Your Privacy Matters to td44

td44 operates an online casino and sports betting platform accessible at td44.io, providing services primarily to players based in Bangladesh. We are fully committed to protecting the privacy and personal data of every individual who accesses our platform, whether as a registered account holder, a prospective player, or a casual visitor.

This Privacy Policy has been drafted in accordance with recognised data protection principles, including those of transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity, and confidentiality. It governs all personal data processing activities carried out by td44 in connection with the operation of our platform and services.

By accessing the td44 platform, creating an account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this policy, you should discontinue your use of the platform and contact us at [email protected] to request account closure if applicable.

This policy should be read in conjunction with our Terms & Conditions and our Responsible Gaming policy, both of which form part of our overarching user agreement.

td44 collects the following categories of personal data from players and platform visitors:

We do not knowingly collect special category personal data (such as data revealing racial or ethnic origin, religious beliefs, health information, or biometric data) except where expressly required by law for identity verification purposes, in which case it is processed with appropriate safeguards and on the basis of explicit consent.

td44 collects personal data through a variety of direct and automated means, including:

• Direct Submission: Information you provide directly when registering an account, completing KYC verification, making a deposit or withdrawal request, or contacting our support team;
• Automated Technologies: Data collected automatically as you navigate the platform, including through cookies, web beacons, pixel tags, session replay tools, and server log files;
• Payment Processors: Transaction confirmation data received from payment service providers including bKash, Nagad, Rocket, Upay, Visa, and Mastercard when processing financial transactions;
• Identity Verification Partners: Data returned by third-party KYC and anti-money-laundering verification services used to confirm the identity and eligibility of account applicants;
• Game Providers: Session and outcome data transmitted by licensed game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi as part of normal game operation;
• Analytics Providers: Aggregated and pseudonymised usage data collected via analytics platforms to help us understand how players interact with the td44 interface and identify areas for improvement.

td44 processes personal data for the following specific, explicit, and legitimate purposes:

• Account Administration: To create, maintain, and manage your player account, including authentication, balance management, and VIP tier tracking;
• Service Delivery: To provide access to casino games, live dealer tables, sports betting markets, and all other platform features you have requested;
• Financial Transactions: To process deposits and withdrawals through your chosen payment method and to maintain accurate transaction records;
• Legal Compliance: To fulfil our obligations under applicable anti-money-laundering (AML), counter-terrorism financing (CTF), and know-your-customer (KYC) requirements;
• Fraud Prevention: To detect, investigate, and prevent fraudulent, abusive, or suspicious activity on the platform, including the use of automated detection systems;
• Responsible Gaming: To monitor player behaviour for signs of problem gambling and to apply responsible gaming tools including deposit limits, cool-off periods, and self-exclusion where warranted;
• Customer Support: To respond to queries, complaints, and account issues raised through our live chat, email, and other support channels;
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have provided explicit consent to receive such communications. You may withdraw this consent at any time;
• Platform Improvement: To analyse usage patterns and player feedback in order to improve the functionality, design, and content of the td44 platform;
• Legal Proceedings: To establish, exercise, or defend legal claims in the event of a dispute.

td44 processes your personal data on one or more of the following recognised legal bases, depending on the specific processing activity in question:

• Contractual Necessity: Processing that is necessary to perform the contract between you and td44 — specifically, to deliver the platform services you have signed up to use and to administer your account;
• Legal Obligation: Processing that is required in order for td44 to comply with applicable laws and regulations, including AML, CTF, and KYC obligations;
• Legitimate Interests: Processing carried out in furtherance of td44's legitimate business interests, such as fraud detection, platform security, and analytics — provided that those interests are not overridden by your own privacy rights and fundamental freedoms;
• Consent: Processing carried out on the basis of your explicit, freely given, informed, and unambiguous consent — specifically for optional marketing communications and for any non-essential cookies. You may withdraw consent at any time without detriment to your account status.

td44 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes under any circumstances. Your data may be disclosed to the following categories of third parties solely for the purposes described in this policy:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Visa, and Mastercard — for the purpose of processing financial transactions;
• Identity Verification Services: Third-party KYC and AML compliance providers engaged to verify the identity and eligibility of account applicants in accordance with our legal obligations;
• Game Technology Providers: Licensed game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — limited to session and outcome data required for game operation;
• IT Infrastructure Providers: Cloud hosting, database management, cybersecurity, and technical support providers who process data on our behalf under strict contractual data processing agreements;
• Analytics Providers: Platforms providing aggregated, pseudonymised usage analytics to support platform optimisation. No directly identifiable personal data is shared with analytics providers;
• Legal and Regulatory Authorities: Law enforcement agencies, regulatory bodies, courts, and other competent authorities where td44 is legally required or compelled to disclose personal data;
• Professional Advisors: Legal counsel, auditors, and accountants where disclosure is necessary in the context of a specific legal, compliance, or financial matter.

All third parties with whom td44 shares personal data are required to maintain appropriate technical and organisational security measures and to process your data solely in accordance with td44's documented instructions and applicable data protection law.

td44 uses cookies and similar technologies to support the operation of the platform and to improve your experience. Cookies are small text files placed on your device by a web server when you visit a website. They enable the platform to recognise your device on subsequent visits, retain session state, and deliver relevant functionality.

The following categories of cookies are used on the td44 platform:

• Strictly Necessary Cookies: Essential to the functioning of the platform. These include session authentication tokens, load-balancing cookies, and security cookies. These cookies cannot be disabled without impairing your ability to use the platform;
• Functional Cookies: Used to remember your preferences and personalise your experience, such as language settings, preferred game categories, and display preferences;
• Performance & Analytics Cookies: Used to collect pseudonymised data about how visitors navigate the platform — including page visit frequency, session duration, and click paths — to help us improve platform performance and content relevance;
• Marketing Cookies: Used to deliver relevant promotional content based on your browsing behaviour on the td44 platform. These cookies are activated only where you have provided explicit consent.

