pbd9 Privacy Policy — How We Protect Your Personal Data

1 Introduction & Scope

This Privacy Policy describes how pbd9 ("we", "us", "our"), the operator of the online gaming platform located at https://pbd9.io, collects, uses, stores, shares, and protects the personal data of individuals ("you", "your") who visit, register on, or otherwise interact with the pbd9 platform.

This policy applies to all personal data processed by pbd9 in connection with the platform's services, including sports betting, live casino games, slot games, account management, customer support interactions, and marketing communications. It applies regardless of the device or browser you use to access pbd9.

By creating a pbd9 account or continuing to use the platform after the effective date of this policy, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how pbd9 processes personal data, you should not create an account or continue using the platform.

This Privacy Policy should be read alongside the pbd9 Terms & Conditions and the pbd9 Responsible Gaming Policy, both of which are published separately on the platform.

2 Data Controller Information

pbd9 is the data controller responsible for the personal data collected and processed through the platform. As data controller, pbd9 determines the purposes and means by which personal data is processed.

For all privacy-related enquiries, data access requests, correction requests, or deletion requests, players may contact the pbd9 Data Protection team directly:

• Email: support@pbd9.io
• Subject Line: "Privacy / Data Request — [Your Registered Username]"
• Response Time: Within 30 calendar days of receipt of a verified request
• Support Hours: 24/7, Bangladesh Standard Time (UTC+6)

To process a data request, pbd9 may require you to verify your identity by providing documentation consistent with the KYC materials submitted at registration. This safeguard exists to prevent unauthorised access to another person's data.

3 Personal Data We Collect

pbd9 collects personal data in the categories described in the table below. We apply the principle of data minimisation — we collect only what is necessary for the stated purpose.

pbd9 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information, except where a player voluntarily discloses health-related information in the context of a responsible gaming self-exclusion request, in which case that data is used exclusively to implement the requested account restriction.

4 How We Collect Your Data

pbd9 collects personal data through the following channels:

• Direct submission: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion, you provide data directly to pbd9.
• Automated collection: When you browse or use the pbd9 platform, our systems automatically collect technical and usage data including your IP address, device identifiers, session data, and interaction logs. This collection occurs via server logs, cookies, and similar tracking technologies.
• Payment processors: When you initiate a BDT transaction via bKash, Nagad, Rocket, or Upay, the relevant payment service provider shares transaction confirmation data with pbd9 for the purpose of crediting or debiting your account balance.
• Identity verification partners: Where pbd9 uses a third-party KYC service to verify your NID or passport, that provider may return a verification result and associated identity data to pbd9 for the purposes of completing your account verification.
• Game providers: Licensed game providers integrated into the pbd9 platform (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may share game session data and round results with pbd9 to enable accurate crediting of winnings and to support dispute resolution.

5 Legal Basis for Processing

pbd9 processes your personal data only where a valid legal basis exists. The legal bases we rely upon are:

• Contractual necessity: Processing is necessary to perform the contract between pbd9 and you as a registered player — for example, processing deposits and withdrawals, maintaining your account, and delivering game results.
• Legal obligation: Processing is required to comply with applicable legal requirements, including anti-money-laundering (AML) obligations, age verification requirements, and record-keeping mandates.
• Legitimate interests: pbd9 processes certain data on the basis of its legitimate interests, including fraud detection, platform security, responsible gaming monitoring, and service improvement — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where pbd9 relies on your consent as the legal basis for processing — for example, to send you promotional communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 How We Use Your Data

pbd9 uses the personal data we collect for the following purposes:

• Creating and managing your pbd9 player account.
• Verifying your identity and age in compliance with our 21+ policy.
• Processing BDT deposits and withdrawals via bKash, Nagad, Rocket, and Upay.
• Delivering casino games, sports betting markets, and live dealer experiences.
• Crediting winnings, applying bonus funds, and calculating wagering progress.
• Providing customer support through live chat and email.
• Detecting and preventing fraud, money laundering, bonus abuse, and multi-accounting.
• Monitoring gaming activity to identify responsible gaming concerns and to implement account restrictions where requested or required.
• Sending transactional communications such as deposit confirmations, withdrawal notifications, and security alerts — these are not marketing messages and cannot be opted out of while your account is active.
• Sending promotional communications about pbd9 bonuses, tournaments, and new games — only if you have provided explicit consent.
• Analysing aggregated, anonymised usage data to improve platform performance, game selection, and user experience.
• Complying with applicable legal obligations and responding to lawful requests from competent authorities.

pbd9 does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review, except where such processing is necessary to detect fraud or fulfil a legal obligation, in which case you have the right to request human review of the decision.

7 Sharing Your Data with Third Parties

pbd9 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

• Payment processors: bKash, Nagad, Rocket, and Upay receive the minimum data necessary to process your BDT transactions. These providers operate under their own privacy policies and are responsible for data processed solely within their systems.
• Game providers: Licensed studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) receive a pseudonymised player session token to enable game delivery and result verification. They do not receive your full name, contact details, or financial information.
• KYC and identity verification providers: Where pbd9 uses a third-party service to verify your NID or passport, that provider receives the document images you submit. These providers are contractually prohibited from retaining or using your documents for any purpose other than verification.
• Fraud prevention and security providers: Technical data including IP addresses, device fingerprints, and session behaviour may be shared with specialist fraud detection partners to protect the integrity of the pbd9 platform and all players on it.
• Legal and regulatory authorities: pbd9 may disclose personal data to law enforcement agencies, financial intelligence units, or other competent authorities where required to do so by applicable law, court order, or regulatory requirement. pbd9 will notify you of such a disclosure unless prohibited from doing so by law.
• Business transfers: In the event that pbd9 undergoes a merger, acquisition, or sale of all or part of its assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy.

