is based on your consent (for example, marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

aec44 will respond to all verified privacy rights requests within 30 days of receipt. Where a request is complex or voluminous, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

10 Children and Minors

The aec44 platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from any individual under the age of 21. Age verification is a mandatory component of our KYC process and is applied to all accounts.

If aec44 discovers or has reasonable grounds to believe that personal data has been collected from an individual under 21 years of age, we will immediately close the associated account, delete the personal data in question (subject to any overriding legal retention obligations), and return any verified real money deposits to the originating payment method. Winnings associated with an underage account will be forfeited.

If you believe that aec44 may have inadvertently collected data from an individual under 21, please contact us immediately at [email protected] so that we may investigate and take appropriate action without delay.

11 Third-Party Links and Embedded Content

The aec44 platform may contain links to third-party websites, including the websites of game software providers (such as Pragmatic Play, Evolution Gaming, or Spribe) accessed when launching certain game titles. These third-party websites and services are governed by their own privacy policies, and aec44 is not responsible for the privacy practices of any third party.

We encourage you to review the privacy policy of any third-party service you access via the aec44 platform before providing personal information to that service. aec44 does not endorse and is not liable for any third-party data practices.

12 International Data Transfers

aec44 primarily processes and stores player data on servers located in secure data centre facilities. In certain circumstances, personal data may be transferred to or accessed by service providers located outside of Bangladesh — for example, cloud infrastructure providers or game software providers operating internationally.

Where such transfers occur, aec44 takes appropriate steps to ensure that your personal data receives an equivalent level of protection to that described in this Policy. This includes implementing contractual safeguards with all international service providers that require them to process your data securely and only for the purposes authorised by aec44.

By using the aec44 platform and accepting this Privacy Policy, you acknowledge and consent to the transfer of your personal data as described in this section.

13 Amendments to This Policy

aec44 reserves the right to update or amend this Privacy Policy at any time. Where changes are material — meaning they significantly alter how we collect, use, or share your personal data — we will notify you by email and via a prominent on-Platform notification prior to the changes taking effect.

The most current version of this Policy will always be available on this page, with the effective date updated accordingly. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with any changes to this Policy, you must cease using the Platform and may request account closure by contacting Support.

This Privacy Policy was last updated on 1 January 2026 and supersedes all previously published versions.

14 Contact and Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way aec44 handles your personal data, please contact our support team using the details below. All privacy-related communications are handled in English.

• Email: [email protected] (subject line: "Privacy Policy Enquiry" or "Privacy Rights Request")
• Live Chat: Available 24/7 via the on-Platform chat widget
• WhatsApp: +880 1700-000000 (Bangladesh Standard Time, UTC+6)

Formal privacy complaints should be submitted in writing to [email protected] with the subject line "Formal Privacy Complaint". We will acknowledge your complaint within 24 hours and aim to provide a full response within 14 business days of receiving all relevant information.