You may manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies may affect your ability to log in and use the platform. Disabling functional or analytics cookies will not prevent you from using the core service.

td44 retains personal data only for as long as is necessary to fulfil the purposes for which it was originally collected, or for as long as is required by applicable legal, regulatory, or contractual obligations. The following indicative retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, in order to satisfy AML record-keeping requirements;
• Financial Transaction Records: Retained for a minimum of seven (7) years following the date of each transaction, in accordance with financial record-keeping obligations;
• KYC Documentation: Retained for the duration of the account relationship and for five (5) years following account closure or the conclusion of any related investigation, whichever is later;
• Customer Support Communications: Retained for three (3) years from the date of the final communication in each support interaction, to support dispute resolution;
• Marketing Consent Records: Retained for the period of consent and for two (2) years following withdrawal of consent, to demonstrate compliance with consent obligations;
• Technical and Usage Logs: Retained for up to twelve (12) months from the date of collection for security and fraud detection purposes, then anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely and irreversibly deleted or anonymised, subject to any overriding legal obligation requiring its continued retention.

td44 implements a comprehensive suite 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:

• SSL/TLS Encryption: All data in transit between your device and td44's servers is encrypted using TLS 1.2 or higher, ensuring that sensitive information cannot be intercepted during transmission;
• Data Encryption at Rest: All personal and financial data stored on td44's systems is encrypted using AES-256 encryption;
• Access Controls: Access to personal data within td44's systems is restricted on a strict need-to-know basis. Staff members are granted access only to the data categories required for their specific role, and all access is logged and auditable;
• Two-Factor Authentication: Two-factor authentication (2FA) is available to all registered players and is mandatory for all internal staff accounts with access to personal data systems;
• Firewall and Intrusion Detection: td44's infrastructure is protected by enterprise-grade firewalls and continuous intrusion detection and prevention systems;
• Regular Security Audits: Our platform undergoes scheduled third-party penetration testing and independent security audits to identify and remediate vulnerabilities on a proactive basis;
• Staff Training: All td44 staff who handle personal data receive mandatory data protection training and are bound by strict confidentiality obligations.

As a player whose personal data is processed by td44, you hold the following rights with respect to your personal data. To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Rights Request" and include your registered account username and a description of the right you wish to exercise.

• Right of Access: You have the right to request a copy of all personal data held about you by td44, along with information about the purposes for which it is processed and the categories of recipients to whom it has been disclosed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. Where correction is not possible, you have the right to request erasure of the inaccurate data;
• Right to Erasure ("Right to be Forgotten"): You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where it has been unlawfully processed — subject to overriding legal retention obligations;
• Right to Restriction of Processing: You have the right to request that td44 restrict the processing of your personal data in certain circumstances, for example while the accuracy of data is being verified or while an objection is being assessed;
• Right to Data Portability: You have the right to receive a copy of the personal data you have provided to td44 in a structured, commonly used, machine-readable format, and to transmit that data to another data controller;
• Right to Object: You have the right to object to the processing of your personal data where td44 relies on legitimate interests as the legal basis, and to object at any time to the processing of your data for direct marketing purposes;
• Right to Withdraw Consent: Where td44 relies on your consent as the basis for any processing activity, you have the right to withdraw that consent at any time without detriment to your account or to the lawfulness of prior processing.

td44 will respond to all verified data rights requests within thirty (30) days of receipt. Where a request is complex or involves a high volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension within the initial thirty-day period.

The td44 platform is strictly intended for use by adults aged 21 years and above. We do not knowingly collect, store, or process the personal data of individuals under the age of 21. If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data from our systems and close the associated account.

If you are a parent or guardian and believe that your child has registered an account with td44 or has provided personal data to our platform without your knowledge or consent, please contact us immediately at [email protected]. We will investigate and take prompt remedial action.

In the course of operating the td44 platform and delivering services to players based in Bangladesh, your personal data may be processed by systems or personnel located in jurisdictions other than Bangladesh. Such transfers may occur in connection with our use of cloud infrastructure providers, game technology partners, and other third-party service providers whose operations are hosted in various countries.

Where personal data is transferred outside Bangladesh, td44 ensures that appropriate safeguards are in place to protect that data to a standard at least equivalent to that which applies domestically. Such safeguards include:

• Contractual data processing agreements that impose binding data protection obligations on the recipient;
• Transfers only to jurisdictions or organisations that maintain an equivalent or higher standard of data protection;
• Technical controls including end-to-end encryption for data in transit across borders.

If you would like further information about the specific safeguards applied to any particular international transfer of your personal data, please contact us at [email protected].

td44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to our platform and services. The effective date of the most recent version is indicated by the "Last Updated" date displayed at the top of this document.

Where changes to this policy are material — meaning they significantly affect the nature of the data we collect, the purposes for which we process it, or the rights available to you — we will notify affected players via the email address registered to their account prior to the changes taking effect. Your continued use of the td44 platform following notification of a material change constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed of how td44 handles your personal data. Prior versions of this policy are superseded in their entirety by the most recently published version.

If you have any questions, concerns, or requests relating to this Privacy Policy or to td44's handling of your personal data, please contact our dedicated data protection team through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Privacy Enquiry" or "Data Rights Request" as appropriate
• Response Time: We aim to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive response within 30 days
• Support Hours: 24 hours a day, 7 days a week, including public holidays observed in Bangladesh (Bangladesh Standard Time, UTC+6)

This Privacy Policy, together with our Terms & Conditions and Responsible Gaming policy, constitutes the complete framework governing your relationship with td44 with respect to the use of your personal data.