All third-party data processors engaged by pbd9 are subject to written data processing agreements that require them to implement appropriate technical and organisational security measures and to process your data only on pbd9's documented instructions.

8 International Data Transfers

pbd9 operates primarily to serve players located in Bangladesh. Some of our third-party service providers — including game studios and technical infrastructure partners — may be located outside Bangladesh and may process your data in their respective countries of operation.

Where personal data is transferred internationally, pbd9 ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that described in this Privacy Policy. These safeguards may include standard contractual clauses, data processing agreements, or the use of providers who operate under internationally recognised data protection frameworks.

By using the pbd9 platform, you acknowledge that your data may be processed in countries outside Bangladesh, subject to the protections described above.

9 Data Retention Periods

pbd9 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of your account plus five (5) years following account closure, to satisfy AML record-keeping obligations.
• Transaction and financial records: Retained for a minimum of seven (7) years from the date of the transaction, in accordance with financial record-keeping requirements.
• KYC and identity documents: Retained for five (5) years following account closure or the completion of the relevant verification process, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the interaction, to support dispute resolution and quality assurance.
• Marketing consent records: Retained for three (3) years from the date of consent or withdrawal of consent, to demonstrate compliance with consent requirements.
• Technical and usage logs: Retained for twelve (12) months, after which they are anonymised or deleted.

Upon the expiry of the applicable retention period, personal data is securely deleted or anonymised. Anonymised data — which cannot be used to identify you — may be retained indefinitely for statistical and analytical purposes.

10 Cookies & Tracking Technologies

pbd9 uses cookies and similar technologies (including local storage and session tokens) to operate the platform, remember your preferences, maintain session security, detect fraud, and analyse platform usage. The types of cookies used by pbd9 are:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional cookies: Remember your preferences such as language settings and display options, so you do not need to reconfigure them on each visit.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and use the platform. This data is used to improve the platform experience. pbd9 uses first-party analytics tools for this purpose.
• Security cookies: Used to detect and prevent fraudulent access attempts, bot activity, and multi-accounting behaviour. These are a core component of the pbd9 platform security infrastructure.

pbd9 does not use third-party advertising cookies or behavioural targeting cookies. Your browsing activity on pbd9 is not shared with advertising networks.

You may configure your browser to refuse or delete cookies; however, disabling strictly necessary cookies will impair your ability to log in and use core platform features. Functional and analytics cookies may be disabled without affecting access to the platform.

11 Your Data Rights

As a pbd9 player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team at support@pbd9.io with the subject line "Privacy / Data Request".

pbd9 will respond to all verified data rights requests within 30 calendar days. In complex cases, this may be extended by a further 30 days, in which case we will notify you of the extension and the reason for it. There is no charge for exercising your data rights unless a request is manifestly unfounded or excessive, in which case pbd9 may charge a reasonable administrative fee or decline to act on the request.

12 Children's Privacy

The pbd9 platform is strictly for adults aged 21 years and above. pbd9 does not knowingly collect personal data from individuals under the age of 21. Age is verified as part of the account registration and KYC process.

If pbd9 discovers or is notified that a person under 21 has created an account or provided personal data, we will immediately suspend the account, delete all associated personal data to the extent permitted by legal obligations, and report the matter to appropriate authorities where required by law. Any deposits made by an underage person will be returned to the originating payment source.

Parents and guardians who believe their child may have accessed the pbd9 platform should contact our support team immediately at support@pbd9.io. We will investigate and act promptly on any such report.

13 Security Measures

pbd9 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and pbd9 servers.
• Encrypted storage of sensitive data fields including passwords (hashed using industry-standard algorithms) and financial identifiers.
• Access controls that restrict internal access to personal data on a strict need-to-know basis. pbd9 staff are prohibited from accessing player data outside the scope of their authorised duties.
• Multi-factor authentication for all internal systems that store or process personal data.
• Regular security audits and penetration testing conducted by independent security specialists.
• Intrusion detection and monitoring systems that flag unusual access patterns in real time.
• Incident response procedures to contain, investigate, and remediate any data security incident promptly, and to notify affected players and relevant authorities where required by applicable law.

Despite these measures, no online platform can guarantee absolute security against all possible threats. Players are advised to use strong, unique passwords for their pbd9 accounts, to keep their login credentials confidential, and to contact support immediately if they suspect unauthorised access to their account.

14 Changes to This Policy

pbd9 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When a material change is made, pbd9 will publish the updated policy on this page with a revised "Last Updated" date and will endeavour to notify registered players via the email address associated with their account.

It is your responsibility to review this Privacy Policy periodically. Continued use of the pbd9 platform following publication of an amended policy constitutes your acknowledgement of the changes. If you do not accept the revised policy, you should cease using the platform and may close your account by contacting our support team.

15 Contact & Data Requests

For all privacy-related enquiries, questions about this Privacy Policy, or to exercise any of your data rights, please contact the pbd9 support team using the details below:

• Email: support@pbd9.io
• Subject Line: "Privacy / Data Request — [Your Registered Username]"
• Response Commitment: Within 30 calendar days of receipt of a verified request
• Availability: 24 hours a day, 7 days a week
• Languages: English and Bengali
• Time Zone: Bangladesh Standard Time (BST, UTC+6)

To help us process your request efficiently, please include your registered username and a clear description of your request. We may ask you to verify your identity before acting on a data rights request, to ensure we do not inadvertently disclose or delete another player's information.

pbd9 is committed to resolving all privacy concerns fairly and promptly. If you are unsatisfied with our response to a privacy complaint, you may have the right to escalate the matter to an appropriate data protection authority under applicable law.