bj111 Privacy Policy

§1 Who We Are

bj111 ("we", "us", "our", "the Company") is the operator of the online casino and sports betting platform accessible at bj-111.vu. We offer a range of gaming and wagering services to players in Bangladesh and other eligible territories, including casino games, live dealer tables, sports betting (including cricket), and related promotional services.

For the purposes of data protection, bj111 acts as the data controller in respect of personal data collected through the platform. This means we determine the purposes for which and the means by which your personal data is processed. We are committed to handling your data responsibly, lawfully, and in accordance with applicable data protection principles.

If you have any questions about this Privacy Policy or wish to exercise your rights in relation to your personal data, please contact our Data Protection team at the address provided in Section 15 of this document.

§2 Personal Data We Collect

bj111 collects personal data that is necessary for the provision of our services, fulfilment of legal and regulatory obligations, and improvement of the player experience. The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (used for mandatory age verification)
• Residential address, including city, division, and postal code
• Email address (used for account correspondence and notifications)
• Mobile phone number (used for verification and account security)
• Nationality and country of residence

2.2 Identity Verification Documents

• Copies of government-issued photo identification (National ID Card, passport, or driving licence)
• Proof of address documentation (utility bills, bank statements, or similar official documents dated within three months)
• Proof of payment method ownership (screenshots or statements where required)

2.3 Financial & Transaction Data

• Deposit and withdrawal history, including amounts, timestamps, and payment method details
• bKash, Nagad, Rocket, or Upay mobile wallet identifiers (account numbers used for transactions)
• Bank account numbers or card details where applicable (stored in tokenised form only)
• Account balance information and bonus credit history

2.4 Gaming & Betting Activity Data

• Game history, bet amounts, wager outcomes, and session durations
• Sports bets placed, including matches, markets, and odds selected
• Bonus activation and wagering requirement progress
• Self-exclusion, deposit limit, and responsible gaming tool usage history

2.5 Technical & Usage Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser information
• Session logs including login timestamps, page navigation paths, and feature interactions
• Cookie identifiers and similar tracking technology data (see Section 7)

2.6 Communications Data

• Records of correspondence between you and bj 111 customer support (live chat transcripts, email messages, phone call records if applicable)
• Your responses to surveys, feedback forms, or promotional questionnaires

§3 How We Collect Your Data

bj111 collects personal data through multiple channels and at different stages of your interaction with the platform:

3.1 Direct Collection from You

We collect data directly from you when you register an account, complete the KYC verification process, make deposits or withdrawal requests, contact customer support, participate in promotions, configure responsible gaming settings, or otherwise voluntarily provide information through forms or communication channels on our platform.

3.2 Automatic Collection via Technology

Certain data is collected automatically whenever you access or use the bj111 platform. This includes technical data (IP address, device type, browser version), usage data (pages visited, features used, session duration), and cookie data. These automatic collection mechanisms help us detect fraud, prevent unauthorised access, optimise platform performance, and personalise your experience.

3.3 Third-Party Sources

We may receive limited data from third parties where necessary to fulfil our obligations. This includes identity verification services used during KYC, payment processors (such as bKash, Nagad, Rocket, Upay, and banking partners) that confirm transaction completion, and Game Providers that report on your gaming activity within their software. We do not purchase marketing data or purchase third-party contact lists.

§4 How We Use Your Personal Data

bj111 uses your personal data for specific, legitimate purposes that are necessary for the operation of the platform and for compliance with our legal obligations. These purposes include:

§5 Legal Basis for Processing Your Data

Under applicable data protection law, bj111 must have a lawful basis for processing your personal data. We rely on the following legal grounds:

5.1 Performance of a Contract

Most of our data processing is necessary to fulfil our contractual obligations to you under the bj111 Terms & Conditions. This includes account creation, identity verification, transaction processing, game provision, and customer support. Without this processing, we cannot provide you with the services you have requested.

5.2 Legal Obligation

We process certain data because we are legally required to do so. This includes age verification (to prevent underage gambling), KYC checks (to comply with anti-money laundering regulations), transaction record retention (for tax and audit purposes), and responding to lawful requests from regulatory or law enforcement authorities.

5.3 Legitimate Interests

We process some data based on our legitimate business interests, provided that those interests are not overridden by your rights and freedoms. Legitimate interests include fraud prevention, security monitoring, platform optimisation, business analytics, and internal administrative purposes. Where we rely on legitimate interests, we conduct balancing assessments to ensure fairness.

5.4 Consent

In some cases, we process your data based on your explicit consent. This applies primarily to marketing communications and certain optional data collection activities (such as surveys or user research). You may withdraw your consent at any time, and withdrawal will not affect the lawfulness of processing conducted prior to withdrawal.

§6 Data Sharing & Third-Party Disclosure

bj111 does not sell your personal data to third parties for marketing purposes. However, we do share limited data with carefully selected third-party service providers and partners where necessary for the operation of the platform and fulfilment of legal obligations:

6.1 Game Providers

Your gaming activity data (bets placed, game sessions, outcomes) is shared with the Game Providers whose software you use (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others). This is necessary for them to deliver the games, generate outcomes, and report results back to bj111. Game Providers are bound by strict data processing agreements.

