cp44 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1 Who We Are and How to Contact Us

cp44 is an online casino and sports betting platform serving players in Bangladesh. The platform is accessible at https://cp44.io and offers a range of casino games, live dealer tables, and cricket and sports betting markets.

For any questions or concerns relating to this Privacy Policy, or to exercise any of your data rights described in Section 10, please contact our Data Protection Officer using the following details:

• Email: [email protected]
• Response Time: We aim to respond to all privacy-related enquiries within 72 hours of receipt.
• Availability: 24 hours a day, 7 days a week, including Bangladeshi public holidays.

Please quote "Privacy Enquiry" in the subject line of any email sent to us regarding data protection matters, so that we can direct your message to the appropriate team member without delay.

2 What Personal Data We Collect

cp44 collects personal data in two ways: information that you provide directly to us, and information that is collected automatically as a result of your use of the platform. The specific categories of data we collect are set out below.

Data you provide directly:

• Registration Data: Full legal name, date of birth, residential address, email address, and mobile number provided when you create an account.
• Identity Verification Documents: Copies of government-issued identity documents (National Identity Card, passport, or driving licence), proof of address documents, and payment method ownership documentation submitted in connection with our know-your-customer (KYC) procedures.
• Financial Data: Payment method details (bKash mobile number, Nagad mobile number, Rocket account number, bank account details) used to process deposits and withdrawals. cp44 does not store full card numbers or mobile banking PINs.
• Communications Data: The content of messages you send to our customer support team via live chat or email, including any attachments or screenshots.
• Preference Data: Your marketing communication preferences, responsible gaming settings (deposit limits, session reminders, self-exclusion status), and language preferences.

Data collected automatically:

• Technical Data: IP address, browser type and version, operating system, device type and identifier, and screen resolution collected at login and during active sessions.
• Usage Data: Pages visited, games played, bet amounts, session duration, navigation paths, and timestamps of all significant account events.
• Cookie and Tracking Data: Information collected via cookies and similar technologies as described in Section 7 of this policy.
• Transaction Data: A complete record of all deposits, withdrawals, bonus credits, wagers placed, and winnings received on your account, together with the timestamps and payment methods associated with each transaction.

3 How and Why We Use Your Personal Data

cp44 processes personal data only where there is a lawful basis for doing so. The table below summarises the primary purposes for which we use your data and the legal basis that applies to each.

Where we rely on legitimate interests as a legal basis, we have assessed that our interests are not overridden by your fundamental rights and freedoms. You have the right to object to processing carried out on the basis of legitimate interests — see Section 10 for details.

4 How We Share Your Personal Data

cp44 does not sell, rent, or trade your personal data. We may, however, share your data with carefully selected third parties where it is necessary to operate the platform or comply with our legal obligations. All third-party recipients are bound by contractual data-processing obligations consistent with this Privacy Policy.

Categories of third parties with whom data may be shared:

• Payment Processors: bKash, Nagad, Rocket, Upay, and partner banks (Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank) receive the minimum financial data necessary to process your transactions. These providers operate under their own regulatory frameworks and privacy obligations.
• Identity Verification Providers: Third-party KYC and document verification services that assist cp44 in confirming the authenticity of identity documents submitted by players.
• Game Content Providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised session and bet data necessary for game integrity auditing. No personally identifiable registration data is shared with game studios.
• IT Infrastructure and Security Providers: Cloud hosting, content delivery, and cybersecurity vendors who process data on cp44's behalf under strict data-processing agreements.
• Analytics Providers: Platform analytics tools that help cp44 understand aggregate usage patterns. Data shared for analytics purposes is anonymised or pseudonymised wherever technically feasible.
• Legal and Regulatory Authorities: Where required by applicable law, court order, or regulatory demand, cp44 will disclose personal data to the relevant authority. cp44 will notify you of such a disclosure request unless prohibited from doing so by law.

