Data Privacy · User Rights · Security
22bte Privacy Policy
Your privacy is important to us. This Policy explains what personal data 22bte collects, why we collect it, how we use it, and your rights as a player based in Bangladesh.
Introduction
About This Privacy Policy
This Privacy Policy ("Policy") applies to the 22bte platform accessible at https://22bte.app ("Platform") and describes how 22bte ("we", "us", "our") collects, processes, stores, and protects personal data submitted by users ("you", "Player") in connection with account registration, deposits, withdrawals, sports betting, casino gaming, and any other activities conducted on the Platform. By using the Platform, you consent to the data practices described in this Policy.
This Policy forms part of the 22bte Terms and Conditions and should be read alongside them. By accepting the Terms and Conditions, you also confirm that you have read and understood this Privacy Policy. We encourage you to review this Policy periodically as we may update it to reflect changes in our data practices or applicable law. The latest version is always available at https://22bte.app/privacy-policy.
Data Collection
What Information We Collect
We collect personal data that you voluntarily provide to us and data that is generated automatically when you use the Platform. The categories of personal data we collect, and the purpose for collecting each, are set out in the table below.
| Data Category | Examples and Purpose |
|---|---|
| Registration Data | Mobile phone number, date of birth, full name. Used to create and verify your account and confirm age eligibility (21+). |
| Identity Verification (KYC) | Government-issued ID, selfie or photo. Required under anti-fraud and responsible gaming obligations; used to verify player identity before processing withdrawals. |
| Financial Data | bKash / Nagad / Rocket / Upay mobile wallet numbers linked to transactions. Used to process deposits and withdrawals and for fraud prevention. |
| Technical Data | Device type, operating system, IP address, browser type, session timestamps. Used for security monitoring, fraud detection, and Platform stability. |
| Behavioural / Gaming Data | Betting history, game session logs, deposit and withdrawal frequency, responsible gaming tool usage. Used to personalise your experience and fulfil responsible gaming obligations. |
We do not collect or store full payment card numbers, banking PINs, or sensitive authentication credentials beyond what is described above. We do not purchase third-party data lists to supplement your personal profile.
Data Use
How We Use Your Personal Data
22bte uses personal data solely for the purposes set out below. We do not sell your personal data to third parties, and we do not use your data for purposes that are incompatible with the original reason it was collected. The specific purposes for which we process your data are as follows.
- Account management: to create, verify, and maintain your player account, including processing deposits, withdrawals, and bet settlements.
- Legal compliance: to fulfil anti-money laundering (AML) obligations, KYC requirements, and any other applicable legal or regulatory obligations.
- Fraud and security: to detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, and other security incidents.
- Responsible gaming: to monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may need support.
- Service improvement: to analyse aggregated, anonymised Platform usage data to improve game offerings, site performance, and the overall player experience.
- Communications: to send you account-related notifications (e.g. deposit confirmations, withdrawal status updates, security alerts). Promotional messages are only sent where you have opted in. You may opt out of marketing communications at any time by contacting [email protected].
Legal Basis
Why We Are Permitted to Process Your Data
Our processing of your personal data is grounded in the following legal bases. At least one of these bases applies to each processing activity described in this Policy.
- Contract performance: processing is necessary to fulfil the contract between you and 22bte — primarily, to operate your account, process transactions, and settle bets.
- Legal obligation: processing is required to comply with applicable law, including anti-money laundering regulations, age verification requirements, and cooperation with law enforcement.
- Legitimate interests: processing for fraud detection, security monitoring, and service improvement where our legitimate interests are not overridden by your rights.
- Consent: where you have given explicit consent, for example by opting into marketing communications or by voluntarily enabling optional responsible gaming notifications.
Cookies
Cookies and Tracking Technologies
22bte uses cookies and similar tracking technologies on the Platform to ensure functionality, maintain session state, and understand how the Platform is used. We do not use cookies to serve third-party advertising. The following categories of cookies are in use on the Platform.
- Essential cookies: required for the Platform to function correctly. These include session authentication tokens, language preference, and security tokens. They cannot be disabled without breaking Platform functionality.
- Analytics cookies: anonymised data about page visits, session length, and feature usage. This data helps us understand which parts of the Platform are most valuable and where we can improve the player experience.
- Functional cookies: store your preferences such as preferred language version and responsible gaming reminder settings to personalise your experience on return visits.
Most mobile browsers allow you to control cookie settings through your browser preferences. Disabling essential cookies will affect the Platform's ability to authenticate your session and may prevent you from logging in or placing bets. Disabling analytics or functional cookies will not prevent you from using the Platform but may reduce personalisation.
Data Sharing
Who We Share Your Data With
22bte does not sell personal data to third parties. We share personal data only in the limited circumstances described below, and only to the extent necessary for each stated purpose.
- Payment processors: mobile wallet operators (bKash, Nagad, Rocket, Upay) receive transaction-specific data — wallet number and transaction amount — strictly to process deposits and withdrawals. They are not given access to your full account profile or gaming history.
