45db Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1 Introduction & Scope

This Privacy Policy ("Policy") describes how 45db ("we", "us", "our") collects, uses, stores, and protects the personal data of individuals ("you", "your", "player") who access or use the 45db online betting and casino platform available at https://45db.io (the "Platform").

This Policy applies to all personal data processed in connection with your registration, use of the Platform, and any communications you have with 45db's support team. It covers data collected through the website, any associated mobile interface, and direct communications by email or messaging.

This Policy should be read alongside the 45db Terms & Conditions and the Responsible Gaming policy, both of which are incorporated by reference. By accessing the Platform or submitting a registration, you acknowledge that you have read and accepted this Policy.

45db serves English-speaking players primarily located in Bangladesh. All personal data processing described in this Policy relates to this player base and is carried out in accordance with applicable data protection principles including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, and integrity.

2 Data We Collect

45db collects the following categories of personal data in connection with your account and use of the Platform:

• Identity Data: Your full legal name, date of birth, nationality, and government-issued identification numbers (national ID, passport, or driving licence number) as provided during registration or KYC verification.
• Contact Data: Your email address, mobile phone number, and current residential address in Bangladesh.
• Payment Data: The mobile number associated with your bKash, Nagad, Rocket, or Upay account; transaction reference numbers; and deposit and withdrawal amounts in BDT. We do not store full payment credentials — payment processing is handled securely by the relevant MFS provider.
• Transaction Data: A complete record of all deposits, withdrawals, bets placed, game sessions, bonus credits, and account balance changes.
• Identity Verification Documents: Scanned or photographed copies of identity and address documents submitted during KYC verification.
• Technical Data: Your IP address, device identifiers, browser type and version, operating system, and network information collected automatically when you access the Platform.
• Usage Data: Information about how you interact with the Platform, including pages visited, games played, session duration, features accessed, and navigation paths.
• Communications Data: Records of your contact with 45db support, including live chat transcripts, emails, and any formal complaints or dispute submissions.

We do not intentionally collect special category data (such as health information, religious beliefs, political opinions, or biometric data) and request that you do not submit such information through any channel on the Platform.

3 How We Collect Your Data

45db collects personal data through the following channels and mechanisms:

• Direct submission: Data you provide when completing the registration form, submitting KYC documents, making a deposit or withdrawal request, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically via server logs, cookies, and similar technologies when you browse or interact with the Platform.
• Third-party verification: Identity and address information confirmed or supplemented by KYC verification service providers acting on our behalf.
• Payment partners: Transaction confirmation data received from bKash, Nagad, Rocket, and Upay following a completed deposit or withdrawal transaction.
• Game providers: Bet settlement data, game session logs, and round outcomes received from certified game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, as part of normal platform operation.

4 Legal Basis for Processing

45db processes your personal data only where a valid legal basis exists. The primary legal bases on which we rely are as follows:

• Contractual necessity: Processing required to perform our obligations to you under the Terms & Conditions — including operating your account, processing payments, settling bets, and providing customer support.
• Legal obligation: Processing necessary to comply with applicable legal and regulatory requirements, including anti-money laundering (AML) checks, age verification obligations, and financial record-keeping requirements.
• Legitimate interests: Processing carried out in pursuit of 45db's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, security monitoring, platform improvement, and responsible gaming analytics.
• Consent: Where we send you optional marketing communications or use non-essential cookies, we will ask for your explicit consent beforehand. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 How We Use Your Data

45db uses the personal data we collect for the following specific purposes:

• To create, verify, and maintain your 45db player account.
• To verify your age and identity in accordance with our KYC obligations (minimum age: 21 years).
• To process deposits and withdrawals in Bangladeshi Taka via bKash, Nagad, Rocket, and Upay.
• To manage your participation in sports betting markets, casino games, crash games, slots, and other Platform products.
• To apply and settle bonuses, free bet credits, and promotional offers in accordance with applicable terms.
• To detect, investigate, and prevent fraudulent activity, collusion, money laundering, and other prohibited conduct.
• To monitor your gaming behaviour for responsible gaming purposes and to provide or action self-exclusion and limit-setting tools.
• To respond to support queries, process complaints, and resolve disputes.
• To send transactional communications (account statements, withdrawal confirmations, security alerts) and, where consent is given, promotional offers.
• To comply with our legal and regulatory obligations, including responding to lawful requests from competent authorities.
• To analyse Platform usage patterns, improve user experience, and test new features and products.

