habaee Privacy Policy
— How We Handle Your Personal Data
At habaee, the privacy and security of every player's personal data is a foundational commitment, not an afterthought. This Privacy Policy explains precisely what information habaee collects when you use our platform, the legal basis on which we process it, how long we retain it, and the rights you hold as a data subject. We encourage all players — whether newly registered or long-standing habaee members — to read this document carefully.
Scope of This Policy: This Privacy Policy applies to all personal data collected by habaee through the website at habaee.net, including all subpages, the habaee Casino section, sports betting services, account registration, habaee Login, promotional communications, and customer support interactions. It does not apply to third-party websites or services linked from or integrated with habaee's platform — please consult those parties' own privacy policies for information on their data practices.
Privacy at a Glance
Our Core Privacy Commitments
Before diving into the full policy detail, the cards below summarise the six most important principles that guide how habaee approaches player data. These are not substitutes for the full policy text — they are entry points to it.
Minimal Collection
habaee collects only the personal data that is strictly necessary for the purposes described in this policy. We do not collect data speculatively or for purposes unrelated to operating a safe, fair, and compliant gaming platform for Bangladesh players.
Secure Storage
All personal data held by habaee is stored on servers protected by industry-standard SSL/TLS encryption, access controls, and regular security audits. Data at rest is encrypted, and access is restricted to authorised personnel on a strict need-to-know basis.
Your Rights Respected
As a habaee player, you have the right to access, correct, export, and in certain circumstances request deletion of the personal data we hold about you. Requests are handled by our support team and processed within the timeframes described in the Your Privacy Rights section of this policy.
No Unauthorised Sale
habaee does not sell, rent, or otherwise trade your personal data to third-party marketers. Data is shared only with trusted service providers acting on habaee's behalf under contractual data protection obligations, or where legally required.
Defined Retention Periods
habaee does not retain personal data indefinitely. Retention periods are tied to the purpose for which data was collected — account data is retained for the duration of your habaee membership plus any legally mandated period thereafter, then securely deleted or anonymised.
Transparent Communication
habaee will notify affected players promptly in the event of a personal data breach that is likely to result in a risk to their rights or interests. We maintain an internal data breach response procedure and will communicate clearly about the nature of any breach and recommended protective steps.
Section 1
Information We Collect
habaee collects personal data through several channels: directly from you when you register an account or interact with our platform, automatically through your use of the site, and from third-party payment processors in the course of deposit and withdrawal transactions. The categories of personal data we collect are described below.
| Data Category | Specific Examples |
|---|---|
| Identity Data | Full legal name, date of birth, gender, government-issued ID number (National ID Card, passport, or driving licence), and a copy of the ID document provided during KYC verification. |
| Contact Data | Email address, mobile phone number, city of residence (e.g., Dhaka, Chittagong, Sylhet, Khulna), and preferred communication language. |
| Financial Data | Mobile financial service account numbers (bKash, Nagad, Rocket, Upay), bank account details where bank transfer is used, deposit and withdrawal transaction history, balances, and bonus redemption records. habaee does not store full card numbers. |
| Device & Technical Data | IP address, browser type and version, operating system, device type (mobile/desktop), screen resolution, session timestamps, and referring URL. |
| Usage & Behavioural Data | Pages visited on habaee.net, games played, bet amounts, wagering patterns, game session duration, bonus activity, and login/logout timestamps recorded after each habaee Login event. |
| Location Data | Country and city-level location derived from IP address. habaee does not request or collect precise GPS location data from your device. |
| Communications Data | Content and metadata of communications sent to habaee via email ([email protected]) or live chat, including support ticket history and any attachments you submit. |
| Marketing Preferences | Your stated preferences regarding promotional emails, SMS notifications, and in-platform bonus offers, including opt-in and opt-out records and the date of each preference change. |
Special Category Data: habaee does not intentionally collect special category personal data (such as health data, religious beliefs, or political opinions). However, if a player contacts us to request Responsible Gaming support — for example, to activate a self-exclusion or disclose a gambling-related health concern — we may record such information for the sole purpose of delivering the requested protective measure. This data is handled with heightened access controls.
Section 2
Legal Basis for Processing
habaee processes personal data only where a valid legal basis exists for doing so. The applicable legal bases are set out below, along with examples of the processing activities to which each basis applies.
- Contractual necessity: Processing that is necessary to perform the contract between habaee and the Player — including account creation, processing deposits and withdrawals via bKash, Nagad, and Rocket, delivering game results, crediting winnings, and applying bonus terms. Without this processing, habaee cannot operate the Player's account.
