hlbaee Privacy & Data Protection Policy
This Privacy Policy explains exactly what personal information hlbaee collects from players across Bangladesh, how that data is used, stored, and protected, and the rights every registered User holds over their own data. We are committed to keeping your information secure and transparent.
hlbaee ("we", "us", "our") is committed to protecting the privacy of every individual who visits, registers on, or interacts with the hlbaee platform at hlbaee.com. This Privacy Policy sets out in plain, formal English exactly what personal data we collect about you, the purposes for which we process it, the legal grounds on which we rely, how long we retain it, who we may share it with, and the rights you hold as the individual to whom that data relates.
This policy applies to all Users of the hlbaee platform, including visitors who browse the site without registering, individuals who create an Account, and registered players who actively wager on casino games or sports betting markets. By accessing any part of the hlbaee platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how hlbaee handles personal data as described here, please discontinue use of the platform and contact to request Account closure if applicable.
hlbaee serves a community of players primarily located across Bangladesh, including Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, and Mymensingh. Where data protection obligations arise under laws applicable to the operation of the hlbaee platform, we comply with those obligations in full. We do not knowingly collect personal data from individuals under the age of 18.
1. Data We Collect
hlbaee collects personal data across several categories depending on how you interact with the platform. The table below summarises what we collect and when.
| Category | Data Points Collected | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, government-issued ID number, nationality | Account registration and KYC verification |
| Contact Data | Email address, mobile phone number, residential address | Account registration; may be updated at any time |
| Financial Data | bKash/Nagad/Rocket/Upay wallet number, bank account details, transaction history, deposit and withdrawal amounts in BDT (৳) | When a deposit or withdrawal is initiated |
| Account Data | Username, encrypted password, account balance, bonus history, wagering history, session logs | Continuously while Account is active |
| Technical Data | IP address, device type, browser type and version, operating system, screen resolution, time zone (Bangladesh Standard Time, UTC+6) | Each session visit to the platform |
| Usage Data | Pages visited, games played, time spent per session, click-path, search terms used within the platform | Continuously via server logs and analytics |
| Communications Data | Support chat transcripts, emails sent to hlbaee, feedback submissions | When you contact the hlbaee support team |
| KYC Documents | Scanned or photographed copies of national ID, passport, driving licence, and proof of address documents | Prior to first withdrawal or when requested by compliance |
hlbaee does not collect sensitive personal data such as racial or ethnic origin, religious beliefs, political opinions, biometric data, or health information, except where a User voluntarily discloses such information in a support communication or where it is strictly necessary for responsible gaming assessments (for example, where a User discloses a gambling-related health concern when requesting self-exclusion).
2. How We Use Your Data
hlbaee processes your personal data only for defined, legitimate purposes. The following describes each processing purpose in full.
We use Identity Data and Contact Data to create and maintain your hlbaee Account, verify your identity at registration and during KYC, authenticate your login sessions, and communicate essential account-related notices such as password resets, security alerts, and policy updates.
We use Financial Data to process deposits made via bKash, Nagad, Rocket, Upay, and supported bank transfers, to verify the source of funds where anti-money-laundering obligations require it, and to execute withdrawal requests to your nominated payment method in Bangladeshi Taka (৳).
We use Account Data and Usage Data to operate the hlbaee casino and sports betting platform, present personalised game recommendations, maintain your wagering history and balance, credit your daily bonus entitlement, and resolve technical issues that affect your gameplay experience.
We use Technical Data, Account Data, and Financial Data to detect and prevent fraudulent activity, identify duplicate accounts, investigate suspicious transaction patterns, and protect the integrity of the hlbaee platform and its genuine user community.
We use Account Data and Usage Data to monitor for indicators of problem gambling behaviour — such as rapid stake escalation, session duration, and self-exclusion requests — and to apply the deposit limits, session reminders, and self-exclusion tools available through the hlbaee responsible gaming programme.
Where you have provided explicit consent, we use Contact Data and Usage Data to send you information about the hlbaee daily bonus, seasonal promotions (such as Eid, Pohela Boishakh, and BPL cricket season offers), and other platform news. You may withdraw your marketing consent at any time by contacting .
We use aggregated and anonymised Usage Data and Technical Data to analyse how Users interact with the hlbaee platform, identify performance bottlenecks, test new features, and make data-driven improvements to the user experience. Anonymised analytics data does not identify any individual User.
We process personal data as required to fulfil our legal obligations, including anti-money-laundering (AML) checks, Know Your Customer (KYC) requirements, response to lawful requests from competent authorities, and maintenance of financial records for the periods mandated by applicable law.
3. Legal Basis for Processing
Every processing activity carried out by hlbaee rests on one of the following recognised legal grounds.
- Contractual Necessity: Processing required to deliver the service you have contracted for — including Account management, payment processing, game delivery, and withdrawal execution — is carried out on the legal basis that it is necessary for the performance of the contract between you and hlbaee.
