habje Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected, processed, and stored by habje in connection with the operation of the habje platform at habje.io, including its website, mobile-optimised site, and any associated applications or services (collectively, "the Platform").

This Policy applies to all individuals who interact with habje, including registered players, visitors who browse the Platform without registering, and individuals who contact our support team. By accessing the Platform or creating an account, you acknowledge that you have read and understood this Privacy Policy.

This Policy should be read alongside habje's Terms & Conditions and Responsible Gaming Policy, both of which contain additional provisions relevant to how habje manages player accounts and data. All three documents form part of the overall agreement between you and habje.

2. Data Controller Information

habje acts as the data controller for all personal data collected through the Platform. As data controller, habje determines the purposes and means by which your personal data is processed. Our designated data protection contact can be reached at the email address listed in Section 15 of this Policy.

habje operates as an offshore betting platform. Players are responsible for determining whether the use of habje's services is lawful in their own jurisdiction. For players accessing habje from Bangladesh, habje acknowledges the unique market context and applies appropriate care to the handling of personal data consistent with internationally recognised data protection standards.

3. Personal Data We Collect

The categories of personal data habje collects depend on how you interact with the Platform. The following table summarises the main data categories and examples of specific data points within each category:

habje does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data beyond what is strictly required for age and identity verification purposes.

4. How We Collect Your Data

habje collects personal data through three primary channels:

• Directly from you — when you complete the registration form, submit KYC documents, make a deposit or withdrawal, contact our support team, or update your account preferences.
• Automatically from your device — when you visit the Platform, our systems automatically record technical and usage data including your IP address, device identifiers, browser information, and navigation behaviour. This is standard practice for all online platforms and is necessary for security monitoring and service optimisation.
• From third-party service providers — habje receives data from identity verification partners when you complete KYC, from payment processors when a transaction is confirmed or declined, and from fraud detection services that flag unusual account activity. We may also receive limited data from third-party analytics providers to understand how players discover and navigate the Platform.

5. Legal Basis for Processing

habje processes your personal data under one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing required to fulfil the agreement between you and habje — including creating your account, processing bets, handling deposits and withdrawals, and providing customer support.
• Legal obligation: Processing required to comply with applicable anti-money-laundering (AML) obligations, age verification requirements, financial record-keeping duties, and cooperation with law enforcement requests.
• Legitimate interests: Processing carried out for habje's legitimate business interests where those interests are not overridden by your rights — including fraud detection, platform security, responsible gaming monitoring, and service improvement analytics.
• Consent: Processing of data for optional purposes where you have given clear, informed consent — primarily for marketing communications via email, SMS, or push notification. Consent may be withdrawn at any time.

6. How We Use Your Data

habje uses the personal data it collects for the following purposes:

• Creating and managing your habje account, including authentication and session management
• Verifying your identity and age as part of the KYC process, in particular confirming that you are aged 21 or above
• Processing deposits from and withdrawals to bKash, Nagad, Rocket, Upay, SureCash, Visa, and Mastercard
• Settling bets, crediting winnings, and maintaining an accurate transaction history in your account
• Providing 24/7 customer support and handling complaints and disputes
• Detecting and preventing fraud, money laundering, multi-accounting, and other forms of prohibited conduct
• Monitoring and enforcing responsible gaming obligations, including tracking deposit limits and self-exclusion status
• Sending you transactional communications such as deposit confirmations, withdrawal notifications, and security alerts — these are not marketing communications and cannot be opted out of while your account is active
• Sending promotional emails, SMS messages, or push notifications about bonuses, special offers, and new features — only if you have given explicit consent to receive such communications
• Analysing aggregate, anonymised usage data to improve the Platform's design, performance, and game selection
• Complying with applicable law, responding to regulatory enquiries, and cooperating with law enforcement authorities when legally required

7. Data Sharing and Third Parties

habje does not sell, rent, or trade your personal data. We share data only in the following limited circumstances:

• Payment processors: bKash, Nagad, Rocket, Upay, SureCash, and card processing partners receive only the data necessary to complete and verify your transactions. habje does not store full card numbers.
• Identity verification providers: Third-party KYC partners receive identity document images and facial photographs solely for the purpose of age and identity verification. These partners are contractually prohibited from using your data for any other purpose.
• Game suppliers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive an anonymised player identifier to manage game sessions and return results. They do not receive your name, contact details, or financial data.
• Fraud and security providers: habje uses specialist fraud detection and security monitoring services. These partners process technical and usage data under strict data processing agreements and are prohibited from retaining or repurposing your data.
• Legal and regulatory authorities: habje may disclose personal data to law enforcement, regulatory bodies, or courts when legally compelled to do so or when disclosure is necessary to protect the safety of habje's platform, staff, or other players.
• Business transfers: In the event of a merger, acquisition, or sale of habje's assets, personal data held by habje may be transferred to the successor entity. You would be notified of any such transfer and your rights would be preserved.

8. Cookies and Tracking Technologies

habje uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing identifiers. They cannot be disabled without preventing access to the Platform.
• Functional cookies: Remember your preferences such as language selection, last login method, and display settings. Disabling these cookies means your preferences will not be saved between sessions.
• Analytics cookies: Collect anonymised data about how visitors use the Platform — which pages are visited most, where users drop off, and how long sessions last. This data is used in aggregate form only to improve the Platform. habje uses privacy-respecting analytics tools and does not share this data with advertising networks.
• Security cookies: Help detect and prevent fraudulent activity, bot access, and account takeover attempts. These cookies record device fingerprint information that is compared against known fraud patterns.

