09bte Privacy Policy
At 09bte, your privacy is not an afterthought — it is built into the architecture of our platform. This Privacy Policy explains precisely what personal data we collect from Bangladesh players, why we collect it, how we use and store it, and the rights you hold over your own information.
Table of Contents
- 1 Introduction & Scope
- 2 Data We Collect
- 3 How We Use Your Data
- 4 Legal Basis for Processing
- 5 Data Sharing & Disclosure
- 6 Cookies & Tracking
- 7 Data Retention
- 8 Security Measures
- 9 Your Privacy Rights
- 10 Children & Minors
- 11 Changes to This Policy
- 12 Contact & Data Enquiries
Introduction & Scope
This Privacy Policy ("Policy") is issued by 09bte ("we", "us", "our") and governs the collection, use, storage, disclosure, and protection of personal data belonging to all users who access or interact with the 09bte platform — including the website at 09bte.io, any associated mobile interfaces, and all related services (collectively, the "Platform").
This Policy applies to all players who have registered an account with 09bte, visitors who browse the Platform without an account, and any individual who communicates with 09bte through our support channels. It covers personal data collected from players located in Bangladesh and is consistent with internationally recognised data protection principles.
By accessing the Platform or creating an account, you acknowledge that you have read, understood, and accepted the terms of this Policy. If you do not agree with any part of this Policy, you must discontinue use of the Platform and contact us to request account closure.
Scope Note: This Policy applies exclusively to data processed by 09bte. It does not extend to third-party websites, game studios, or payment providers whose own privacy policies govern their respective data handling practices. We recommend reviewing the privacy documentation of any third party you interact with via the Platform.
Data We Collect
09bte collects personal data through several channels: directly from you when you register or interact with the Platform, automatically through your use of the Platform, and occasionally from third-party sources such as payment providers and identity verification services. The categories of personal data we collect are set out below.
Registration & Account Data
When you create a 09bte account, we collect the information you provide, including:
- Full legal name
- Date of birth (to verify you are aged 21 or above)
- Email address
- Mobile phone number (used for account verification and, where opted in, promotional messaging)
- Residential address
- Username and encrypted password
Identity Verification (KYC) Data
To comply with our anti-money laundering obligations and to confirm player eligibility, we may request and retain copies of:
- National Identity Card (NID) or passport
- Proof of address documents (utility bill, bank statement issued within the last three months)
- Selfie or live photo for biometric comparison with the submitted identity document
Financial & Transaction Data
When you make deposits or withdrawals, we collect transaction records including the payment method used (bKash, Nagad, Rocket, Upay, Visa, Mastercard), transaction reference numbers, amounts in BDT, and timestamps. We do not store complete card numbers; card data is tokenised by our payment processing partners.
Technical & Usage Data
We automatically collect certain technical data when you access the Platform:
- IP address and approximate geolocation (country/city level)
- Browser type and version
- Device type, operating system, and screen resolution
- Pages visited, session duration, and click-path data
- Referral URL (the page or link that directed you to 09bte)
Communications Data
When you contact our customer support team — via live chat, email to [email protected], or any other channel — we retain a record of the communication, including the content of messages, timestamps, and the resolution outcome. This data is used to maintain service quality and to resolve disputes.
Sensitive Data: 09bte does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data beyond KYC identity verification, or health data. If any such data is incidentally provided to us, it will be deleted promptly unless required for a legal purpose.
How We Use Your Data
09bte processes personal data for specific, clearly defined purposes. We do not use personal data for any purpose incompatible with the purposes for which it was originally collected. The table below summarises our primary processing activities:
| Purpose | Data Used |
|---|---|
| Account creation & management | Registration data, device data |
| Identity verification (KYC/AML) | KYC documents, date of birth, address |
| Processing deposits & withdrawals | Financial & transaction data |
| Delivering game & betting services | Account data, usage data |
| Fraud prevention & security monitoring | IP address, usage data, transaction data |
| Customer support | Communications data, account data |
| Responsible gaming monitoring | Usage data, transaction data, account data |
| Personalised promotions (where consented) | Account data, usage data, transaction history |
| Platform analytics & improvement | Technical data, usage data (aggregated) |
| Legal & regulatory compliance | All categories as required by applicable law |
Where 09bte uses your personal data for direct marketing purposes — such as sending promotional emails or SMS messages about bonuses, tournaments, or new game releases — we will only do so where you have opted in to receive such communications. You may withdraw your marketing consent at any time through your account settings or by contacting support.
Legal Basis for Processing
09bte processes personal data under the following legal bases, consistent with widely recognised data protection frameworks:
- Contractual necessity: Processing required to fulfil our contractual obligations to you, including operating your account, processing transactions, and delivering gaming services.