- Legal Obligation: Processing required to comply with applicable legal obligations — including AML screening, KYC verification, and retention of financial records — is carried out on the legal basis that it is necessary for hlbaee's compliance with those obligations.
- Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics is carried out on the legal basis of hlbaee's legitimate interests in operating a safe, fair, and commercially viable platform, provided those interests are not overridden by your individual rights and freedoms.
- Consent: Processing for direct marketing communications is carried out on the basis of your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.
4. Data Sharing & Disclosure
hlbaee does not sell your personal data. We share data only where strictly necessary and only with parties bound by appropriate data protection obligations.
hlbaee may share your personal data with the following categories of third-party recipients, each of whom is contractually required to handle your data in accordance with applicable data protection standards:
- Payment Service Providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, and Sonali Bank receive the minimum financial data required to process your deposit or withdrawal transaction. These providers operate under their own regulatory frameworks and privacy policies.
- Game Technology Providers: Providers including Pragmatic Play, Evolution Gaming, Spribe, NetEnt, Microgaming, and Ezugi receive your Account identifier and session tokens necessary to deliver their games within the hlbaee platform environment. These providers do not receive your full identity or financial data.
- Identity Verification Services: Third-party KYC and identity verification services receive your identity documents and personal details solely for the purpose of conducting legally required verification checks.
- Fraud Prevention & AML Services: Specialist fraud detection and anti-money-laundering screening providers may receive transaction data and technical identifiers to assist in detecting suspicious activity.
- IT Infrastructure & Hosting Providers: The technical infrastructure that hosts the hlbaee platform is operated by service providers who may process personal data incidentally as part of providing hosting, backup, and security services. All such providers are bound by data processing agreements.
- Legal & Regulatory Authorities: Where we receive a lawful request from a competent authority — including law enforcement agencies, financial intelligence units, or courts — we will disclose the personal data specified in that request to the extent required by law. We will notify you of such a disclosure where we are legally permitted to do so.
hlbaee does not share your personal data with advertising networks, data brokers, or any third party for the purpose of serving behavioural advertising to you on other websites or platforms. Your data stays within the hlbaee ecosystem except where necessary for the purposes described above.
5. Cookies & Tracking Technologies
hlbaee uses cookies and similar tracking technologies to operate the platform, maintain your session, and gather anonymised usage analytics.
A cookie is a small text file placed on your device when you visit a website. Cookies allow the hlbaee platform to recognise your browser across sessions, maintain your login state, remember your preferences, and collect analytics data about how the platform is used. The following categories of cookies are used on the hlbaee platform:
Strictly Necessary Cookies
Required for the platform to function. These include session authentication cookies that keep you logged in, security tokens that protect against cross-site request forgery, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
Preference Cookies
Store your platform preferences such as language setting (English), display preferences, and last-visited game category. These improve your experience on return visits but are not required for core functionality and can be cleared via your browser settings.
Analytics Cookies
Collect anonymised data about how visitors use the hlbaee platform — including pages visited, session duration, device type, and navigation paths. This data is aggregated and does not identify individual Users. It is used solely to improve platform performance and content.
Security & Fraud Cookies
Used by hlbaee's fraud prevention systems to detect and flag suspicious session behaviour, bot activity, and account takeover attempts. These cookies are part of our commitment to keeping your account and funds secure.
You can control and delete cookies through your browser settings. Most modern browsers allow you to refuse all or certain categories of cookies, delete existing cookies, and be notified when new cookies are set. Please note that disabling strictly necessary cookies will prevent you from logging in to your hlbaee Account or using core platform features.
In addition to cookies, hlbaee may use web beacons (also known as pixel tags) in promotional emails sent with your consent. These allow hlbaee to determine whether a marketing email has been opened. You can prevent web beacon tracking by disabling image loading in your email client.
6. Data Retention
hlbaee retains your personal data only for as long as necessary to fulfil the purpose for which it was collected or to comply with legal obligations.
The retention periods below apply to each category of personal data held by hlbaee. Where multiple retention obligations apply to the same data, the longer period governs.
| Data Category | Retention Period | Basis |
|---|---|---|
| Identity & KYC Documents | 5 years from Account closure | AML and regulatory compliance obligations |
| Financial Transaction Records | 5 years from the date of each transaction | Financial record-keeping obligations |
| Account & Wagering History | Duration of Account plus 2 years after closure | Contractual obligation and dispute resolution |
| Support Communications | 3 years from the date of communication | Legitimate interest in resolving disputes |
| Technical & Usage Logs | 13 months from collection | Platform security and fraud prevention |
| Marketing Consent Records | Duration of consent plus 2 years | Demonstrating lawful basis for marketing |
| Self-Exclusion Records | Indefinitely (or until formal request to remove) | Responsible gaming obligations |
Upon expiry of the applicable retention period, hlbaee will securely delete or irreversibly anonymise the personal data in question. Where data is anonymised rather than deleted, the resulting anonymised data set contains no information that could be used to identify you and falls outside the scope of this Privacy Policy.
