Privacy Policy — bengawin

01 Data We Collect

bengawin collects personal data from you in several ways: directly when you register an account, indirectly through your use of the platform, and from third-party verification services during our Know Your Customer (KYC) process. The categories of data we collect are described below.

Registration Data

When you create an account on bengawin, we ask you to provide the following information:

• Full legal name — as it appears on your government-issued identity document.
• Date of birth — to verify that you meet the 18+ age requirement.
• Email address — used for account communications, transaction confirmations, and support correspondence.
• Bangladeshi mobile number — used for OTP verification and, where applicable, for bKash or Nagad payment authentication.
• Residential address — collected during the KYC verification stage. Players in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, and other cities across Bangladesh are all served.
• Username and encrypted password — for secure account access.

Identity Verification (KYC) Data

Before processing withdrawals above certain thresholds, or where our compliance team flags an account for review, bengawin may request copies of the following documents:

• Bangladesh National Identity Card (NID), passport, or driving licence.
• Utility bill, bank statement, or other proof of residential address (dated within the last 3 months).
• Payment method verification — for example, a screenshot of your bKash or Nagad transaction history to confirm that you are the account owner.

Transactional Data

bengawin maintains a record of all financial transactions associated with your account. This includes deposit amounts, withdrawal requests, payment methods used (bKash, Nagad, Rocket, Upay, Visa, Mastercard), transaction timestamps, and transaction reference numbers. This data is retained for anti-money-laundering (AML) compliance purposes.

Technical & Usage Data

When you access bengawin, our servers automatically collect certain technical information:

• IP address and approximate geographic location (city-level).
• Device type, operating system, and browser version.
• Pages visited, time spent on each page, and navigation paths through the platform.
• Game session data — games played, bet amounts, win/loss outcomes, and session duration.
• Login timestamps and logout events.

02 How We Use Your Data

bengawin processes your personal data strictly for the following legitimate purposes. We do not use your data for any purpose that is incompatible with the reason it was originally collected.

Where bengawin relies on your consent as the legal basis for processing — for example, to send you promotional emails about bonus offers or BPL season promotions — you may withdraw that consent at any time by contacting our support team or using the unsubscribe link in any marketing email we send you. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

03 Data Sharing & Disclosure

bengawin does not sell, rent, or trade your personal data to any third party for their own independent commercial purposes. We may, however, share your data with carefully selected service providers and in specific legally required circumstances, as set out below.

Service Providers

bengawin works with a limited number of third-party service providers who process data on our behalf, strictly under our instruction and in accordance with data processing agreements. These include:

• Payment processors — bKash, Nagad, Rocket, Upay, and card payment gateways process transaction data to execute deposits and withdrawals.
• Identity verification partners — third-party KYC platforms that assist with document validation and age verification checks.
• Game providers — studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive anonymised session data necessary to operate their games. They do not receive your full personal profile.
• Cloud infrastructure providers — data hosting and content delivery services that store and transmit platform data under strict security controls.
• Analytics platforms — receive anonymised, aggregated usage statistics only. No personally identifiable information is shared for analytics purposes.

Legal Disclosures

bengawin may be required to disclose personal data to law enforcement, regulatory authorities, or courts in Bangladesh or other applicable jurisdictions under the following circumstances:

• When required by a lawful court order, subpoena, or government directive.
• To comply with anti-money-laundering (AML) reporting obligations.
• To prevent, investigate, or report suspected fraud, criminal activity, or security breaches.
• To protect the rights, property, or safety of bengawin, its employees, or its players.

Business Transfers

In the event that bengawin undergoes a merger, acquisition, restructure, or sale of all or part of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will provide reasonable notice of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those described in this policy.

04 Cookies & Tracking

bengawin uses cookies and similar tracking technologies to operate the platform effectively. A cookie is a small text file stored on your device by your web browser when you visit a website. Cookies allow bengawin to recognise your browser across sessions and enable certain platform features.