- Legal obligation: Processing necessary to comply with applicable laws and regulations, including anti-money laundering (AML) requirements, know-your-customer (KYC) rules, and responses to lawful requests from competent authorities.
- Legitimate interests: Processing carried out for 09bte's legitimate business interests, such as fraud detection, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your fundamental rights and freedoms.
- Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications. You may withdraw this consent at any time without detriment to your continued use of the Platform.
Where processing is based on legitimate interests, 09bte conducts an internal balancing test to confirm that the processing does not disproportionately affect your privacy rights. You may request details of this assessment by contacting us at [email protected].
Data Sharing & Disclosure
09bte does not sell your personal data to third parties. We share personal data only in the limited circumstances described below, and solely to the extent necessary for the stated purpose.
Service Providers & Technology Partners
We share data with carefully selected third-party service providers who assist in operating the 09bte platform. These include payment processing partners (such as the infrastructure underlying bKash, Nagad, Rocket, and card networks), identity verification services, cloud hosting providers, and analytics platforms. All such providers are contractually bound to process data solely on our instructions and to maintain appropriate security standards.
Game Studio Partners
When you play a game supplied by a third-party studio — including Pragmatic Play, Evolution Gaming, PG Soft, JILI, Spribe, Microgaming, NetEnt, or Ezugi — limited technical data (such as a pseudonymous player ID and session token) is transmitted to that studio to facilitate gameplay. No directly identifying information such as your name, email, or payment details is shared with game studios.
Legal & Regulatory Authorities
09bte may disclose personal data to competent legal or regulatory authorities where required to do so by law, court order, or other binding legal instrument. In such cases, we will disclose only the minimum data necessary to satisfy the legal requirement, and — where permitted — will notify you of the disclosure.
Business Transfers
In the event of a merger, acquisition, or sale of all or substantially all of 09bte's assets, personal data held by 09bte may be transferred to the acquiring entity. We will provide reasonable notice of any such transfer and will ensure the acquiring entity commits to processing your data in a manner consistent with this Policy.
No Sale of Data: 09bte will never sell, rent, or trade your personal data to third-party advertisers, data brokers, or marketing networks. Your data is used exclusively for the purposes outlined in this Policy.
Cookies & Tracking Technologies
09bte uses cookies and similar tracking technologies to operate the Platform, maintain your session state, and gather analytics data that helps us improve the user experience for Bangladesh players. The following categories of cookies may be set when you visit the Platform:
| Cookie Type | Purpose | Retention |
|---|---|---|
| Strictly Necessary | Session management, login authentication, CSRF protection | Session / up to 24 hours |
| Functional | Language preference, game lobby layout, responsible gaming reminder settings | Up to 12 months |
| Analytics | Page-view tracking, session duration, feature engagement (data aggregated and pseudonymised) | Up to 24 months |
| Marketing | Conversion tracking for referral and affiliate channels (only where you have consented) | Up to 30 days |
Strictly necessary cookies cannot be disabled as they are essential to core Platform functionality. You may manage your preferences for functional, analytics, and marketing cookies through your browser settings. Note that disabling certain cookies may impair the performance or features of the Platform.
09bte does not use cookies to track your activity on third-party websites unrelated to the Platform, and does not participate in cross-site behavioural advertising networks.
Data Retention
09bte retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following indicative retention periods apply:
- Active account data: Retained for the duration of your account and for a minimum of five years following account closure, to satisfy AML record-keeping requirements.
- KYC verification documents: Retained for a minimum of five years from the date of verification or from account closure, whichever is later.
- Transaction records: Retained for a minimum of five years from the date of each transaction.
- Customer support communications: Retained for three years from the date of the final message in each support thread, unless the thread relates to an ongoing dispute or legal matter.
- Technical and usage data (server logs): Retained for up to 12 months, after which logs are either purged or fully anonymised.
- Marketing consent records: Retained for the duration of your consent and for one year following withdrawal, to document compliance.
Where 09bte is under a legal obligation to retain data beyond these periods — for example, in connection with ongoing litigation, a regulatory investigation, or a court order — the data will be retained until that obligation is extinguished.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that makes re-identification impossible.
Security Measures
09bte employs a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, and destruction. Our key technical and organisational security measures include:
- 256-bit SSL/TLS encryption: All data transmitted between your device and the 09bte servers is encrypted in transit using industry-standard 256-bit SSL/TLS certificates. No data is transmitted in plain text.
- Data encryption at rest: Sensitive personal data stored on 09bte servers — including KYC documents, identity fields, and payment tokens — is encrypted at rest using AES-256 encryption.
- Access controls: Access to personal data within 09bte's infrastructure is strictly role-based. Only personnel with a legitimate operational need are granted access, and all access is logged and audited.