- Game content providers: software providers (e.g. Pragmatic Play, Evolution Gaming, Spribe) receive anonymised session identifiers needed to serve game content and validate outcomes. They do not receive your name, contact details, or financial data.
- Identity verification services: where KYC verification is required, a regulated identity verification partner may process your identification documents on our behalf. This partner operates under strict data processing agreements and is not permitted to use your data for any other purpose.
- Law enforcement and regulatory authorities: where we are legally required to disclose personal data in response to a court order, regulatory instruction, or law enforcement request, we will comply. We will notify you of such disclosure where legally permitted to do so.
Data Retention
How Long We Keep Your Data
We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The general retention periods we apply are as follows: registration and KYC data is retained for the duration of your account and for a minimum of 5 years after account closure to meet anti-money laundering record-keeping obligations; transaction records are retained for a minimum of 5 years from the date of each transaction; gaming session logs are retained for 24 months from the date of the session; communications records (support tickets, emails) are retained for 3 years.
When a retention period expires, data is securely deleted or anonymised so that it can no longer be associated with any individual. Where you request deletion of your personal data and no legal obligation requires us to retain it, we will process your deletion request within 30 days and confirm completion in writing to your registered contact.
Security
How We Protect Your Data
22bte implements industry-standard technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Specific security measures in place on the Platform include SSL/TLS encryption for all data transmitted between your device and our servers; server-side encryption for stored sensitive data fields; access controls that restrict employee access to personal data on a need-to-know basis; automated fraud detection systems that flag unusual account activity; and regular security reviews of our platform infrastructure.
No method of electronic transmission or storage is 100% secure. While we use commercially reasonable measures to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights or freedoms, we will notify you without undue delay using the contact details you have registered on your account.
Your Rights
Your Data Protection Rights
As a player using the 22bte Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us in writing at [email protected] with the subject line "Data Rights Request" and your registered mobile number. We will respond within 30 days.
- Right of access: request a copy of the personal data we hold about you and information about how we use it.
- Right to rectification: request correction of inaccurate or incomplete personal data we hold about you.
- Right to erasure: request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and where no legal retention obligation applies.
- Right to restrict processing: request that we limit how we use your personal data, for example while a rectification request is pending or while you contest the basis for our processing.
- Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.
We will not charge a fee for handling a data rights request unless the request is manifestly unfounded or excessive. Where we are unable to comply with a request — for example, because a legal retention obligation prevents deletion — we will explain the reason in writing.
Children
Minors and the 22bte Platform
The 22bte Platform is strictly for adults aged 21 and above. We do not knowingly collect personal data from any individual under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will delete that data immediately and close the associated account. If you believe a minor has registered on the Platform, please notify us immediately at [email protected] so we can investigate and take appropriate action.
Third-Party Services
Game Providers and External Services
The 22bte Platform integrates content from third-party game providers and uses certain operational service providers. Each of these parties processes only the minimum data necessary to perform their function, under a contractual data processing agreement with 22bte. Key third-party categories in use on the Platform are listed below.
- Game software providers (e.g. Pragmatic Play, Evolution Gaming, Spribe, Ezugi): receive anonymised session tokens to serve live and RNG game content. No personally identifiable information is passed to these providers beyond a session reference.
- Mobile payment processors (bKash, Nagad, Rocket, Upay): receive only the wallet number and transaction amount required to execute a specific deposit or withdrawal. Payment processors operate under their own privacy policies and are independently regulated.
- Platform analytics and security tools: anonymised, aggregated technical data is processed by our hosting and security infrastructure partners to maintain Platform availability and detect threats. No personal data leaves the secure processing environment in identifiable form.
Policy Updates
Changes to This Privacy Policy
22bte may update this Privacy Policy from time to time to reflect changes in our data processing activities, applicable law, or feedback from players. When we make a material change to this Policy, we will post the updated version on the Platform with a revised effective date and, where practical, notify registered players via their account contact. The date at which the current version of this Policy became effective is shown at the top of this page. We encourage you to review this page regularly. Your continued use of the Platform following any update constitutes acceptance of the revised Policy.
Contact
Privacy Enquiries and Data Requests
For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact the 22bte data team in writing at [email protected]. Please include your registered mobile number, a clear description of your query or request, and the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate. All written enquiries are acknowledged within one business day and substantively responded to within 30 days.
Our Privacy Commitments
What Makes 22bte's Privacy Approach Different
Your personal data is never sold to advertisers, data brokers, or any third party. Full stop.
We collect only what is necessary to run your account and stay compliant. No unnecessary data fields, no speculative profiling.
Clear retention schedules mean your data is not kept indefinitely. Expired data is deleted or anonymised on schedule.
bKash, Nagad, Rocket, and Upay transactions share only the minimum data needed to process each payment — nothing more.
Access, rectify, restrict, or erase your data at any time by writing to our support team. We respond within 30 days, no exceptions.
All data in transit between your device and 22bte servers is encrypted with SSL/TLS. Your session and account details are never transmitted in plaintext.
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