upbd8 Privacy Policy

1 Information We Collect

upbd8 collects personal data from players through several channels: directly from you when you register an account or contact support, automatically when you use our platform, and from third-party service providers involved in the delivery of our services. The categories of personal data we collect are described below.

Registration and Account Data

When you create an upbd8 account, we collect the personal information you provide during the registration process. This includes your full legal name, date of birth, a valid Bangladesh mobile phone number, and a chosen username. If you choose to provide an email address for account notifications, that is also stored. This data is necessary to create and administer your player account and to comply with our age verification and identity verification obligations.

Identity Verification (KYC) Data

As part of our Know Your Customer process, we may collect and store copies of identity documents you submit during verification. These may include your National Identity Card (NID), passport, or other government-issued photographic identification. We may also collect proof of address documents and proof of payment method ownership. KYC document data is handled with the highest level of security and is retained only for the period required by applicable compliance obligations.

Financial and Transaction Data

We record all financial transactions conducted through your upbd8 account. This includes deposit amounts, withdrawal requests, payment method details (such as your bKash or Nagad account number), transaction reference numbers, timestamps, and wallet balance history. This data is necessary for processing payments, resolving disputes, and meeting anti-money-laundering (AML) record-keeping obligations. We do not store raw mobile wallet PIN codes or passwords.

Technical and Usage Data

When you access upbd8, we automatically collect certain technical data about your device and session. This includes your IP address, device type and operating system, browser type and version, screen resolution, session start and end times, pages visited within the platform, games played, bet amounts and outcomes, and error logs. This data is used to improve platform performance, diagnose technical issues, detect fraud, and personalise your experience.

Communications Data

If you contact upbd8 support via email at [email protected] or through any other support channel, we retain records of your communications including the content of messages, timestamps, and the outcome of any support interactions. This allows us to provide consistent support and maintain an accurate record of any issue or dispute you raise with us.

2 How We Use Your Data

upbd8 processes your personal data only for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The table below summarises the primary purposes for which we use your data and the corresponding legal basis for each use.

Marketing Communications

upbd8 will only send you promotional emails, SMS notifications, or in-platform messages about bonuses, new games, and seasonal promotions if you have explicitly opted in to receive such communications during registration or through your account settings. You may withdraw your consent to marketing communications at any time by updating your notification preferences in your account settings or by contacting [email protected]. Withdrawal of marketing consent does not affect the lawfulness of any processing carried out prior to withdrawal.

Automated Decision-Making

upbd8 uses automated systems to detect unusual account activity, potential fraud, and responsible gaming indicators. In certain circumstances, these automated systems may trigger account restrictions or flag an account for manual review without prior human intervention. Where an automated decision has a significant effect on your account — such as a temporary deposit freeze — you have the right to request human review of that decision by contacting our support team.

3 Legal Basis for Processing

upbd8 processes your personal data under one or more of the following legal bases, depending on the specific processing activity involved:

• Contract Performance: Processing that is necessary to fulfil the contractual obligations between upbd8 and you as a registered player — including account management, payment processing, and game delivery — is carried out on the basis that it is necessary to perform the contract we have with you.
• Legal Obligation: Certain processing activities are required by applicable law or regulation, including age verification, KYC identity checks, AML transaction monitoring, and the retention of financial records. upbd8 has no discretion to decline this processing where it is mandated by law.
• Legitimate Interest: upbd8 processes some data on the basis of its legitimate business interests, provided those interests are not overridden by your rights and interests. Examples include fraud prevention, platform security, responsible gaming monitoring, and internal analytics to improve our services.
• Consent: Where we rely on your consent as the legal basis — primarily for marketing communications and the use of non-essential cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

4 Data Sharing and Disclosure

upbd8 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

Payment Service Providers

To process your deposits and withdrawals, upbd8 must share relevant transaction data with the mobile financial service providers and banking partners you choose to use, including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, and Sonali Bank. The data shared is limited to what is technically required to initiate and confirm each transaction. These providers operate under their own privacy policies and are subject to applicable Bangladeshi financial regulations.

Game Software Providers

The games available on the upbd8 platform are powered by third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. To deliver real-time game sessions, your player account identifier, session token, and stake data must be transmitted to the relevant game server operated by the game provider. Game providers are contractually prohibited from using this data for any purpose other than delivering and auditing the game session.

Fraud Prevention and Law Enforcement

upbd8 may share personal data with fraud prevention agencies, AML monitoring services, and law enforcement authorities where we are required to do so by law, court order, or regulatory direction, or where we have reasonable grounds to believe that disclosure is necessary to prevent fraud, money laundering, or other serious criminal activity. In such cases, data will be disclosed only to the extent legally required and under appropriate confidentiality protections where permissible.

Professional Advisers

upbd8 may disclose personal data to its legal advisers, auditors, and accountants where necessary for the conduct of legal proceedings, regulatory compliance audits, or financial reporting. All such disclosures are subject to professional confidentiality obligations binding on the receiving party.

Business Transfers

In the event that upbd8 undergoes a merger, acquisition, restructuring, or sale of all or part of its assets, player personal data held by upbd8 may be transferred to the acquiring entity as part of that transaction. In such circumstances, upbd8 will notify affected players through the platform prior to any transfer and will ensure that the acquiring entity agrees to honour the commitments made in this Privacy Policy.

