ase44 Privacy Policy

1 Personal Data We Collect

ase44 collects personal data from you in the course of providing our services. The categories of personal data we may collect include, but are not limited to, the following:

Identity & Contact Data:

• Full legal name as it appears on your official identity document;
• Date of birth;
• Residential address, city, and postcode (Bangladesh-based players: district and division);
• Email address;
• Mobile phone number (used for account verification and two-factor authentication).

Identity Verification (KYC) Data:

• National Identity Card (NID) number and scanned copy;
• Passport number and copy, where submitted;
• Driver's licence copy, where submitted;
• Proof of address documents (utility bills, bank statements dated within 90 days);
• Selfie or live photograph taken during identity verification.

Financial Data:

• bKash, Nagad, Rocket, or Upay mobile banking account numbers registered to your ase44 account;
• Bank account details (account number, bank name, branch) where bank transfers are used;
• Deposit and withdrawal transaction history;
• Account balance and bonus balance records.

Technical & Usage Data:

• IP address and geolocation data at login;
• Device type, operating system, browser type and version;
• Session timestamps, login and logout records;
• Pages visited, games played, bets placed, and features accessed;
• Clickstream data and navigation patterns within the Platform.

Communication Data:

• Records of correspondence with ase44 customer support via email or live chat;
• Details of complaints or enquiries submitted to ase44;
• Responses to voluntary surveys or feedback forms.

2 How We Collect Your Data

ase44 collects personal data through several distinct channels:

• Direct submission: When you register an account, complete KYC verification, make a deposit or withdrawal, claim a bonus, or contact our support team, you provide data to us directly.
• Automated collection: When you access the ase44 Platform, our servers and analytics systems automatically collect technical data including your IP address, device identifiers, browser characteristics, and session behaviour data.
• Cookies and tracking technologies: ase44 uses cookies, pixel tags, and similar technologies to collect data about your interactions with the Platform. Please refer to Section 8 of this Policy for full details on our cookie practices.
• Third-party verification providers: Where you submit identity documents for KYC, our third-party verification partner may provide us with the results of their document authenticity checks and identity matching scores.
• Payment processors: When you transact via bKash, Nagad, Rocket, Upay, or a supported bank, our payment processing partners confirm transaction status and may share reference data required to credit or debit your ase44 balance.

3 Purpose of Data Processing

ase44 processes your personal data only for specific, documented purposes. The table below sets out the primary purposes for which we use your data:

ase44 does not use your personal data for any purpose not listed above without first obtaining your explicit consent or having a valid legal basis to do so.

4 Legal Basis for Processing

ase44 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing is required to perform the contract between you and ase44, including account registration, payment processing, gameplay, and customer support;
• Legal obligation: Processing is required to comply with applicable laws and regulatory obligations, including KYC verification, AML compliance, and fraud prevention requirements;
• Legitimate interests: Processing is necessary for the legitimate interests of ase44, including platform security, fraud detection, responsible gaming monitoring, and service improvement, provided these interests are not overridden by your fundamental rights;
• Consent: Where you have given explicit consent for a specific processing activity, such as receiving marketing communications or accepting non-essential cookies. You may withdraw your consent at any time by contacting [email protected] or updating your account preferences.

5 Data Sharing & Disclosure

ase44 may share your personal data with the following categories of third parties, strictly for the purposes outlined in Section 3:

• Payment processors: bKash, Nagad, Rocket, Upay, and supported banking partners require identity and transaction data to process your deposits and withdrawals securely;
• KYC and identity verification providers: Third-party services that process your identity documents and biometric data to verify your age and identity as required by our compliance obligations;
• Game content providers: Software providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive a session token and anonymised player identifiers to deliver game content; they do not receive your full personal profile;
• IT and cloud infrastructure providers: Hosting, database, and content delivery providers who process data on our behalf under strict data processing agreements;
• Fraud prevention and cybersecurity services: Specialist providers who assist in detecting and preventing fraudulent account activity, bonus abuse, and unauthorised access;
• Legal and regulatory authorities: Where required by law, court order, or a valid regulatory demand, ase44 may disclose data to law enforcement agencies, financial intelligence units, or other competent authorities in Bangladesh or applicable jurisdictions.

All third-party service providers engaged by ase44 are contractually required to process personal data only in accordance with ase44's instructions and to maintain appropriate technical and organisational security measures.