- Password hashing: Account passwords are never stored in plain text. They are processed through a computationally intensive one-way hashing algorithm with a unique per-account salt.
- Two-factor authentication (2FA): 09bte offers 2FA for all player accounts and requires it for administrative access to internal systems.
- Penetration testing & vulnerability management: The Platform undergoes regular security assessments by qualified security professionals to identify and remediate vulnerabilities.
- Incident response: 09bte maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights and freedoms, we will notify affected individuals without undue delay.
Your Role in Security: While 09bte maintains robust technical safeguards, the security of your account also depends on the strength of your password and the confidentiality of your login credentials. Please review the account security guidance in our Terms & Conditions for best practice recommendations.
Your Privacy Rights
As a 09bte account holder, you hold the following rights in relation to your personal data. To exercise any of these rights, please submit a written request to [email protected] with the subject line "Privacy Rights Request". We will acknowledge receipt within 48 hours (Bangladesh Standard Time, UTC+6) and respond substantively within 30 calendar days.
- Right of access: You have the right to request a copy of all personal data that 09bte holds about you, together with information about how it is being used.
- Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it. You may also update certain data fields 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, where you have withdrawn your consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to overriding legal retention obligations — for example, KYC and transaction records that must be retained under AML rules cannot be erased on request.
- Right to restrict processing: You may request that 09bte restrict the processing of your data in certain circumstances, such as while the accuracy of the data is under dispute, or while an objection to processing is being considered.
- Right to data portability: Where processing is based on your consent or on contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
- Right to object: You have the right to object to processing carried out on the basis of legitimate interests, and to object to direct marketing at any time. Upon receipt of a valid marketing opt-out, we will cease all marketing communications within five business days.
- Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time through your account settings or by contacting support. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.
09bte will not charge a fee for exercising your privacy rights unless requests are manifestly unfounded, repetitive, or excessive. In such cases, we may charge a reasonable administrative fee or decline to act, and we will inform you of the reason.
Children & Minors
The 09bte platform is strictly restricted to persons aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is conducted at the point of registration and again during the KYC process to confirm that all account holders meet the minimum age requirement.
If 09bte becomes aware that personal data has been collected from a person under the age of 21 — whether through a fraudulent registration, a parental notification, or an internal audit — the account will be immediately suspended, all associated data will be deleted in accordance with our data retention procedures, and any deposited funds will be returned to the payment method on record after identity verification of the rightful account owner.
21+ Strictly Enforced: If you are a parent or guardian and believe that a minor has created a 09bte account, please contact us immediately at [email protected]. We will act on all such reports within 24 hours.
Changes to This Policy
09bte reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the structure of our business. When a material update is made, we will revise the effective date displayed at the top of this document and, where the change is significant, notify registered account holders by email to their address on record.
Your continued use of the Platform following the publication of an updated Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how 09bte protects your personal data.
Archived versions of this Policy are available on request by contacting [email protected].
Contact & Data Enquiries
For any questions, requests, or concerns relating to this Privacy Policy or to the personal data that 09bte holds about you, please contact our data protection team through the following channel:
Privacy Enquiries: [email protected] — please use the subject line "Privacy Rights Request" for formal data subject requests, or "Privacy Enquiry" for general questions about this Policy.
We aim to acknowledge all privacy-related emails within 48 hours (Bangladesh Standard Time, UTC+6) and to provide a full response within 30 calendar days. Complex requests involving large volumes of data or legal assessment may require additional time; in such cases, we will inform you of the extended timeline and the reason for the delay.
For general customer support — including account queries, deposit and withdrawal assistance, and technical issues — please use the live chat feature available on the Platform or contact [email protected] with your account details.
How 09bte Safeguards Your Privacy
Six concrete measures that define the 09bte approach to protecting the personal data of every Bangladesh player on our platform.
256-bit SSL Encryption
Every byte of data exchanged between your device and the 09bte servers travels through a 256-bit SSL encrypted tunnel. Your credentials and payment details are never exposed in transit.
No Data Selling — Ever
09bte operates a strict no-sale policy on personal data. Your information is never sold to advertisers, data brokers, or marketing networks. We share only what is necessary, with bound partners only.
Full Data Subject Rights
Access, rectify, erase, restrict, port, or object to your data — all seven privacy rights are honoured. Submit a request to [email protected] and receive a substantive response within 30 days.
Defined Retention Periods
Data is kept only as long as legally required or operationally necessary. When the retention period expires, records are securely deleted or fully anonymised — no indefinite data warehousing.
Role-Based Access Controls
Internal access to player data is strictly need-to-know. Every access event is logged and audited. No 09bte staff member can query personal data outside their assigned operational role.
Regular Security Audits
The 09bte platform undergoes periodic penetration testing and vulnerability assessments by qualified security professionals to ensure our defences remain effective against evolving threats.
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