5 International Data Transfers

cp44's primary platform infrastructure is operated with data security and player privacy as a top priority. Some of our third-party service providers may process personal data in jurisdictions outside Bangladesh. In all such cases, cp44 takes steps to ensure that appropriate safeguards are in place to protect your personal data to a standard equivalent to, or exceeding, the protections described in this Privacy Policy.

Safeguards used for international transfers include:

• Contractual clauses requiring the recipient to provide equivalent data protection standards.
• Data minimisation — ensuring only the minimum necessary data is transferred internationally.
• Encryption of data both in transit (TLS 1.2 or higher) and at rest (AES-256).

If you would like further information about the specific safeguards in place for any particular international data transfer, please contact us at [email protected].

6 Data Retention

cp44 retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the full duration that your account remains open and active on the platform.
• Closed account data: Retained for a minimum of five years following account closure, in compliance with anti-money laundering record-keeping obligations.
• Transaction records: Retained for a minimum of seven years from the date of each transaction, in compliance with financial record-keeping requirements.
• Identity verification documents: Retained for a minimum of five years following the end of the business relationship.
• Support communications: Retained for three years following the resolution of the relevant support case, unless the matter is the subject of ongoing legal proceedings.
• Cookie and analytics data: Session cookies are deleted when your browser session ends. Persistent cookies and analytics data are retained for up to 13 months from the date of collection.

At the end of the applicable retention period, personal data is securely and permanently deleted or anonymised in accordance with our internal data destruction procedures. Anonymised data, which can no longer be linked back to any individual, may be retained indefinitely for aggregate statistical purposes.

7 Cookies and Tracking Technologies

cp44 uses cookies and similar tracking technologies to enable essential platform functionality, improve user experience, and generate aggregate analytics. A cookie is a small text file placed on your device by your browser when you visit a website. Cookies do not contain executable code and cannot access other files on your device.

Categories of cookies used by cp44:

• Strictly Necessary Cookies: Required for the platform to function correctly, including session authentication, security tokens, and load balancing. These cookies cannot be disabled without impairing core platform functionality.
• Functional Cookies: Used to remember your preferences such as preferred language, responsible gaming settings, and display configurations. Disabling these cookies will not prevent access to the platform but will reset your preferences on each visit.
• Analytics Cookies: Used to collect anonymised data about how visitors interact with the platform, including which pages are most visited and how users navigate between sections. This data helps cp44 improve the user experience.
• Security Cookies: Used to detect and mitigate fraudulent activity, including detection of unusual login patterns and CSRF (cross-site request forgery) protection tokens.

You can manage your cookie preferences through your browser settings. Note that disabling certain categories of cookies may affect your experience on the cp44 platform. For detailed instructions on managing cookies in your specific browser, refer to your browser's official help documentation.

8 Children and Minors

The cp44 platform is strictly intended for adults aged 21 years and above. cp44 does not knowingly collect, store, or process personal data relating to individuals under the age of 21. If cp44 becomes aware that personal data has been submitted by or on behalf of a person under 21, that data will be deleted immediately and the associated account will be suspended pending review.

If you are a parent or guardian and believe that a minor has created a cp44 account or submitted personal data to us, please contact [email protected] immediately. We will investigate and take appropriate action without delay.

9 Security Measures

cp44 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS 1.2+): All data transmitted between your browser and the cp44 platform is encrypted using industry-standard TLS protocols. You will see a padlock icon in your browser's address bar confirming this protection is active.
• AES-256 Encryption at Rest: Sensitive personal data, including identity documents and financial records, is encrypted using AES-256 at the storage layer.
• Password Hashing: Account passwords are never stored in plain text. cp44 uses bcrypt with a per-user salt to store password hashes.
• Access Control: Access to systems holding personal data is restricted to authorised personnel on a need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Security Monitoring: cp44 operates continuous intrusion detection monitoring and automated alerts for anomalous account activity, unusual login patterns, and potential data security incidents.
• Penetration Testing: The platform undergoes regular independent security assessments to identify and remediate vulnerabilities before they can be exploited.