We do not use your personal data to make fully automated decisions that produce significant legal effects without human review. Where automated tools are used for fraud scoring or responsible gaming flagging, a human review step is included before any material action is taken on your account.

6 Sharing Your Data

45db does not sell, rent, or trade your personal data to any external party for commercial purposes. We share data only in the following limited and necessary circumstances:

• KYC and identity verification providers: Third-party service providers engaged to verify the identity and age of players as part of our account verification process. These providers process data solely on our instruction and under confidentiality obligations.
• Payment processors: bKash, Nagad, Rocket, and Upay receive the minimum data necessary to execute deposit and withdrawal transactions on your behalf. Each MFS provider operates under its own privacy terms and regulatory framework.
• Game studios and content providers: Certified game studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) receive session and bet data necessary to operate the games you play. This data sharing is governed by strict data processing agreements.
• IT infrastructure and security providers: Hosting providers, CDN operators, and cybersecurity service providers engaged to maintain the availability and security of the Platform. All operate under binding contractual data protection obligations.
• Legal and regulatory authorities: We may disclose personal data to competent law enforcement, regulatory, or judicial authorities where required to do so by applicable law, court order, or regulatory obligation, or where we reasonably believe disclosure is necessary to prevent financial crime.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 45db's business, personal data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

7 Payment Data & MFS Partners

Given the nature of 45db's payment infrastructure — which relies exclusively on Bangladeshi mobile financial services — the following specific provisions apply to the handling of payment-related personal data:

When you initiate a deposit or withdrawal, you provide 45db with the mobile phone number registered to your bKash, Nagad, Rocket, or Upay account. This number is used solely to route the transaction and to confirm ownership of the payment account. We verify that this number matches the mobile number registered on your 45db player account to prevent third-party payment processing.

45db does not store your full MFS PIN, wallet password, or any other authentication credential for these services. Full payment credentials remain with the respective MFS provider and are never transmitted to or stored by 45db. Transaction confirmation data (reference numbers, amounts, timestamps) is retained as part of your transaction history for account management and regulatory compliance purposes.

All transactions are denominated in Bangladeshi Taka (BDT). The minimum deposit is ৳200 and the minimum withdrawal is ৳500. No foreign currency conversion is applied, and no international payment routing is involved in standard player transactions.

8 Cookies & Tracking

45db uses cookies and similar browser-based technologies on the Platform for the following purposes:

• Essential cookies: Required for the Platform to function correctly. These include session cookies that maintain your logged-in state, security tokens that protect against cross-site request forgery, and load-balancing cookies. These cannot be disabled without impacting Platform functionality.
• Functional cookies: Used to remember your preferences such as language settings, display options, and recently accessed game categories. These improve your experience but are not strictly necessary.
• Analytics cookies: Used to collect aggregated, anonymised data about how players navigate and use the Platform. This helps us identify areas for improvement and optimise the user experience. We use internal analytics only — we do not embed third-party advertising analytics tools.

45db does not use advertising cookies, behavioural profiling cookies, or third-party tracking pixels that connect your activity on our Platform to external advertising networks or social media platforms.

You can manage or delete cookies through your browser's privacy settings at any time. Disabling essential cookies may affect your ability to log in or use certain features of the Platform. Disabling functional or analytics cookies will not prevent you from accessing or using the Platform.

9 Data Retention

45db retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following specific retention periods:

• Active account data: Retained for the full duration of your active 45db account relationship and for a period of five years following account closure, to satisfy financial record-keeping and AML regulatory requirements.
• KYC identity documents: Retained for a minimum of five years from the date of verification or from account closure, whichever is later, in accordance with applicable anti-money laundering obligations.
• Transaction records: Retained for five years from the date of the transaction, in line with financial regulatory requirements applicable to online payment processing.
• Support and communications records: Retained for three years from the date of the last communication, to support dispute resolution and quality assurance processes.
• Technical and usage data: Retained in anonymised or aggregated form for up to 24 months for platform analytics purposes.

Where you submit a valid erasure request following account closure, 45db will delete or anonymise personal data that falls outside the mandatory retention categories described above within 30 days of receiving your request.