6 Data Retention

ase44 retains personal data only for as long as is necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

The following general retention guidelines apply:

• Active account data: Retained for the duration of your active account plus a minimum of 5 years following account closure, to satisfy AML record-keeping obligations;
• KYC verification documents: Retained for a minimum of 5 years from the date of submission or account closure, whichever is later;
• Financial transaction records: Retained for a minimum of 5 years following the transaction date, in line with financial record-keeping standards;
• Customer support correspondence: Retained for 3 years from the date of the most recent interaction;
• Technical and usage data: Retained for up to 24 months, after which it is anonymised or deleted;
• Marketing consent records: Retained for the duration of your opt-in consent and for 2 years following withdrawal of consent.

When personal data is no longer required and retention obligations have been satisfied, ase44 will securely delete or irreversibly anonymise it so that it can no longer be associated with you as an individual.

7 Security Measures

ase44 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and ase44 servers;
• Encryption of sensitive data fields at rest within our database infrastructure;
• Role-based access controls ensuring that only authorised personnel with a defined operational need can access personal data records;
• Comprehensive audit logging of all internal access to player account data;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• Two-factor authentication (2FA) available for player accounts to add an additional layer of login security;
• Automated anomaly detection systems that flag unusual login patterns, IP address changes, and suspicious transaction behaviour;
• Dedicated incident response procedures in the event of a data security breach.

While ase44 takes every reasonable precaution to protect your personal data, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately at [email protected] if you suspect any unauthorised access to your account.

8 Cookies & Tracking Technologies

ase44 uses cookies and similar tracking technologies to operate the Platform effectively, remember your preferences, analyse traffic patterns, and deliver a personalised experience. The categories of cookies used on ase44.io are as follows:

You may manage your cookie preferences by updating your browser settings to refuse or delete cookies. Please note that disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from logging in or completing transactions. For specific requests about cookie data, contact [email protected].

9 Your Data Rights

As a user of the ase44 Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please submit a written request to [email protected]. ase44 will respond to all valid requests within 30 days of receipt.

• Right of Access: You have the right to request a copy of the personal data ase44 holds about you, along with information about how it is being processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. You may update certain details directly through your account settings;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal retention obligations;
• Right to Restriction: You may request that ase44 restrict processing of your data in certain circumstances, for example while an accuracy dispute is being resolved;
• Right to Data Portability: Where processing is based on consent or contract, you may request that we provide your data in a structured, machine-readable format;
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes;
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

Please note that certain rights may be limited where ase44 has a legal obligation to retain data or where exercising the right would adversely affect our AML compliance obligations. ase44 will explain the reason for any limitations when responding to your request.

10 Third-Party Services & External Links

The ase44 Platform integrates with third-party services, including game content providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) and payment partners (bKash, Nagad, Rocket, Upay). While ase44 carefully selects partners who maintain strong data protection standards, each third party operates under its own privacy policy and ase44 does not control or accept liability for their independent data practices.

The ase44 Platform does not contain hyperlinks to external third-party websites beyond those necessary for payment processing and game delivery. Where any such link exists, navigating to an external site means you are subject to that site's own privacy policy from the point of departure.

ase44 requires all third-party data processors to enter into written data processing agreements that impose obligations consistent with the standards set out in this Privacy Policy. These agreements require third parties to process data only on ase44's instructions and to implement appropriate security measures.

11 Minors & Age Verification Policy

ase44 employs age verification controls at the point of registration and during KYC review to prevent underage individuals from accessing the Platform. If ase44 discovers or has reasonable grounds to believe that personal data has been collected from a person under the age of 21, the following steps will be taken immediately:

• The relevant account will be suspended and access to the Platform revoked;
• Any deposited funds will be returned to the source payment method upon identity confirmation of the account holder;
• All personal data associated with the underage account will be deleted from ase44's systems once the return of funds has been confirmed and any required regulatory notification has been made;
• Where applicable, the matter will be reported to relevant child protection or regulatory authorities.

If you are a parent or guardian and believe that a minor in your care has registered on the ase44 Platform, please contact us immediately at [email protected] so that we can take appropriate action without delay.

12 Amendments to This Privacy Policy

ase44 reserves the right to update, modify, or replace any part of this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we provide. The effective date shown at the top of this document will be updated whenever a revision is made.

Where changes are material — for example, where we introduce a new purpose for processing your data or change the categories of third parties with whom your data is shared — ase44 will provide you with advance notice by email to your registered address, or by a prominent notice on the Platform, no less than 14 days before the changes take effect.

Your continued use of the ase44 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised policy, you must discontinue use of the Platform and may request account closure in accordance with the ase44 Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the ase44 data protection team at [email protected]. We aim to respond to all enquiries within 5 business days (Bangladesh Standard Time, UTC+6).