54bd2 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1. Introduction

54bd2 ("the Platform", "we", "us", "our") operates the online casino and sports betting website at https://54bd2.io, serving players across Bangladesh. This Privacy Policy ("Policy") describes how 54bd2 collects, uses, stores, shares, and protects the personal information of individuals ("Player", "you", "your") who register for, access, or use any part of the 54bd2 platform, including its casino, sports betting, and any other services offered under the 54bd2 brand.

This Policy forms part of the overall legal framework governing your use of 54bd2, alongside the Terms & Conditions and the Responsible Gaming Policy. Defined terms used but not defined in this Policy carry the meanings assigned to them in the Terms & Conditions.

This Policy applies to all data processing activities carried out by 54bd2 in connection with the operation of the Platform, regardless of whether you are a registered player, a visitor browsing the website without an account, or a person who has previously held an account that has since been closed.

2. Data Controller

For the purposes of this Privacy Policy, 54bd2 is the data controller — that is, the entity responsible for determining the purposes and means of processing personal data collected through the Platform. Any questions, requests, or concerns relating to your personal data and how 54bd2 handles it should be directed to the 54bd2 data team at the contact address provided in Section 15 of this Policy.

Where 54bd2 engages third-party service providers who process personal data on its behalf — such as payment processors, identity verification services, and game suppliers — those providers act as data processors under contractual instruction from 54bd2. Their processing activities are governed by data processing agreements that require them to handle your data securely and only for the purposes specified by 54bd2.

3. Personal Data We Collect

54bd2 collects the following categories of personal data in the course of providing its services:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID.
• Date of birth (used to verify the 21+ age requirement).
• Residential address, including city, district, and postcode.
• Mobile phone number registered on your bKash, Nagad, Rocket, or Upay account.
• Email address used for account registration and communications.

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (National ID card, passport, or driving licence).
• Proof of address documents (utility bills, bank statements dated within 90 days).
• Selfie or live verification photographs where required.
• Payment method verification screenshots confirming your mobile wallet registration details.

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records including amounts, dates, and payment methods used (bKash, Nagad, Rocket, Upay, DBBL, bank transfers).
• Account balance history and bonus credit/debit records.
• Payment method identifiers (mobile wallet numbers, masked card numbers) — full card or wallet credentials are never stored by 54bd2.

3.4 Gaming Activity Data

• Game session logs including games played, bet amounts, outcomes, and session duration.
• Sports betting history including markets selected, stakes, and settlement outcomes.
• Bonus usage records and wagering requirement progress tracking.

3.5 Technical and Device Data

• IP address at the time of registration and each login.
• Device type, operating system, and browser version.
• Login timestamps and session activity logs.
• Geolocation data (country/region level, derived from IP address).

3.6 Communications Data

• Records of communications between you and 54bd2 support staff, including live chat transcripts, emails, and support tickets.
• Survey responses and feedback submissions where you have chosen to participate.

4. How We Collect Your Data

54bd2 collects personal data through the following channels:

• Direct submission by you: When you register an account, complete the KYC verification process, make a deposit or withdrawal, contact support, or respond to a survey, you directly provide personal data to 54bd2.
• Automated technical collection: When you access the Platform, your device and browser automatically transmit technical data (IP address, device type, session timestamps) that our servers log for security and operational purposes.
• Cookies and similar tracking technologies: 54bd2 uses cookies and local storage to maintain session state, remember your preferences, and analyse usage patterns. Full details are set out in Section 9 of this Policy.
• Third-party verification partners: When you complete KYC verification, our identity verification service provider processes your document data and returns a verification result to 54bd2.
• Payment processors: When you initiate a deposit or withdrawal, our payment processing partners (bKash, Nagad, Rocket, Upay, and banking partners) confirm transaction status and transmit relevant transaction data to 54bd2's systems.

5. How We Use Your Personal Data

54bd2 uses the personal data it collects for the following purposes:

54bd2 does not use your personal data for purposes other than those listed above without first obtaining your explicit consent or being required to do so by applicable law.

6. Legal Basis for Processing

54bd2 processes your personal data on one or more of the following legal bases, depending on the specific processing activity in question:

• Contractual necessity: Processing that is necessary to perform the contract between you and 54bd2 — for example, processing your deposit to credit your account balance, or verifying your identity before releasing a withdrawal.
• Legal obligation: Processing required to comply with applicable legal requirements — for example, retaining transaction records for the period required by anti-money laundering regulations, or conducting KYC verification as required by responsible gaming obligations.
• Legitimate interests: Processing that serves 54bd2's legitimate business interests where those interests are not overridden by your rights — for example, analysing gaming activity to detect fraud, monitoring login activity to identify unauthorised access, or improving Platform performance based on usage analytics.
• Consent: Processing activities that are not covered by the above bases — most notably, sending you marketing communications about promotions, new games, or special offers — are carried out only where you have given your explicit, informed, and freely given consent. You may withdraw consent for marketing at any time as described in Section 11.

7. Data Retention

54bd2 retains personal data for the periods described below. Once the applicable retention period has elapsed, data is securely deleted from our systems or anonymised so that it can no longer be linked to any individual player.

Where 54bd2 is involved in ongoing legal proceedings or a regulatory investigation, relevant data may be retained beyond the standard retention period until the matter is fully resolved.

