622bat Privacy Policy

This Privacy Policy ("Policy") sets out the basis on which 622bat ("the Platform", "we", "us", "our") collects, processes, stores, and shares personal data obtained from users ("you", "your") of the 622bat website at https://622bat.app and all associated services. 622bat is committed to handling your personal information with transparency, security, and respect for your rights as a player in Bangladesh.

Please read this Policy carefully alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of the 622bat platform. If you have questions about this Policy at any time, please contact the 622bat support team via live chat or at [email protected].

1. Information We Collect

622bat collects personal data in several ways: directly from you when you register an account or interact with platform features, automatically as you use the platform, and from third parties where this is permitted and necessary for the purposes described in this Policy.

1.1 Registration and Identity Data

When you create a 622bat account, we collect the following information as part of the onboarding process:

• Full legal name as it appears on your government-issued identification
• Date of birth (required to verify you are aged 18 or above)
• Mobile phone number associated with your bKash, Nagad, or Rocket account
• Email address (where provided as an optional contact method)
• Preferred username and encrypted account password

1.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) obligations, we may request documentary evidence of identity before processing your first withdrawal. This may include:

• A copy of your National Identity Card (NID) or passport
• A recent bank statement or utility bill as proof of address
• A screenshot or confirmation reference from your bKash, Nagad, Rocket, or Upay account to verify payment method ownership

KYC documents are processed securely and are retained only for as long as required by our verification obligations and applicable data retention rules described in Section 5 of this Policy.

1.3 Financial Transaction Data

Every deposit and withdrawal you initiate on the 622bat platform generates a transaction record. The financial data we collect includes:

• Transaction amount in Bangladeshi Taka (BDT)
• Payment method used (bKash, Nagad, Rocket, Upay, Visa, or Mastercard)
• Transaction reference numbers issued by your payment provider
• Date, time (Bangladesh Standard Time, UTC+6), and status of each transaction
• Running account balance at the time of each transaction

622bat does not store full card numbers, CVV codes, or mobile banking PINs. Payment credentials are handled directly by your payment provider and are never transmitted to or retained by 622bat's servers.

1.4 Betting and Gaming Activity Data

We record your activity on the platform in order to administer your account, settle bets and game outcomes, and support responsible gaming monitoring. This includes:

• All bets placed, including market, stake amount, odds, and settlement outcome
• Casino and slot game sessions, including game title, session duration, stakes, and results
• Bonus offers accepted, wagering progress, and bonus outcomes
• Responsible gaming tool activations (deposit limits, self-exclusion requests, session reminders)

1.5 Technical and Usage Data

When you access the 622bat platform, we automatically collect certain technical information from your device and browser, including:

• IP address and approximate geographic location derived from that IP address
• Device type, operating system version, and browser type and version
• Pages visited, time spent on each page, and navigation paths through the platform
• Session start and end times, login frequency, and session duration
• Referring URLs (the page you visited immediately before arriving at 622bat)

2. How We Use Your Data

622bat processes your personal data only for specific, legitimate purposes. The table below summarises the primary uses of each data category and the legal basis on which we rely.

Purpose	Data Used	Legal Basis
Account creation and management	Registration data, identity data	Contractual necessity
Age and identity verification (KYC)	KYC documents, registration data	Legal obligation / player protection
Processing deposits and withdrawals	Financial transaction data	Contractual necessity
Bet and game settlement	Betting and gaming activity data	Contractual necessity
Fraud detection and prevention	Technical data, transaction data, IP data	Legitimate interest / legal obligation
Responsible gaming monitoring	Gaming activity, session data, RG tool usage	Legal obligation / player protection
Platform performance and analytics	Technical and usage data (anonymised)	Legitimate interest
Promotional communications (opt-in only)	Contact details, gaming preferences	Consent
Customer support and dispute resolution	All relevant account data	Contractual necessity / legitimate interest

2.1 Marketing Communications

622bat will only send you promotional messages — including bonus offers, seasonal promotions tied to BPL, IPL, Eid, Pohela Boishakh, and other events — if you have explicitly opted in to receive such communications during registration or via your account settings. You may withdraw your consent and opt out of all marketing communications at any time by updating your notification preferences in your account settings or by contacting the support team via live chat. Opting out of marketing does not affect the delivery of transactional communications (such as deposit confirmations, withdrawal notifications, and account security alerts), which are sent as part of the platform service.