7. Your Data Rights
As a User of the hlbaee platform, you hold a number of rights with respect to your personal data. These rights are described below together with guidance on how to exercise them.
Right of Access
You may request a copy of all personal data hlbaee holds about you at any time. We will respond within 30 days of receiving a verified request.
Right to Rectification
You may ask us to correct any inaccurate or incomplete personal data we hold about you. Minor contact details can be updated directly in your Account settings; identity data changes require a support request with supporting documentation.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent, or where processing was unlawful. This right is subject to legal retention obligations.
Right to Restriction
You may ask hlbaee to restrict processing of your data — for example, while a rectification request is being assessed, or where you contest the legal basis for processing.
Right to Object
You may object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming purposes. hlbaee will assess whether its legitimate interests override your objection.
Right to Portability
Where processing is based on your consent or contractual necessity and is carried out by automated means, you may request your data in a structured, machine-readable format for transfer to another service.
Right to Withdraw Consent
Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time by contacting . Withdrawal does not affect prior lawful processing.
Self-Exclusion Right
You may request a self-exclusion period of between 24 hours and 12 months at any time for responsible gaming reasons. Contact to activate self-exclusion on your Account immediately.
To exercise any of the rights described above, please submit a written request to from the email address registered to your hlbaee Account. For security purposes, we may ask you to verify your identity before processing a rights request. We aim to respond to all verified rights requests within 30 calendar days of receipt. Where a request is complex or we receive a high volume, we may extend this period by a further 30 days and will notify you accordingly.
Rights requests are free of charge. If a request is manifestly unfounded or excessive — particularly where it is repetitive in nature — hlbaee reserves the right to charge a reasonable administrative fee or decline to act on the request, in either case providing written reasons for that decision.
8. Data Security Measures
hlbaee implements layered technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction.
SSL / TLS Encryption
All data transmitted between your device and the hlbaee platform is encrypted using industry-standard SSL/TLS protocols. This protects your login credentials, financial data, and personal information from interception during transmission.
Encrypted Data Storage
Personal data stored in hlbaee's databases is encrypted at rest. Passwords are hashed using industry-standard one-way hashing algorithms and are never stored in plain text. KYC documents are stored in access-controlled, encrypted storage environments.
Access Controls
Access to personal data within the hlbaee organisation is restricted on a strict need-to-know basis. Staff members who handle personal data receive regular privacy and security training, and all data access is logged and audited.
Vulnerability Management
The hlbaee platform undergoes regular security assessments and penetration testing. Critical vulnerabilities are patched on an expedited basis. A responsible disclosure process is in place for security researchers who identify potential issues.
Fraud Detection Systems
Real-time fraud detection monitors all Account activity for indicators of account takeover, payment fraud, and multi-account abuse. Suspicious activity triggers automated alerts and human review by the hlbaee security team.
Incident Response
hlbaee maintains a documented data breach response procedure. In the event of a breach that poses a risk to your rights, we will notify affected Users without undue delay, including a description of the nature of the breach and the steps taken to mitigate it.
While hlbaee takes comprehensive measures to protect your personal data, no internet-based platform can guarantee absolute security against all possible threats. You also have a responsibility to keep your hlbaee Account credentials secure — use a strong, unique password, do not share your login details with any third party, and contact immediately if you suspect unauthorised access to your Account.
9. Policy Updates & Contact
hlbaee reviews this Privacy Policy regularly and will notify registered Users of any material changes before they take effect.
hlbaee 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 features and services offered on the platform. The "Last Updated" date at the top of this page will be revised whenever a change is made.
For material changes — those that meaningfully affect how we process your personal data or the rights available to you — hlbaee will notify registered Users by email to the address associated with their Account at least 14 days before the revised policy takes effect. Your continued use of the hlbaee platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated terms.
For minor or clarificatory changes that do not affect the substance of our data processing commitments, hlbaee may update this page without prior individual notification. We encourage you to review this Privacy Policy periodically to stay informed of how we protect your data.
Contact the hlbaee Privacy Team
If you have any questions, concerns, or requests relating to this Privacy Policy or to how hlbaee processes your personal data, please contact the privacy team directly:
- Email: (subject line: "Privacy Enquiry")
- Support Hours: 24 hours a day, 7 days a week
- Response Languages: English and Bengali
- Serving Users Across: Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, and Mymensingh
- Target Response Time: Within 2 business days for general privacy enquiries; within 30 days for formal rights requests
hlbaee is committed to resolving all privacy-related concerns fairly and transparently. If you feel that your concern has not been adequately addressed after contacting the support team, you retain the right to escalate the matter to a competent data protection authority or seek independent legal advice.
Your Privacy Is Protected at hlbaee
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