whenbd Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how whenbd ("whenbd", "the Platform", "we", "us", "our"), the operator of the website at whenbd.club, collects, processes, stores, and protects the personal information of individuals ("Player", "User", "you") who access or use the whenbd platform.

whenbd is committed to protecting the privacy and security of the personal data entrusted to us by our players across Bangladesh. This Policy is written in clear, plain English to ensure that every player — regardless of their technical background — can understand how their data is handled.

By registering a whenbd account, making a deposit, or otherwise using the whenbd platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the whenbd platform.

This Policy should be read together with whenbd's Terms & Conditions and Responsible Gaming Policy, which together constitute the full framework governing your use of the platform.

2. Information We Collect

whenbd collects personal information from players through several means: directly from you during registration and account use, automatically through your use of the platform, and from third-party payment and verification services. The categories of personal data we collect include:

2.1 Registration and Account Data

When you create a whenbd account, we collect your full legal name, date of birth, residential address in Bangladesh, mobile phone number, and email address. This information is required to create and manage your account and to verify your identity and age (18+ requirement) in accordance with our Terms & Conditions.

2.2 Identity Verification (KYC) Data

As part of our Know Your Customer (KYC) obligations, we may collect copies of government-issued identity documents such as your National Identity Card (NID), passport, or driving licence. We may also collect proof of address documents such as utility bills or bank statements issued within the last three months. These documents are collected to verify your identity, confirm your age, and satisfy our anti-money laundering (AML) obligations.

2.3 Financial and Transaction Data

whenbd collects data relating to deposits, withdrawals, wager amounts, winnings, and transaction histories on your account. When you transact via bKash, Nagad, Rocket, Upay, or a bank, we receive transaction confirmation data including the transaction reference number, the amount in BDT, and the masked identifier of the payment source. We do not store full mobile wallet PINs, card numbers, or bank login credentials.

2.4 Usage and Behavioural Data

whenbd automatically collects data about how you interact with the platform, including pages visited, games played, bet types and amounts, session duration, login timestamps, and in-platform navigation patterns. This data is used to improve the platform experience, detect fraud and unusual activity, and deliver personalised content where applicable.

2.5 Technical and Device Data

We collect technical information about the device and network you use to access whenbd, including your IP address, browser type and version, operating system, device type (mobile or desktop), screen resolution, and referring URL. This data is used for security monitoring, fraud detection, and platform performance optimisation.

2.6 Communications Data

If you contact whenbd's support team via email or live chat, we retain records of those communications, including the content of your messages and any attachments provided. This data is used to resolve disputes, improve support quality, and maintain an audit trail of player interactions.

3. How We Use Your Data

whenbd uses the personal data we collect for the following specific and legitimate purposes:

Purpose	Legal Basis	Data Categories Used
Account creation and management	Contractual necessity	Registration data, identity data
Age and identity verification (KYC)	Legal obligation	Identity documents, date of birth
Processing deposits and withdrawals	Contractual necessity	Financial data, transaction data
Fraud prevention and security monitoring	Legitimate interests	Technical data, usage data, transaction data
Anti-money laundering (AML) compliance	Legal obligation	Identity data, financial data, transaction data
Responsible gaming monitoring	Legal obligation / Legitimate interests	Usage data, financial data, behavioural data
Customer support and dispute resolution	Contractual necessity	Communications data, account data
Platform analytics and improvement	Legitimate interests	Usage data, technical data (anonymised)
Promotional communications (with consent)	Consent	Email, mobile number, game preferences

whenbd will not use your personal data for any purpose not listed above without first notifying you and, where required by law, obtaining your explicit consent.

4. Data Sharing & Disclosure

whenbd does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipient strictly on a need-to-know basis and only to the extent necessary for the purposes described in Section 3:

• Payment Processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and our banking partners receive the minimum financial data needed to authorise and process your transactions.
• Identity Verification Providers: Third-party KYC service providers who assist whenbd in verifying player identities and documents may receive copies of identity documents. All such providers are contractually bound to process data only on whenbd's instructions.
• Game Technology Providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised player session data necessary to deliver their game content within the whenbd platform. They do not receive personally identifiable registration data.
• Analytics and Security Vendors: Providers of fraud detection, cybersecurity, and platform analytics services may process technical and usage data in anonymised or pseudonymised form.
• Legal and Regulatory Authorities: whenbd may disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where we are legally compelled to do so, or where we believe disclosure is necessary to prevent fraud, protect the safety of any person, or defend whenbd's legal rights.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of whenbd's assets, player data may be transferred to the successor entity. Players will be notified of any such transfer in advance.

All third parties with whom whenbd shares personal data are required to maintain appropriate technical and organisational security measures and to process data only in accordance with whenbd's instructions and applicable data protection principles.

5. Cookies & Tracking Technologies

5.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites function correctly, to remember your preferences, and to provide website operators with anonymised information about how their sites are used.

5.2 How whenbd Uses Cookies

whenbd uses the following categories of cookies on the platform:

• Strictly Necessary Cookies: These cookies are essential for the whenbd platform to function. They manage your login session, maintain your account security state, and enable core platform features such as the game lobby and deposit flow. These cookies cannot be disabled without preventing the platform from functioning correctly.
• Functional Cookies: These cookies remember your preferences — such as your preferred language (English), your display settings, and whether you have previously dismissed notices. They improve your experience but are not strictly essential.
• Analytics Cookies: whenbd uses anonymised analytics cookies to understand how players navigate the platform — which games are most popular, which pages have high exit rates, and where players encounter friction. This data is used exclusively to improve the whenbd platform and is never linked to identifiable player profiles.
• Security Cookies: These cookies help whenbd detect and prevent fraudulent activity, including automated bot traffic and account takeover attempts.