You may adjust your cookie preferences through your browser settings. Please be aware that disabling strictly necessary cookies will prevent you from logging in to or using habje. Disabling analytics cookies will not affect your ability to use the Platform.

9. Data Retention

habje retains personal data for the following periods, after which data is securely deleted or irreversibly anonymised:

• Active account data: Retained for the full duration your account is open and active on habje.
• Closed account data: Identity, financial, and transaction data is retained for a minimum of 5 years following account closure to meet anti-money-laundering record-keeping requirements. After 5 years, data is deleted unless an ongoing legal obligation requires further retention.
• Support communications: Email and chat records are retained for 3 years from the date of the conversation to support dispute resolution and quality assurance.
• Technical and usage logs: Server logs and session data are retained for a maximum of 12 months, after which they are deleted from live systems. Anonymised aggregate analytics data may be retained indefinitely.
• Marketing consent records: Records of your consent or opt-out for marketing communications are retained for as long as your account is active, plus 2 years, to demonstrate compliance.
• Self-exclusion records: Where a player has self-excluded, a record of that self-exclusion status is retained permanently to prevent re-registration during the exclusion period and to support responsible gaming obligations.

10. Your Data Rights

You hold the following rights in relation to the personal data habje holds about you. To exercise any of these rights, please contact habje using the details in Section 15:

• Right of access: You may request a copy of all personal data habje holds about you. habje will respond within 30 days of receiving a valid request.
• Right to rectification: You may request the correction of any inaccurate or incomplete personal data. For most account details, corrections can be made directly through your account settings.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where the processing is unlawful. Note that habje may be required to retain certain data for legal compliance purposes even after an erasure request.
• Right to restrict processing: You may request that habje stops actively processing your data in certain circumstances — for example, while a dispute about data accuracy is being resolved.
• Right to data portability: You may request a copy of the personal data you have provided to habje in a structured, commonly used, machine-readable format.
• Right to object: You may object to habje processing your data on the basis of legitimate interests. You may also object to direct marketing at any time, with immediate effect.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

habje will respond to all data rights requests within 30 calendar days. In complex cases, habje may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

11. Children and Minors

habje's services are strictly restricted to individuals aged 21 and above. habje does not knowingly collect personal data from any person under the age of 21. Age verification is applied at the registration stage and reinforced through the KYC process.

If habje discovers that an account has been registered by a person under 21, the account will be closed immediately, all deposits will be returned in full, and any data collected will be deleted in accordance with our responsible gaming obligations. If you believe a minor may have registered on habje, please contact our support team immediately so that we can investigate and take appropriate action.

12. Security Measures

habje employs a layered security architecture to protect your personal data from unauthorised access, disclosure, alteration, and destruction. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your browser or device and habje's servers
• Encrypted storage for all sensitive data at rest, including identity documents and financial records
• Role-based access controls ensuring that only authorised habje staff members can access specific categories of player data, limited to what is strictly necessary for their role
• Two-factor authentication (2FA) available to all players and required for all habje staff accessing internal systems
• Continuous intrusion detection and monitoring via automated security tooling that flags anomalous access patterns in real time
• Regular penetration testing conducted by independent security specialists to identify and remediate vulnerabilities before they can be exploited
• Secure data destruction protocols ensuring that all data scheduled for deletion is irrecoverably erased from habje's systems and backup infrastructure

Despite these measures, no system connected to the internet is completely immune to security risks. habje cannot provide an absolute guarantee against all potential breaches. In the event of a data breach that is likely to result in a significant risk to your rights and freedoms, habje will notify affected players without undue delay and take all necessary remedial action.

13. International Data Transfers

habje operates servers and uses service providers located in multiple jurisdictions. As a result, your personal data may be transferred to, stored in, or processed in countries outside Bangladesh. habje takes steps to ensure that all such transfers are subject to appropriate safeguards, including:

• Contractual data processing agreements with all third-party providers that receive your data, incorporating standard data protection clauses
• Selection of service providers that operate to internationally recognised security standards, including ISO 27001 certification where applicable
• Regular due diligence reviews of third-party data processors to assess their compliance with habje's data protection requirements

Where data is transferred to a country that does not provide an equivalent level of data protection to that which applies in habje's primary operating jurisdiction, habje will implement additional contractual and technical safeguards to protect your information.

14. Changes to This Policy

habje may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or regulatory guidance. Where changes are material, habje will notify registered players by email to the address held on their account and will post a prominent notice on the Platform no less than 7 days before the changes take effect.

The "Last Updated" date at the top of this Policy always reflects the date of the most recent revision. We encourage you to review this Policy periodically so that you remain informed about how habje protects your data. Your continued use of habje following the effective date of any revision constitutes your acceptance of the updated Policy.

15. Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how habje has handled your personal data, please contact us:

• Email: [email protected] — please include "Privacy Request" or "Data Rights" in the subject line so your message is routed to the correct team
• Response time: habje aims to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive response within 30 calendar days
• Support hours: 24 hours a day, 7 days a week, 365 days a year

If you are not satisfied with habje's response to a privacy complaint, you have the right to escalate the matter through habje's formal complaints process as described in our FAQ, or to seek independent dispute resolution.