2.2 Automated Decision-Making

622bat uses automated systems for certain account-level decisions, including fraud risk scoring, responsible gaming pattern detection, and duplicate account identification. Where an automated decision results in a restriction on your account, you have the right to request a manual review by a member of the 622bat compliance team. To exercise this right, contact support via live chat with the subject "Manual Review Request".

3. Data Sharing and Disclosure

622bat does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share your data only in the limited circumstances described below.

3.1 Service Providers and Technology Partners

To operate the platform effectively, 622bat engages trusted third-party service providers who process data on our behalf under strict data processing agreements. These include:

• Game content providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — these providers receive only the minimum session data required to deliver and settle game outcomes.
• Payment processors — bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive transaction data necessary to execute deposits and withdrawals. Each provider operates under its own privacy policy and regulatory obligations.
• Platform analytics and security vendors — we use industry-standard tools to monitor platform performance, detect fraudulent activity, and maintain uptime. These vendors receive anonymised or pseudonymised data where possible.

All third-party service providers engaged by 622bat are contractually bound to process your data only for the purposes specified by 622bat and to maintain appropriate technical and organisational security measures.

3.2 Legal and Regulatory Disclosure

622bat may disclose personal data to competent authorities, regulators, or law enforcement agencies where we are legally required to do so, or where disclosure is necessary to prevent, detect, or investigate fraud, money laundering, or other unlawful activity. In such cases, 622bat will disclose only the minimum data necessary to fulfil the legal obligation and will notify affected users where permitted by law.

3.3 Business Transfers

In the event of a merger, acquisition, or transfer of all or part of 622bat's business or assets, personal data held by the platform may be transferred to the acquiring entity as part of that transaction. In such circumstances, 622bat will take reasonable steps to ensure that the recipient entity provides data protection commitments equivalent to those described in this Policy, and will notify registered users of any material change to data controller identity within a reasonable period.

4. Cookies and Tracking

622bat uses cookies and similar tracking technologies to ensure the platform functions correctly, to remember your session and preferences, and to analyse how users interact with the site. The following categories of cookies are used on the platform:

Cookie Category	Purpose	Can Be Disabled?
Strictly Necessary	Maintain your login session, enforce security tokens, remember your language preference, and enable the cashier to function.	No — required for platform operation
Functional	Remember your preferred game lobby view, last-visited category, responsible gaming settings, and notification preferences.	Yes — via browser settings
Analytics	Collect anonymised usage data to understand navigation patterns, page performance, and error rates. Data does not identify individual users.	Yes — via browser settings
Fraud Prevention	Detect bot activity, identify suspicious login patterns, and flag anomalous transaction behaviour for manual review.	No — required for platform security

622bat does not use third-party advertising cookies or cross-site tracking technologies for the purpose of building advertising profiles or retargeting users on other websites. You may manage functional and analytics cookies through your browser's cookie settings at any time. Disabling strictly necessary or fraud prevention cookies may impair your ability to log in, deposit, or withdraw.

5. Data Retention

622bat retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention schedule applies:

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years post-closure	Anti-money laundering and fraud prevention obligations
KYC identity documents	Duration of account + 5 years post-closure	Regulatory verification requirements
Financial transaction records	7 years from transaction date	Financial record-keeping obligations
Betting and gaming activity logs	3 years from last account activity	Dispute resolution and responsible gaming monitoring
Technical and usage data	13 months from collection	Platform analytics and security monitoring
Customer support correspondence	3 years from last interaction	Dispute resolution and quality assurance
Marketing consent records	Until consent is withdrawn + 3 years	Proof of consent for regulatory compliance

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to any individual. Where data must be retained beyond the standard period due to an ongoing investigation, dispute, or legal proceeding, 622bat will inform you where legally permitted to do so.

6. Your Privacy Rights

As a 622bat user, you have the following rights in relation to your personal data. To exercise any of these rights, contact the 622bat support team via live chat or at [email protected]. We will respond to all verified requests within a reasonable period and no later than thirty (30) calendar days of receipt.