Despite these measures, no system connected to the internet can be guaranteed to be completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, cp44 will notify affected players without undue delay and will take all reasonable steps to contain and remediate the incident.

10 Your Data Rights

As a cp44 account holder, you hold the following rights in relation to the personal data we process about you. To exercise any of these rights, please submit a written request to [email protected], quoting "Data Rights Request" in the subject line. cp44 will respond within 30 days of receiving a verifiable request.

• Right of Access: You may request a copy of all personal data that cp44 holds about you, together with information about how it is being used and with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Minor corrections (such as a typo in your address) can be made directly within your account settings.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where the processing is unlawful. Note that this right may be limited where retention is required by law (e.g., anti-money laundering obligations).
• Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of our legitimate grounds.
• Right to Data Portability: You may request that cp44 provide your personal data in a structured, machine-readable format (such as JSON or CSV) so that you may transfer it to another service provider.
• Right to Object: You may object at any time to the processing of your personal data where cp44 relies on legitimate interests as the legal basis. You also have an unconditional right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

Where a request to exercise a data right is refused, cp44 will explain the reasons for the refusal in writing and inform you of any available remedies. cp44 will not charge a fee for handling data rights requests unless the requests are manifestly unfounded, excessive, or repetitive, in which case a reasonable administrative fee may apply.

11 Marketing Communications

cp44 will send you promotional emails, SMS notifications, or in-platform messages relating to new games, upcoming cricket and BPL betting markets, seasonal offers (such as Eid, Pohela Boishakh, and ICC tournament promotions), reload bonuses, and platform updates only if you have explicitly opted in to receive such communications at registration or via your account preferences.

You may withdraw your consent to receive marketing communications at any time by:

• Clicking the "Unsubscribe" link at the bottom of any marketing email.
• Updating your notification preferences within your account settings.
• Contacting [email protected] with the subject line "Marketing Opt-Out".

Withdrawing consent for marketing communications will not affect your ability to receive transactional communications that are essential for the operation of your account, such as deposit confirmations, withdrawal notifications, security alerts, and identity verification requests. These operational communications cannot be disabled while your account remains active.

12 Responsible Gaming and Data Processing

cp44 processes certain categories of your personal data specifically in support of our responsible gaming obligations. This includes monitoring your betting patterns, session duration, deposit frequency, and use of player protection tools to identify signs of potentially problematic gambling behaviour.

Where our responsible gaming monitoring systems flag a concern, an authorised member of the cp44 player welfare team may review your account data and, where appropriate, make contact to offer support resources or suggest the use of available player protection tools such as deposit limits, cooling-off periods, or self-exclusion.

This processing is carried out in the interests of player welfare and in fulfilment of our legal and ethical obligations. It does not constitute automated profiling for any commercial purpose. You may learn more about the responsible gaming tools available to you by visiting our Responsible Gaming page.

13 Changes to This Privacy Policy

cp44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. When changes are made, the revised policy will be published on this page with an updated effective date shown at the top of the document.

Where changes are material — meaning they significantly affect the way we collect, use, or share your personal data — cp44 will notify registered players via the email address associated with their account at least 14 days before the changes take effect. For non-material changes (such as clarifications of existing language or corrections of typographical errors), no advance notice will be provided, but the effective date will be updated.

Your continued use of the cp44 platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised policy, you should cease using the platform and may request account closure by contacting [email protected].

14 Contact and Complaints

If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a complaint about how cp44 has handled your personal data, please contact our Data Protection Officer:

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate.
• Live Chat: Available within the platform 24 hours a day, 7 days a week.
• Response Time: We will acknowledge your message within 24 hours and provide a substantive response within 30 days.

cp44 is committed to resolving privacy complaints promptly and fairly. If you are not satisfied with the outcome of a complaint handled by our Data Protection Officer, you may escalate the matter through any dispute resolution mechanism available to you under applicable law.

We serve players across all eight divisions of Bangladesh — Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, and Mymensingh — and our support team is experienced in handling the specific privacy needs and payment-method questions of the Bangladeshi gaming community.