6.2 Payment Processors

When you make a deposit or request a withdrawal, we share necessary transaction data (amount, currency, payment method identifier) with our payment partners, including bKash, Nagad, Rocket, Upay, and banking partners. These processors require this information to complete your transaction. We never share more data than is necessary for the specific payment function.

6.3 Identity Verification Services

We use third-party identity verification providers to conduct KYC checks. These services receive the identity documents and personal details you submit during verification. They confirm your identity and age, then securely return the verification result to us. Verification providers do not retain your data beyond the completion of the check.

6.4 Customer Support Platforms

Our live chat and email support systems are hosted by third-party software providers. These platforms process your messages, contact details, and support history solely to facilitate customer service. Support platform providers are prohibited from using your data for any other purpose.

6.5 Regulatory & Law Enforcement Authorities

We may disclose your personal data to regulatory bodies, law enforcement agencies, or courts where we are legally required to do so, where necessary to comply with lawful requests, or where necessary to protect the rights, property, or safety of bj111, our players, or the public. We will only make such disclosures where legally justified and proportionate.

6.6 Business Transfers

In the event that bj111 is acquired by or merged with another company, or if we sell or transfer a substantial portion of our business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such change in ownership or control via email and via a prominent notice on the platform.

§7 Cookies & Tracking Technologies

Like most websites, bj111 uses cookies and similar technologies to enhance functionality, improve user experience, and gather analytics. A cookie is a small text file placed on your device by your browser when you visit our site. Cookies help us recognise your device on return visits and remember your preferences.

7.1 Types of Cookies We Use

• Essential Cookies: These cookies are strictly necessary for the operation of the platform. They enable core functionality such as login authentication, session management, and security features. The platform cannot function properly without these cookies.
• Performance & Analytics Cookies: These cookies collect aggregated, anonymised data about how visitors use the platform. They help us understand which pages are most popular, how long users spend on the site, and where errors occur. This data is used solely to improve platform performance.
• Functionality Cookies: These cookies remember your preferences and choices, such as language settings, display options, or favourited games. They enhance your experience by personalising the platform based on your past interactions.
• Marketing Cookies: These cookies track your activity across the platform to deliver relevant promotional content and measure the effectiveness of marketing campaigns. Marketing cookies are only deployed if you have consented to marketing communications.

7.2 Managing Cookies

You can manage or delete cookies through your browser settings. Most browsers allow you to refuse cookies entirely, delete existing cookies, or be notified when a new cookie is set. Please note that disabling essential cookies will prevent certain features of the platform from functioning correctly. Disabling analytics or marketing cookies will not impair core functionality but may reduce the personalisation of your experience.

For detailed instructions on managing cookies in your specific browser, please visit your browser's help documentation or settings menu.

§8 Data Retention

bj111 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal and regulatory obligations, and resolve disputes. Specific retention periods vary by data type:

• Account & Identity Data: Retained for the duration of your account's active status, plus seven (7) years following account closure, to comply with regulatory record-keeping obligations.
• Transaction Records: Retained for seven (7) years following the transaction date, as required by anti-money laundering and tax regulations.
• Gaming Activity Data: Retained for five (5) years following the session date, for audit, dispute resolution, and responsible gaming monitoring purposes.
• Customer Support Records: Retained for three (3) years following the date of the last communication, or longer if related to an ongoing dispute.
• Marketing Data: Retained until you withdraw consent or request deletion, whichever comes first.
• Technical Logs: Typically retained for twelve (12) months for security monitoring and troubleshooting purposes.

Once the applicable retention period has expired, we will securely delete or anonymise your personal data so that it can no longer identify you. In some cases, we may retain anonymised or aggregated data indefinitely for statistical and analytical purposes, as such data does not constitute personal data.

§9 Data Security

Protecting your personal data from unauthorised access, alteration, disclosure, or destruction is a top priority for bj111. We implement comprehensive technical and organisational security measures, including:

• 256-bit SSL Encryption: All data transmitted between your device and the bj111 platform is encrypted using industry-standard 256-bit SSL/TLS encryption, preventing interception or eavesdropping.
• Secure Data Storage: Personal data is stored on secure servers located in professional data centres with physical security controls, access restrictions, and environmental protections.
• Access Controls: Access to personal data is restricted to authorised bj111 personnel only, on a strict need-to-know basis. All employees with data access undergo background checks and receive regular data protection training.
• Password Protection: Account passwords are stored using strong, one-way cryptographic hashing algorithms. bj111 never stores passwords in plain text and cannot retrieve your original password.
• Two-Factor Authentication: Where available, we encourage players to enable two-factor authentication (2FA) for an additional layer of account security.
• Regular Security Audits: We conduct regular internal security reviews and engage independent third-party auditors to test our security infrastructure and identify vulnerabilities.
• Incident Response: We maintain a documented data breach response plan. In the unlikely event of a data breach affecting your personal information, we will notify you and relevant authorities in accordance with applicable legal requirements.

