hbajer Privacy Policy — How We Handle Your Data

hbajer ("the Platform", "we", "us", or "our") is the data controller responsible for the personal data collected and processed through the hbajer website at hbajer.club and any associated mobile or web applications. As data controller, hbajer determines the purposes and means by which your personal data is processed.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way hbajer processes your personal data, you may contact us at any time using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Response Time: hbajer aims to respond to all privacy-related enquiries within 5 business days of receipt.
• Languages Accepted: English
• Platform URL: hbajer.club

This Privacy Policy applies to all registered players, visitors browsing hbajer.club without an account, and any individual whose personal data hbajer processes in connection with the operation of the platform. It covers all data collected through the website, through account registration, through gameplay, through deposit and withdrawal transactions, and through any communications you initiate with the hbajer support team.

hbajer collects personal data in several ways — directly from you when you register an account or contact support, automatically when you use the platform, and indirectly from payment partners and identity verification services as part of our KYC process. The following table sets out every category of personal data we collect and the primary source of that data.

Data We Do NOT Collect

hbajer does not collect full payment card numbers or card CVV codes directly — card payments are processed through PCI-DSS compliant payment processors that handle sensitive card data entirely on their own secure infrastructure. hbajer receives only a tokenised reference for card transactions. hbajer also does not collect biometric data, facial recognition data, or any health or medical information from players.

Data Collected from Minors

hbajer does not knowingly collect personal data from individuals under the age of 18. If hbajer becomes aware that personal data has been collected from a person under 18, that data will be deleted immediately and the associated account will be closed. If you believe that hbajer may have inadvertently collected data from a minor, please contact us immediately at [email protected].

hbajer uses the personal data it collects only for legitimate, clearly defined purposes directly related to the operation of the platform and the delivery of services to players. The following list sets out every purpose for which hbajer processes your personal data:

• Account Creation and Management: To register your player account, verify your identity, manage your account settings, and provide you with access to the hbajer platform and its features.
• Transaction Processing: To process your deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and supported Bangladesh bank accounts, and to maintain an accurate record of your transaction history.
• KYC and Fraud Prevention: To verify your identity and age as required by our responsible gaming obligations, to detect and prevent fraudulent activity, money laundering, and other financial crimes, and to investigate suspected breaches of our Terms & Conditions.
• Platform Personalisation: To remember your account preferences, display your preferred language and currency settings, and tailor the selection of games and promotions presented to you based on your gameplay history.
• Customer Support: To respond to your queries, complaints, and support requests promptly and accurately, and to maintain a record of communications for quality assurance and dispute resolution purposes.
• Responsible Gaming Compliance: To monitor your gaming activity for indicators of problem gambling behaviour, to apply self-exclusion periods and deposit limits you have requested, and to contact you if our monitoring systems identify a pattern of play that may suggest a gambling-related difficulty.
• Platform Security: To protect the technical integrity of the hbajer platform, detect and block unauthorised access attempts, investigate security incidents, and enforce our one-account-per-player policy.
• Regulatory Compliance: To comply with applicable legal and regulatory obligations, respond to lawful requests from competent authorities, and maintain records required by anti-money laundering regulations.
• Marketing Communications (with consent): To send you promotional emails, SMS messages, or push notifications about bonuses, tournaments, seasonal promotions such as Eid offers or BPL specials, and new features on the hbajer platform — but only if you have explicitly opted in to receive such communications. You may withdraw your consent at any time through your account settings.
• Platform Improvement and Analytics: To analyse aggregated, anonymised usage patterns to identify technical issues, improve game loading times, optimise the user interface, and develop new features that better serve the hbajer player community in Bangladesh.

hbajer does not sell, rent, or otherwise commercialise your personal data. However, operating a complex online gaming and payments platform in Bangladesh requires hbajer to share limited categories of personal data with carefully selected third-party partners. Every third party that receives your data from hbajer is contractually required to handle it securely and to use it only for the specific purpose for which it was shared.

Categories of Third Parties Who May Receive Your Data

• Payment Partners (bKash, Nagad, Rocket, Upay, Visa, Mastercard, and Bangladesh banking partners): Your transaction data — including amounts, timestamps, and the payment method identifier — is shared with the relevant payment provider to process your deposit or withdrawal. Payment partners receive only the data necessary to execute and verify the transaction.
• Identity Verification Services: hbajer may use third-party KYC and identity verification providers to authenticate documents you submit during the verification process. These providers process your identity documents solely for verification purposes and are prohibited from using your data for any other purpose.
• Game Providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others): When you launch and play a game, certain technical identifiers — including a session token and your account reference — are shared with the game provider's platform to enable the game session. Game providers do not receive your full name, mobile number, or payment details from hbajer.
• IT Infrastructure and Cloud Service Providers: hbajer uses third-party hosting and cloud infrastructure providers to operate the platform. These providers may store data on servers located in one or more jurisdictions. All such providers are engaged under data processing agreements that require them to apply security standards equivalent to or greater than those applied by hbajer directly.
• Fraud Prevention and Security Services: hbajer uses specialised third-party tools to monitor for fraudulent activity, detect bot behaviour, and identify suspicious login attempts. These tools may process your IP address, device fingerprint, and behavioural data to generate a risk score for your account activity.
• Legal and Regulatory Authorities: hbajer will disclose your personal data to law enforcement agencies, regulatory bodies, or other competent authorities if required to do so by applicable law, by a valid court order, or in connection with the investigation of suspected financial crime or underage gambling. hbajer will disclose only the minimum data required to comply with the specific legal obligation.