6.1 Right of Access

You have the right to request a copy of the personal data that 622bat holds about you, along with information about how that data is being processed. This is commonly referred to as a Subject Access Request (SAR). 622bat will provide the requested information in a structured, commonly used, and machine-readable format.

6.2 Right to Rectification

If you believe that any personal data held by 622bat is inaccurate or incomplete, you have the right to request that it be corrected. Where a correction affects your KYC verification status, updated documentary evidence may be required before the change is applied.

6.3 Right to Erasure

You may request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and no other legal basis for processing applies. This right is subject to 622bat's legal and regulatory obligations, which may require retention of certain data categories even after account closure (see Section 5 above).

6.4 Right to Restrict Processing

You have the right to request that 622bat restricts the processing of your personal data in certain circumstances, such as while the accuracy of data is being contested or while an objection to processing is being assessed. During a restriction period, 622bat will store your data but will not actively process it beyond what is legally required.

6.5 Right to Data Portability

Where personal data has been provided by you and is processed on the basis of consent or contractual necessity, you have the right to receive that data in a structured electronic format (such as CSV or JSON) and to transmit it to another service provider of your choice.

6.6 Right to Object

You have the right to object to processing of your personal data where that processing is carried out on the basis of legitimate interests — including profiling for responsible gaming purposes. 622bat will cease such processing upon receiving a valid objection unless it can demonstrate compelling legitimate grounds that override your interests, or where processing is necessary for the establishment, exercise, or defence of a legal claim.

7. Data Security

622bat takes the security of your personal data seriously and maintains a comprehensive set of technical and organisational measures designed to protect your information against unauthorised access, accidental loss, destruction, or disclosure.

7.1 Technical Security Measures

• 256-bit SSL/TLS encryption is applied to all data transmitted between your device and the 622bat platform, ensuring that your login credentials, payment details, and personal information cannot be intercepted in transit.
• Encrypted data storage — sensitive fields including passwords and KYC document references are stored using industry-standard encryption algorithms. Plaintext passwords are never stored in the 622bat database.
• Access controls — access to personal data within 622bat's internal systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Fraud monitoring systems — automated systems continuously monitor login patterns, transaction behaviour, and session data for indicators of fraudulent or unauthorised activity, with flagged events escalated to the security team for manual review.

7.2 Your Responsibilities

While 622bat maintains robust security measures on its side, the security of your account also depends on the precautions you take. You are responsible for:

• Keeping your 622bat username and password confidential and not sharing them with any third party
• Using a strong, unique password that is not reused across other websites or mobile apps
• Logging out of your 622bat account when using a shared or public device
• Notifying 622bat support immediately if you suspect your account has been accessed without your authorisation

7.3 Data Breach Response

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 622bat will take immediate containment action and will notify affected users as soon as reasonably practicable. Notifications will be sent to the contact details registered on your account and will include a description of the nature of the breach, the categories of data affected, and the steps 622bat is taking in response.

8. Policy Updates and Contact

622bat reviews this Privacy Policy on a regular basis and reserves the right to update or amend it at any time. Where changes are material — for example, where we introduce a new category of data processing or a new data sharing arrangement — we will notify registered users via the contact details held on their account at least fourteen (14) calendar days before the changes take effect. Non-material updates (such as clarifications of existing language or corrections of typographical errors) may be made without prior notice.

The date at the top of this Policy ("Effective Date") reflects the most recent revision. Continued use of the 622bat platform following notification of an update constitutes acceptance of the revised Policy. If you do not accept the revised terms, you should cease using the platform and may request account closure in accordance with the procedure described in the Terms & Conditions.

8.1 Children's Privacy

The 622bat platform is strictly for individuals aged 18 years and above. We do not knowingly collect personal data from persons under the age of 18. If you believe that a minor has registered an account on the platform, please contact us immediately via live chat so that we can investigate and take appropriate action, including suspension of the account and deletion of any associated data collected in error.

8.2 Links to Third-Party Services

The 622bat platform does not contain links to external third-party websites as part of its standard navigation. Where payment processing redirects to a provider's interface (such as bKash or Nagad), that provider's own privacy policy governs the handling of data within that interface. 622bat is not responsible for the privacy practices of third-party payment platforms.