While we employ robust security measures, no method of electronic transmission or storage is entirely impenetrable. Players are responsible for maintaining the confidentiality of their account credentials and should immediately notify bj111 if they suspect unauthorised access to their account.

§10 Your Rights Over Your Personal Data

Under applicable data protection law, you have certain rights concerning your personal data held by bj111. These rights include:

10.1 Right of Access

You have the right to request a copy of the personal data we hold about you. We will provide this information in a structured, commonly used, and machine-readable format. You may request access by contacting our Data Protection team (see Section 15). We will respond within thirty (30) days.

10.2 Right to Rectification

If any of your personal data held by bj111 is inaccurate or incomplete, you have the right to request that we correct or complete it. You can update most of your personal details directly through your account settings. For changes requiring verification (such as name or date of birth), please contact customer support.

10.3 Right to Erasure

You have the right to request deletion of your personal data in certain circumstances, such as when the data is no longer necessary for the purposes for which it was collected, or when you withdraw consent. Please note that we may be legally required to retain certain data (such as transaction records) even after you request deletion, in which case we will inform you of the legal basis for continued retention.

10.4 Right to Restrict Processing

You have the right to request that we temporarily restrict the processing of your personal data in certain situations, such as when you contest the accuracy of the data or when you have objected to processing based on legitimate interests while we verify whether our interests override yours.

10.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another service provider without hindrance from bj111. This right applies where processing is based on consent or contract and is carried out by automated means.

10.6 Right to Object

You have the right to object to processing of your personal data where we rely on legitimate interests as the legal basis. If you object, we must stop processing unless we can demonstrate compelling legitimate grounds that override your interests. You have an absolute right to object to processing for direct marketing purposes.

10.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal. You can withdraw marketing consent by clicking the unsubscribe link in any email or by adjusting your account settings.

10.8 Right to Lodge a Complaint

If you believe that bj111 has processed your personal data unlawfully or has failed to respect your data protection rights, you have the right to lodge a complaint with a supervisory data protection authority in your jurisdiction.

To exercise any of these rights, please contact our Data Protection team using the details provided in Section 15 below. We may request proof of identity to verify your request and prevent unauthorised disclosure of personal data.

§11 Children's Privacy

The bj111 platform is strictly intended for use by individuals aged eighteen (18) years or older. We do not knowingly collect, process, or retain personal data from anyone under the age of 18. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. Any funds held in an account found to belong to a minor will be forfeited.

If you are a parent or guardian and believe that your child has provided personal data to bj111, please contact our support team immediately so that we can take appropriate action.

§12 Third-Party Links & Services

The bj111 platform may contain links to third-party websites or services (such as payment provider portals or Game Provider sites). This Privacy Policy applies only to bj111 and does not cover the privacy practices of any third party. We are not responsible for the data collection, use, or security practices of external sites. We encourage you to review the privacy policies of any third-party site you visit.

When you interact with third-party services through the bj111 platform (such as initiating a bKash payment), you may be redirected to that third party's site or application, where their own privacy policy will apply. bj111 is not responsible for how third parties handle your data once you leave our platform.

§13 International Data Transfers

bj111 operates an online platform accessible from multiple countries. Your personal data may be transferred to, stored in, and processed in jurisdictions outside of Bangladesh, including jurisdictions that may not offer the same level of data protection as Bangladeshi law. Where we transfer data internationally, we ensure that appropriate safeguards are in place, such as:

• Standard contractual clauses approved by relevant data protection authorities;
• Adequacy decisions recognising certain jurisdictions as providing adequate data protection;
• Binding corporate rules for transfers within corporate groups;
• Explicit consent from you for the specific transfer.

All third-party service providers we engage are required to implement appropriate technical and organisational measures to protect your data, regardless of their location.

§14 Changes to This Privacy Policy

bj111 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or business operations. Where changes are material and affect how we use your personal data, we will notify you in advance via email to your registered address or via a prominent notice on the platform.

Your continued use of the bj111 platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data. The current version of this Privacy Policy is always available at bj-111.vu/privacy-policy, and the "Last Updated" date at the top of this document indicates when the most recent changes were made.

§15 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way bj111 handles your personal data, please contact our Data Protection team. We are committed to addressing your enquiries promptly and professionally.

Email: [email protected] (plain text — not a clickable link)

Subject Line: For data protection enquiries, please use the subject line "Data Protection Request" to ensure your message is routed to the appropriate team.

Live Chat: Available 24/7 within your bj111 account dashboard for general support. For specific data protection requests, email is preferred to ensure secure handling.

We aim to respond to all data protection requests within thirty (30) days of receipt. If your request is particularly complex or we have received multiple requests from you, we may extend this period by an additional sixty (60) days, in which case we will inform you of the extension and the reasons for it.