International Data Transfers

Some of hbajer's third-party service providers may be located outside Bangladesh. Where your personal data is transferred internationally, hbajer ensures that appropriate safeguards are in place — such as standard contractual clauses or equivalent data transfer mechanisms — to protect your data to a standard no lower than that which applies within Bangladesh.

hbajer uses cookies and similar tracking technologies — including local storage and session tokens — to operate the platform, maintain your login session, and analyse how players use the site. This section explains exactly what cookies hbajer uses and what each one does.

What hbajer Does NOT Use Cookies For

hbajer does not use third-party advertising cookies, cross-site behavioural tracking pixels, or social media tracking tags on its platform. You will not be retargeted with hbajer advertisements on other websites as a result of cookies set during your visit to hbajer.club.

Managing Your Cookie Preferences

You may control and manage cookie settings through your web browser. Most modern browsers allow you to view, block, or delete cookies stored by specific websites. Please note that disabling essential session cookies will prevent you from logging in to your hbajer account, as these cookies are technically necessary for the platform to function. Disabling preference and analytics cookies will not affect your ability to use the platform but may reduce the quality of your experience.

hbajer retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or to comply with applicable legal, regulatory, or accounting obligations. The following retention periods apply to the main categories of personal data hbajer holds:

• Account and Identity Data: Retained for the lifetime of your active account, plus a minimum of 5 years following permanent account closure. This retention period supports compliance with anti-money laundering record-keeping obligations.
• Transaction Records: Retained for a minimum of 5 years from the date of each transaction in accordance with financial record-keeping requirements.
• KYC Documents: Retained for the duration of your account plus 5 years following account closure. Original document images are stored in encrypted form and access is restricted to authorised compliance personnel only.
• Support Communications: Retained for 3 years from the date of the last communication in the relevant thread, to support dispute resolution and service improvement.
• Technical and Usage Logs: Retained for 13 months from the date of generation, then automatically deleted or anonymised.
• Marketing Consent Records: Retained for as long as you hold an active account, and for 3 years following account closure or withdrawal of consent, whichever is later.

Storage Security Measures

hbajer applies a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and hbajer's servers.
• AES-256 encryption for sensitive data at rest, including KYC documents, financial records, and hashed account credentials.
• Role-based access controls ensuring that only authorised hbajer personnel with a legitimate need can access specific categories of personal data.
• Regular penetration testing and security audits of the hbajer platform infrastructure.
• Multi-factor authentication requirements for all hbajer internal systems that store or process personal data.
• Automated anomaly detection systems that flag unusual access patterns for immediate investigation.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, hbajer will notify affected players without undue delay and will take immediate steps to contain and remediate the breach.

As a player on the hbajer platform, you hold a defined set of rights in relation to the personal data hbajer holds about you. hbajer is committed to honouring these rights promptly and without unnecessary bureaucracy. To exercise any of the rights listed below, send a written request to [email protected] from the email address registered to your hbajer account, clearly stating which right you wish to exercise and providing sufficient information to allow hbajer to identify your account and fulfil your request.

• Right to Access: You have the right to request a copy of all personal data hbajer holds about you in a structured, commonly used, machine-readable format. hbajer will provide this within 30 days of receiving a valid access request.
• Right to Rectification: If any personal data hbajer holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may also update certain data directly through your account settings panel.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected and no overriding legal retention obligation applies. Please note that hbajer is required by law to retain certain categories of data — particularly financial and identity records — for defined periods following account closure, and erasure requests cannot override these obligations.
• Right to Restriction of Processing: You may request that hbajer restrict the processing of your personal data in specific circumstances — for example, while the accuracy of the data is being contested or while a complaint is under investigation.
• Right to Data Portability: You may request that hbajer provide your personal data in a portable format so that you can transfer it to another service provider. This right applies to data you have provided directly to hbajer and that is processed on the basis of your consent or a contractual necessity.
• Right to Object: You have the right to object to hbajer processing your data for direct marketing purposes at any time. You may also object to processing based on hbajer's legitimate interests, though in this case hbajer may continue processing if it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where hbajer processes your data on the basis of your consent — in particular for marketing communications — you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before the withdrawal. Manage your marketing preferences directly in your hbajer account settings.

hbajer reserves the right to update or amend this Privacy Policy at any time to reflect changes in platform features, data processing practices, applicable law, or regulatory guidance. The "Effective Date" displayed at the top of this page will be updated whenever a new version of the Privacy Policy is published.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights, the categories of data we collect, or the purposes for which we use your data — hbajer will notify registered players via their registered email address at least 14 days before the revised policy takes effect. For minor or administrative updates that do not materially affect player rights, the updated policy will be published on this page without advance notice.

Continued use of the hbajer platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the revised policy, you should cease using the hbajer platform and contact support to request account closure and data handling instructions.

The English-language version of this Privacy Policy published at hbajer.club/privacy-policy is the authoritative and legally binding version. Any translation or summary provided in another format is for informational convenience only.