- Legal obligation: Processing required to comply with applicable legal and regulatory requirements, including Anti-Money Laundering (AML) obligations, Know Your Customer (KYC) identity verification, retention of financial transaction records, and responding to lawful requests from authorities. habaee is required by law to conduct and retain the results of these processes and cannot waive them at a Player's request.
- Legitimate interests: Processing for purposes that are in habaee's legitimate business interests and do not override the Player's fundamental rights — including fraud detection, security monitoring, platform performance analytics, responsible gaming risk assessment, internal audit, and improving the quality of habaee's games and services. Players may object to legitimate-interest processing in certain circumstances (see Your Privacy Rights).
- Consent: Processing that relies on your explicit consent — specifically, sending promotional emails and SMS notifications about habaee bonuses, new game launches, cricket betting markets, and seasonal offers (such as Eid promotions or BPL match specials). You may withdraw consent at any time by updating your marketing preferences in Account Settings or by emailing [email protected].
Section 3
How We Use Your Data
The personal data habaee holds is used exclusively for the purposes described in this policy. We do not use your data for any purpose that is incompatible with the reason it was originally collected. The primary uses of your data are set out below:
- Account management: Creating and maintaining your habaee account, authenticating your habaee Login sessions, processing password resets, and communicating account status updates.
- Payment processing: Facilitating deposits and withdrawals via bKash, Nagad, Rocket, Upay, and bank transfer; reconciling transaction records; and resolving payment disputes.
- KYC and compliance: Verifying player identity and age (18+ requirement), screening against sanctions lists, fulfilling AML monitoring obligations, and generating compliance reports as required by applicable law.
- Personalisation: Tailoring the habaee game lobby, promotional offers, and cricket betting markets to your demonstrated interests and play history, where you have not opted out of personalisation.
- Responsible gaming: Monitoring wagering patterns to identify signs of problem gambling; applying deposit limits, cool-off periods, and self-exclusion measures you have requested; and proactively reaching out where our systems flag potential harm-related activity.
- Customer support: Responding to enquiries submitted to [email protected], resolving disputes, and maintaining a record of support interactions for quality assurance purposes.
- Security and fraud prevention: Detecting, investigating, and preventing fraudulent transactions, bonus abuse, account takeover attempts, bot activity, and any other conduct that violates habaee's Terms & Conditions.
- Marketing communications: Sending promotional messages about habaee bonuses, new game titles, cricket and sports betting markets, and seasonal offers — only where you have given consent or where permitted under the legitimate interest basis for existing customer communications. You may opt out at any time.
- Platform improvement: Aggregated and anonymised analytics to understand how players use habaee.net, identify technical issues, optimise page performance, and improve the overall gaming experience for Bangladesh players.
Section 5
Data Sharing & Third Parties
habaee does not sell personal data. We share player data only in the following defined circumstances, and only to the extent necessary for the stated purpose:
- Payment service providers: Transaction data (name, account number, amount, timestamp) is shared with bKash, Nagad, Rocket, Upay, and participating banks (including Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, and Sonali Bank) solely for the purpose of processing deposits and withdrawals to and from your habaee account.
- KYC and identity verification providers: Where habaee uses a third-party KYC service to assist with document verification, the minimum necessary identity data (name, date of birth, ID document image) is shared with that provider under a data processing agreement. The provider processes this data only on habaee's instruction and is contractually prohibited from using it for any other purpose.
- Game Suppliers: Your username or anonymised Player ID, session token, and bet/win data are shared with the relevant Game Supplier (e.g., Pragmatic Play, Evolution Gaming, Spribe, NetEnt, Microgaming, Ezugi) to deliver the game round and return the outcome to habaee's platform. Game Suppliers do not receive your full identity or payment data.
- Fraud and security vendors: Anonymised device and behavioural data may be shared with third-party fraud prevention services that help habaee identify bot activity, account takeover attempts, and collusion patterns. These vendors are bound by strict confidentiality and data minimisation obligations.
- Legal and regulatory disclosure: habaee will disclose personal data to law enforcement, regulatory authorities, or courts where required to do so by a lawful order or legal obligation. habaee will, where legally permitted, notify affected players of such disclosure requests.
- Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of habaee's assets, player personal data may be transferred to the successor entity as part of that transaction. Players will be notified of any such transfer and of any resulting material change to this Privacy Policy before it takes effect.