5.3 Managing Cookies

You can manage, restrict, or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will prevent you from logging in or using core platform features. Instructions for managing cookies in popular browsers are available at the browser's official help pages. whenbd does not use cross-site tracking cookies or behavioural advertising cookies.

6. Data Retention

whenbd retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal or regulatory obligations. Our standard data retention periods are as follows:

• Account and Registration Data: Retained for the duration of your active whenbd account and for a period of 5 years following account closure, in accordance with standard financial record-keeping requirements.
• KYC and Identity Documents: Retained for 5 years from the date of submission or from the date of account closure, whichever is later, to comply with anti-money laundering regulations.
• Transaction and Financial Records: Retained for a minimum of 5 years from the date of the transaction to comply with financial regulatory requirements.
• Customer Support Communications: Retained for 3 years from the date of the last interaction, or longer if the communication relates to an open dispute or legal proceeding.
• Anonymised Analytics Data: May be retained indefinitely in anonymised, aggregated form as it cannot be used to identify any individual player.
• Marketing Consent Records: Retained until you withdraw your consent, at which point your details are removed from marketing lists within 14 days.

When the applicable retention period expires, personal data is securely deleted from whenbd's systems or anonymised so that it can no longer be associated with any identifiable individual.

7. Your Privacy Rights

As a whenbd player, you have the following rights with respect to your personal data. To exercise any of these rights, please contact whenbd at [email protected] with the subject line "Data Rights Request":

• Right of Access: You have the right to request a copy of the personal data that whenbd holds about you. We will provide this within 30 days of receiving a valid request.
• 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 basic account information directly from your whenbd account settings.
• Right to Erasure ("Right to be Forgotten"): You may request that whenbd delete your personal data. Note that this right is not absolute — we may be required to retain certain data to comply with legal obligations (e.g., AML transaction records) even after your account is closed.
• Right to Restrict Processing: In certain circumstances, you may request that whenbd temporarily suspend the processing of your personal data — for example, while you contest the accuracy of data we hold.
• Right to Data Portability: You have the right to receive a copy of personal data you provided to whenbd in a structured, machine-readable format, and to request its transfer to another service provider where technically feasible.
• Right to Object: You may object to whenbd's processing of your personal data where that processing is based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

8. Data Security

whenbd employs a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your browser and the whenbd platform is encrypted using SSL/TLS technology. The whenbd website operates exclusively over HTTPS.
• Encrypted Data Storage: Personal data and financial records stored on whenbd's servers are encrypted at rest using AES-256 encryption.
• Access Controls: Access to player personal data is restricted to whenbd staff who require it to perform their specific job functions. All staff access is logged and audited.
• Two-Factor Authentication: whenbd's internal systems require multi-factor authentication for all staff accessing production data environments.
• Regular Security Audits: whenbd conducts periodic security assessments and penetration testing of its platform infrastructure to identify and address vulnerabilities proactively.
• Fraud Detection Systems: Real-time monitoring systems analyse transaction patterns and login behaviour to detect and flag suspicious activity for manual review.

While whenbd takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, whenbd will notify affected players without undue delay and take all necessary remedial action.

9. Third-Party Services

The whenbd platform integrates third-party services to deliver games, process payments, and support platform operations. These third-party providers operate under their own privacy policies, and whenbd is not responsible for the data practices of those providers beyond the contractual obligations we impose on them.

whenbd's game library includes content from providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may collect anonymised technical data — such as game session identifiers and RNG seed data — that is necessary to deliver their games. They do not receive your full whenbd profile or payment details.

Payment partners including bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, and Sonali Bank process your transactions under their own terms of service and privacy policies. whenbd recommends that you review the privacy policy of any payment provider you use.

whenbd's platform does not contain links to external third-party websites for advertising or affiliate purposes. Any link displayed on the platform leads to another section of whenbd.club or to one of the legal/utility pages listed in our site menu.

10. Children's Privacy

whenbd is strictly an adults-only platform. The minimum age requirement to register and play on whenbd is 18 years. whenbd does not knowingly collect personal data from individuals under the age of 18.

If whenbd discovers or is notified that a registered player is under 18 years of age, the account will be suspended immediately and all associated personal data will be deleted from our systems, except to the extent that we are legally required to retain records of the interaction for regulatory reporting purposes.

If you are a parent or guardian and you believe your child has registered a whenbd account, please contact us immediately at [email protected] with the subject line "Underage Account Report". We will investigate and take appropriate action within 48 hours of receiving your report.

11. Policy Updates

whenbd reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes to this Policy, we will notify registered players via the email address associated with their whenbd account or via an in-platform notification banner.

The updated Privacy Policy will be published on this page with a revised "Last Updated" date at the top. We encourage you to review this Policy periodically to stay informed about how whenbd is protecting your personal data.

Your continued use of the whenbd platform following notification of changes to this Policy constitutes your acceptance of the updated Policy. If you do not accept the revised Policy, you must stop using whenbd and request account closure as described in whenbd's Terms & Conditions.

12. Contact & Data Requests

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a privacy concern, please contact the whenbd privacy team using the details below:

• Email: [email protected] — use subject line "Privacy Policy Query" for general questions or "Data Rights Request" for formal data access/deletion requests.
• Live Chat: Available on the whenbd platform daily, 9:00 AM – 1:00 AM BST (UTC+6). For data rights requests, email is preferred to ensure a proper written record.
• Response Time: General privacy queries are answered within 4 hours during operating hours. Formal data rights requests are acknowledged within 5 business days and resolved within 30 calendar days.

whenbd is committed to resolving all privacy queries and data rights requests fairly, transparently, and within the timeframes stated above. Players who feel their privacy concern has not been addressed adequately are encouraged to resubmit their query with the subject line "Escalated Privacy Complaint" for priority review by a senior member of the whenbd team.