8. Data Sharing and Third Parties

54bd2 does not sell your personal data. Data is shared only in the circumstances and with the categories of recipient described below:

8.1 Payment Processors

To process deposits and withdrawals, 54bd2 shares relevant transaction data with your chosen payment provider — bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, Visa, or Mastercard. These providers receive only the data necessary to execute the specific transaction.

8.2 Identity Verification Partners

To fulfil KYC obligations, 54bd2 may use third-party identity verification services who process your KYC documents under our instruction. These providers are contractually bound to use your data solely for verification purposes and to delete it upon completion of the verification process.

8.3 Game Suppliers

Game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive a session token and account identifier when you launch a game. Full personal identification data is not transmitted to game suppliers. Game logs are returned to 54bd2's systems for account crediting and responsible gaming monitoring purposes.

8.4 Legal and Regulatory Disclosure

54bd2 may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required to do so by applicable law, a valid legal order, or where 54bd2 has a good-faith belief that disclosure is necessary to prevent fraud, protect the safety of players, or defend 54bd2's legal rights.

8.5 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 54bd2's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material changes to how your data will be handled as a result.

9. Cookies and Tracking Technologies

54bd2 uses cookies and similar client-side storage technologies to operate the Platform effectively and to improve your experience. The following types of cookies are used:

• Essential cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in, security tokens that prevent cross-site request forgery, and load-balancing cookies. These cannot be disabled without preventing you from using the Platform.
• Functional cookies: Used to remember your preferences, such as your preferred language setting, last-visited game category, and responsible gaming display preferences. Disabling these cookies will mean that your preferences are not remembered between sessions.
• Analytics cookies: Used to collect anonymised or pseudonymised data about how the Platform is used — such as which pages are most visited, how long sessions last, and which features are used most frequently. This data is used solely to improve the Platform. Individual users are not identified through analytics data.

You can manage cookie preferences through your browser settings. Blocking essential cookies may prevent you from accessing certain parts of the Platform. For full details of specific cookies in use, contact 54bd2 support.

10. Your Data Rights

As a player whose personal data is processed by 54bd2, you have the following rights with respect to your personal data:

• Right of access: You may request a copy of the personal data 54bd2 holds about you. 54bd2 will provide this within 30 days of a valid request.
• Right of rectification: If any personal data 54bd2 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update basic account details directly within your account settings; for other corrections, contact support.
• Right of erasure: You may request that 54bd2 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent and no other legal basis applies, or where the data has been processed unlawfully. Note that this right is subject to 54bd2's legal retention obligations — some data cannot be deleted before the relevant retention period has elapsed.
• Right to restrict processing: You may request that 54bd2 temporarily restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to data portability: Where processing is based on your consent or on a contract, you may request that 54bd2 provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing that is carried out on the basis of 54bd2's legitimate interests. 54bd2 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent — principally, marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

11. Marketing Communications

54bd2 may send you promotional communications about bonuses, new games, seasonal offers (such as Eid promotions, Pohela Boishakh specials, BPL cricket season offers, and IPL-related promotions), and platform updates via email or SMS to the contact details registered on your account.

Marketing communications are sent only where you have provided explicit consent to receive them during account registration or at a later point through your account settings. You may withdraw consent at any time by:

• Clicking the unsubscribe link included in any marketing email you receive from 54bd2.
• Updating your communication preferences in your 54bd2 account settings.
• Contacting 54bd2 support at [email protected] (plain text — not a clickable link) with a request to be removed from marketing lists.

Withdrawal of marketing consent does not affect your ability to use the Platform or receive essential transactional communications such as deposit confirmations, withdrawal notifications, and security alerts. These operational messages are sent regardless of your marketing consent status as they are necessary for account management.

12. Data Security

54bd2 implements a range of technical and organisational measures to protect the personal data of all players against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 54bd2's servers.
• Encryption of sensitive data at rest, including KYC documents and financial records.
• One-way cryptographic hashing of all account passwords — 54bd2 staff cannot view your password in plain text.
• Role-based access controls ensuring that 54bd2 staff can access only the data necessary for their specific job function.
• Regular penetration testing and security audits by qualified third-party security professionals.
• Automated intrusion detection and anomalous login monitoring.
• Secure data centre infrastructure with physical access controls and environmental protections.

While 54bd2 takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to affect your rights and freedoms, 54bd2 will notify affected players without undue delay and will take all appropriate remedial steps.

13. Children and Minors

The 54bd2 platform is strictly intended for adults aged 21 and above. 54bd2 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the registration and KYC process to enforce this requirement.

If a parent or guardian becomes aware that a minor has accessed the 54bd2 platform or submitted personal data without authorisation, they should contact 54bd2 support immediately at [email protected] (plain text — not a clickable link). 54bd2 will investigate the matter promptly, close the account if the player is found to be underage, delete any personal data collected in connection with that account, and reverse any transactions associated with it to the extent possible.

14. Changes to This Privacy Policy

54bd2 reserves the right to update or revise this Privacy Policy at any time. When material changes are made — that is, changes that affect how your personal data is used or your rights in relation to that data — 54bd2 will provide advance notice to registered players via email or a prominent notice on the Platform before the revised Policy takes effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how 54bd2 handles your personal data. Continued use of the Platform following the effective date of a revised Privacy Policy constitutes acceptance of the changes.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or to how 54bd2 handles your personal data, please contact the 54bd2 data and privacy team using the details below:

For general account support unrelated to data privacy, the 54bd2 support team is available around the clock via the live chat feature accessible after logging in to your account.