Types of Cookies We Use

bengawin does not deploy third-party advertising cookies, cross-site tracking pixels, or behavioural profiling technologies. You may configure your browser to refuse all cookies or to alert you when cookies are being sent. Note that disabling essential cookies will prevent you from logging into your bengawin account and accessing most platform features.

05 Data Security Measures

Protecting the personal data of our players is a technical and organisational priority at bengawin. We implement layered security controls to guard against unauthorised access, accidental loss, disclosure, or destruction of data.

Technical Safeguards

• 256-bit SSL/TLS encryption on all data in transit between your device and bengawin servers.
• AES-256 encryption at rest for sensitive stored data including identity documents and payment references.
• Tokenisation of payment method identifiers — bKash wallet numbers, Nagad references, and card tokens are never stored in plain text.
• Multi-factor authentication for all internal staff accessing production systems.
• Intrusion detection systems monitoring server activity 24/7 for anomalous access patterns.
• Regular penetration testing conducted by independent security specialists.

Organisational Safeguards

• Access to personal data is granted on a strict need-to-know basis. Front-line support agents can access only the data necessary to resolve your query.
• All staff with access to personal data complete mandatory data protection training.
• Data processing agreements are in place with all third-party service providers.
• A formal incident response plan is maintained. In the event of a data breach that poses a risk to your rights, bengawin will notify affected players within 72 hours of becoming aware of the breach.

06 Data Retention Policy

bengawin retains personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or for as long as we are required to do so by applicable law. The following retention schedules apply:

When data reaches the end of its retention period, bengawin securely deletes or anonymises it in accordance with industry best practices. Deletion requests submitted by players will be processed within 30 days, subject to the legal retention obligations noted above. Where a legal obligation prevents immediate deletion, you will be informed of the specific reason and the earliest date by which deletion can occur.

07 Your Privacy Rights

As a registered player on bengawin, you have the following rights in relation to your personal data. These rights may be subject to certain legal exceptions, which will be explained if applicable when you submit a request.

• Right of Access: You may request a copy of the personal data bengawin holds about you at any time. We will provide this within 30 days of a verified request.
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You may also update certain account details (such as email address or mobile number) directly through your account settings.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data. We will action this request where there is no overriding legal obligation to retain the data. Note that AML-related data (transaction records and KYC documents) must be retained for a minimum of 5 years by law and cannot be deleted within that period.
• Right to Data Portability: You may request that bengawin provides your personal data in a structured, commonly used, machine-readable format (e.g., CSV or JSON), allowing you to transfer it to another service if you wish.
• Right to Restrict Processing: In certain circumstances (for example, while a data accuracy dispute is being resolved), you may request that bengawin restricts the processing of your data.
• Right to Object: You may object to the processing of your personal data where bengawin relies on legitimate interest as the legal basis. We will assess whether our legitimate interest overrides your objection and respond within 30 days.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time. This does not affect the lawfulness of any processing carried out prior to withdrawal.

08 Policy Updates & Contact

bengawin may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via the email address on file at least 14 days before the revised policy takes effect. The "Effective Date" displayed at the top of this page will be updated to reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically, particularly before providing any additional personal data or before taking advantage of new platform features. Your continued use of bengawin after a revised Privacy Policy takes effect constitutes your acceptance of the updated terms.

How to Contact bengawin About Privacy

If you have any questions, concerns, or complaints about how bengawin handles your personal data, or if you wish to exercise any of your privacy rights, please contact us using the details below. We are committed to resolving all privacy-related queries promptly and transparently.

• Email: support@bengawin (subject line: "Privacy Query" or "Privacy Rights Request")
• Response time: Within 4 hours for general queries; within 30 days for formal rights requests (all times Bangladesh Standard Time, BST UTC+6).
• Live chat: Available 24/7 via the bengawin platform for immediate assistance from our English-language support team.

bengawin takes all privacy complaints seriously. If you are not satisfied with our response to a privacy complaint, you may have the right to escalate your concern to the relevant data protection authority or seek independent legal advice.