Section 6
Data Retention & Storage
habaee retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or audit obligations. The retention periods below reflect our current data lifecycle policy.
| Data Category | Retention Period & Rationale |
|---|---|
| Account & Identity Data | Retained for the lifetime of your habaee account plus a minimum of 5 years following account closure. This period reflects AML and financial record-keeping obligations. After expiry, data is securely deleted or irreversibly anonymised. |
| Financial Transaction Records | Retained for a minimum of 5 years from the date of the transaction, consistent with financial record-keeping requirements. Transaction logs include deposit/withdrawal amounts, timestamps, payment method references, and balance snapshots. |
| KYC Verification Documents | Retained for the duration of the account relationship plus 5 years post-closure. Document copies are stored in an access-controlled, encrypted repository separate from general account data. |
| Wagering & Game History | Individual bet records retained for 2 years from the date of the wager. Aggregated statistical data derived from game history may be retained longer in anonymised form for responsible gaming monitoring purposes. |
| Customer Support Communications | Retained for 2 years from the date of the last message in a support ticket thread. This allows habaee to reference prior interactions when handling follow-up enquiries and dispute investigations. |
| Marketing Preferences & Consent Records | Consent records (including opt-in and opt-out timestamps) are retained for the lifetime of the account plus 3 years post-closure, to demonstrate compliance with marketing consent obligations. |
| Analytics & Technical Logs | Server access logs and anonymised analytics data retained for up to 12 months, after which they are aggregated or deleted. Personally identifiable technical data (such as raw IP logs) is retained for no more than 90 days unless required for an active fraud investigation. |
Storage Location: habaee stores personal data on secure servers. All data is encrypted in transit using TLS 1.2 or higher and encrypted at rest. Access to production data is restricted to a limited number of authorised habaee personnel and is subject to multi-factor authentication. habaee conducts regular security reviews of its data storage infrastructure.
Section 7
Your Privacy Rights
As a habaee player, you have a number of rights in relation to the personal data habaee holds about you. These rights are set out below. To exercise any of these rights, contact habaee's support team at [email protected] with your registered email address and the nature of your request. habaee targets acknowledgement within 48 hours and full response within 30 days on Bangladesh Standard Time (UTC+6), unless the complexity of the request requires a brief extension, in which case we will notify you.
Right of Access
You may request a copy of the personal data habaee holds about you, along with information about why we hold it, who we share it with, and how long we retain it. This is sometimes called a Subject Access Request (SAR).
Right to Rectification
If any personal data habaee holds about you is inaccurate or incomplete, you have the right to request correction. Minor account detail updates (such as phone number or city) can be made directly in Account Settings after habaee Login.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose it was collected and no overriding legal obligation requires habaee to retain it. Note that financial and KYC records must be retained for legally mandated periods and are not eligible for early erasure.
Right to Restriction
In certain circumstances — for example, while a data accuracy dispute is under review — you may request that habaee restricts its processing of your data to storage only, temporarily pausing other uses until the matter is resolved.
Right to Portability
Where processing is based on your consent or contractual necessity and carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format, and to request that habaee transmit it to another data controller where technically feasible.
Right to Object
You may object at any time to habaee processing your personal data on the basis of legitimate interests, including for direct marketing and profiling for personalisation purposes. If you object to marketing, habaee will cease that processing immediately upon receipt of your request.
Identity Verification for Rights Requests: To protect player privacy, habaee will verify the identity of anyone submitting a data rights request before processing it. You will be asked to confirm your registered email address and may be asked to provide additional verification details. habaee will not fulfil data rights requests from individuals who cannot be verified as the account holder or an authorised representative.
Section 8
Contact & Data Enquiries
habaee takes all privacy-related enquiries seriously. Whether you have a question about this Privacy Policy, want to exercise a data subject right, or need to report a suspected data security incident affecting your account, our team is available around the clock on Bangladesh Standard Time (UTC+6).
All data-related enquiries should be sent to [email protected] with the subject line "Privacy Enquiry" or "Data Request". Please include your registered email address and, where relevant, your habaee account username so that we can locate your records efficiently. Do not include full payment method numbers or government ID numbers in your email — reference them by type only (e.g., "my bKash number" or "my National ID").
habaee targets acknowledgement of all privacy and data requests within 48 hours and a full substantive response within 30 calendar days of receipt. For complex requests that require additional time, habaee will notify you before the 30-day deadline explaining the reason for the extension and the expected completion date.
habaee reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, operational requirements, or applicable law. When material changes are made, habaee will notify registered players by email to their registered address and/or by a prominent notice on habaee.net for at least 14 days before the updated policy takes effect. Continued use of the habaee platform after the effective date of a revised Privacy Policy constitutes acceptance of the revised terms. If you do not accept the revised terms, you should close your account before the effective date by emailing [email protected].
Policy Version: This Privacy Policy is version 1.0, effective 1 January 2026. The most current version of this policy is always available at habaee.net/privacy-policy. Previous versions are available on request by contacting [email protected].
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