5 Cookies and Tracking Technologies

upbd8 uses cookies and similar tracking technologies on the upbd8.net website to enable core platform functionality, maintain your login session, remember your preferences, and analyse how players use the platform. A summary of the cookie categories we use is provided below.

Strictly Necessary Cookies

These cookies are essential for the upbd8 platform to function. They manage your authenticated session, maintain your wallet state during a session, and enable the security features that protect your account from unauthorised access. These cookies cannot be disabled without rendering the platform inoperable. No consent is required for strictly necessary cookies as they are required for the delivery of the service you have requested.

Performance and Analytics Cookies

upbd8 uses performance cookies to collect anonymised data about how players navigate the platform — which pages are visited most frequently, where players encounter errors, and how long sessions last. This data is used internally to prioritise development work and improve the platform experience. These cookies do not identify you personally; all data collected is aggregated and anonymised before analysis.

Functional Cookies

Functional cookies allow upbd8 to remember your preferences such as your chosen language display settings, notification preferences, and last-visited game category. These cookies improve your experience by ensuring the platform behaves consistently with your preferences across sessions.

Managing Cookies

You may control non-essential cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies stored by websites you visit. Please note that blocking certain cookies may impair the functionality of the upbd8 platform, including the ability to maintain a logged-in session. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

6 Data Retention

upbd8 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulation. The following retention periods apply to the main categories of personal data we hold:

• Account and registration data: Retained for the lifetime of your active account, plus a minimum of 5 years following account closure to meet AML and financial record-keeping requirements.
• KYC identity verification documents: Retained for a minimum of 5 years from the date of submission, or longer where required by applicable regulatory guidance.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction to satisfy anti-money-laundering record-keeping obligations.
• Customer support communications: Retained for 3 years from the date of the final communication in a support thread, or longer if the communication is relevant to an unresolved dispute or legal proceeding.
• Technical and usage logs: Retained for up to 13 months in standard form, after which data is aggregated and anonymised for longer-term analytics purposes.
• Marketing consent records: Retained for the duration of your consent and for 2 years thereafter to demonstrate compliance with consent obligations.

When personal data is no longer required and no legal obligation requires its continued retention, upbd8 will securely delete or irreversibly anonymise that data in accordance with our internal data destruction procedures.

7 Your Privacy Rights

As a player on the upbd8 platform, you hold a number of rights in relation to your personal data. upbd8 is committed to honouring these rights and to responding to all valid requests within 30 days of receipt. To exercise any of the rights described below, please contact us at [email protected] with the subject line "Privacy Rights Request" and a clear description of the right you wish to exercise.

Right of Access

You have the right to request a copy of the personal data that upbd8 holds about you, together with information about how that data is being used. This is sometimes referred to as a Subject Access Request (SAR). We will provide this information free of charge and in a commonly used electronic format.

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. You can update some of your account data directly through your account settings. For data that cannot be self-corrected — such as your registered full name or date of birth — please contact support and provide appropriate documentary evidence of the correct information.

Right to Erasure

You may request the deletion of your personal data in certain circumstances — for example, if the data is no longer necessary for the purpose for which it was collected, or if you withdraw consent and no other legal basis applies. Please note that upbd8 may be required to retain certain data for legal, regulatory, or fraud prevention purposes even following a valid erasure request. In such cases, we will inform you of the specific grounds on which we are retaining the data and the expected retention period.

Right to Restriction of Processing

In certain circumstances — for example, while you contest the accuracy of data we hold, or while an objection to processing is being assessed — you may request that upbd8 restrict its use of your personal data to storage only, without further active processing.

Right to Data Portability

Where upbd8 processes your personal data on the basis of your consent or contract performance, and that processing is carried out by automated means, you have the right to receive a copy of the personal data you provided to us in a structured, commonly used, machine-readable format.

Right to Withdraw Consent

Where upbd8 relies on your consent as the legal basis for any processing activity, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to the withdrawal. To withdraw consent for marketing communications, update your preferences in your account settings or contact [email protected].

8 Data Security Measures

upbd8 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our approach to data security is outlined below.

Encryption in Transit and at Rest

All data transmitted between your device and the upbd8 platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data stored in our systems — including identity documents and financial records — is encrypted at rest using strong encryption standards. Our platform operates exclusively over HTTPS; unencrypted HTTP connections are not accepted.

Access Controls

Access to systems containing player personal data is restricted to upbd8 personnel and contractors who have a legitimate operational need to access that data. All staff with access to personal data are subject to confidentiality obligations and receive regular data protection training. Access rights are reviewed periodically and revoked immediately upon the termination of any staff member's role.

Security Monitoring

upbd8 operates continuous security monitoring on its platform infrastructure. Suspicious activity patterns — including unusual login attempts, bulk data access, and anomalous transaction behaviour — trigger automated alerts that are reviewed by our security team. We conduct periodic security assessments to identify and remediate potential vulnerabilities before they can be exploited.

Data Breach Response

In the event of a personal data breach that poses a risk to affected players, upbd8 will take immediate steps to contain the breach, assess the scope and impact, and — where the breach is likely to result in a high risk to affected individuals — notify affected players without undue delay. Notifications will be provided via the contact details registered on your upbd8 account and will include a description of the nature of the breach, the categories of data affected, and the steps upbd8 is taking in response.