10 Security Measures

45db takes the security of your personal data seriously and applies a layered set of technical and organisational measures to protect it against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL 256-bit encryption applied across all Platform pages and data transmissions between your device and our servers.
• Encryption of sensitive data fields (including identity document data and payment references) at rest in our database infrastructure.
• Role-based access controls that restrict access to personal data to authorised personnel with a documented business need.
• Regular security audits, vulnerability assessments, and penetration testing of Platform infrastructure.
• Intrusion detection and real-time anomaly monitoring on all production systems.
• Staff training on data protection obligations and incident response procedures.
• Contractual data protection obligations imposed on all third-party service providers who process personal data on our behalf.

Notwithstanding these measures, no internet-based system can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 45db will take prompt action to contain the breach and will notify affected players without undue delay in accordance with applicable data breach notification obligations.

You are also responsible for maintaining the security of your 45db account. Keep your login credentials confidential, use a strong unique password, and contact support immediately at [email protected] if you suspect any unauthorised access to your account.

11 Your Data Rights

As a registered 45db player, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team at [email protected] with your account details and a clear description of your request. We will acknowledge your request within 5 business days and respond in full within 30 days.

• Right of access: You may request a copy of all personal data 45db holds about you, along with information about how it is being used and with whom it has been shared.
• Right to rectification: You may request correction of any personal data that is inaccurate, incomplete, or out of date.
• Right to erasure: Subject to our legal retention obligations, you may request deletion of your personal data following account closure. We will delete all non-mandatorily retained data within 30 days of a valid erasure request.
• Right to restriction: You may request that we restrict processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or object to its processing.
• Right to data portability: You may request a machine-readable copy of the personal data you have provided to us, for the purpose of transferring it to another service provider.
• Right to object: You may object to processing based on legitimate interests at any time. We will assess your objection and cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (for example, marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.

12 Children & Minors

45db's services are strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from any individual under the age of 21, and we do not permit persons under 21 to register or use a 45db account under any circumstances.

If you are a parent or guardian and you believe that a minor has provided personal data to 45db or has registered an account on the Platform, please contact our support team immediately at [email protected]. We will promptly investigate the matter, close any identified underage account, delete the associated personal data, and return any deposits made to the originating payment method.

45db employs age verification controls at the point of registration and may conduct additional age checks at any stage of the account lifecycle. These controls are part of our broader commitment to responsible gaming and the protection of vulnerable individuals.

13 International Data Transfers

45db's primary player base is located in Bangladesh and the majority of our operational and data processing infrastructure is maintained to serve this market. However, as an internationally operating platform, some personal data may be processed by our service providers (including game studios and KYC verification providers) whose infrastructure is located outside Bangladesh.

Where personal data is transferred outside Bangladesh, 45db takes appropriate steps to ensure that an adequate level of data protection is maintained throughout the transfer. These steps include executing data processing agreements with relevant service providers that incorporate data protection provisions consistent with recognised international standards.

45db does not transfer personal data to any jurisdiction that does not provide adequate protections without implementing appropriate safeguards. If you would like further information about the specific safeguards applicable to any particular international data transfer, please contact our support team.

14 Changes to This Policy

45db reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing practices, or the nature of our services. The "Last Reviewed" date displayed in the hero section of this page will be updated whenever a revision is made.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — we will notify registered players by email or via an in-platform notice at least 14 days before the revised Policy takes effect. Non-material changes (such as typographical corrections or clarifications that do not alter the substance of any clause) may be published immediately without advance notice.

Your continued use of the Platform following the effective date of any revised Policy constitutes your acknowledgement of and agreement to the updated terms. If you do not accept the revised Policy, you must cease using the Platform and contact support to initiate account closure.

15 Contact & Data Requests

For any questions, concerns, or formal requests relating to this Privacy Policy or the personal data 45db holds about you, please contact our support team using the details below. All data-related requests are handled by trained personnel and responded to within the timeframes specified in Clause 11 above.

• Email: [email protected] (plain text — not a clickable link)
• Subject line for data requests: "Privacy Request — [Your Registered Email Address]"
• Support hours: 24/7, Bangladesh Standard Time (BST, UTC+6)
• Response target: Acknowledgement within 5 business days; full response within 30 days

For responsible gaming concerns, self-exclusion requests, or deposit limit adjustments, please visit our dedicated Responsible Gaming page, which provides detailed guidance and direct access to all available player protection tools.