habee Privacy Policy

📄 1. Introduction

habee ("we", "us", "our") is the operator of the online casino and sports betting platform accessible at habee.app. We are committed to protecting the privacy and personal data of all players, visitors, and users who interact with the habee platform. This Privacy Policy describes how habee collects, uses, stores, shares, and protects personal information in connection with our services.

This policy has been drafted with reference to internationally recognised data protection principles, including those set out in the General Data Protection Regulation (GDPR) and comparable standards applied to the Bangladesh digital services market. habee applies these principles voluntarily as a matter of best practice to provide the highest level of data protection for our players.

This Privacy Policy applies to:

• All registered habee account holders, regardless of whether they are active or inactive;
• Visitors who browse the habee platform without registering an account;
• Any person who contacts habee support, participates in a promotion, or subscribes to habee communications;
• All devices and access methods, including desktop browsers, mobile browsers, and any habee-branded application.

This policy does not apply to third-party websites or services linked from the habee platform. habee is not responsible for the privacy practices of any third-party game provider, payment processor, or external site. We encourage you to review the privacy policies of those third parties independently.

🗂️ 2. Data We Collect

habee collects personal data through several channels: directly from you when you register or use the platform, automatically through your use of the platform (technical and behavioural data), and from trusted third parties where necessary for identity verification, fraud prevention, and payment processing.

2.1 Registration & Account Data

When you create a habee account, we collect the following mandatory information:

• Full legal name (as it appears on your government-issued identification)
• Date of birth (to verify you are aged 18 or above)
• Email address (used for account communications and verification)
• Mobile phone number (used for two-factor authentication and account notifications)
• Preferred payment method and associated account identifier (e.g., bKash mobile number, Nagad number)
• Residential address (city and district, e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi)
• Username and password (password is stored in hashed form; habee staff cannot view your plain-text password)

2.2 Identity Verification (KYC) Data

As part of habee's Know Your Customer (KYC) process, you may be asked to submit copies of one or more of the following documents. These are processed solely for identity verification and fraud prevention purposes:

• National Identity Card (NID) issued by the Bangladesh Election Commission
• Valid Bangladeshi passport (biodata page)
• Bangladesh driving licence
• Recent utility bill or bank statement (for proof of address)
• Screenshot or confirmation of payment method ownership (e.g., bKash registered name confirmation)

2.3 Transaction & Financial Data

habee records all financial transactions conducted through your account. This includes:

• Deposit amounts, timestamps, and payment method used (bKash, Nagad, Rocket, Upay, bank transfer, Visa, Mastercard)
• Withdrawal requests, amounts, destination payment method, and processing status
• Account balance history and adjustments
• Bonus credits, wagering activity, and bonus clearance status
• Any disputed transaction records and supporting correspondence

2.4 Gaming & Behavioural Data

habee automatically collects data relating to your activity on the platform:

• Games played, bet amounts, wager outcomes, session duration, and game-category preferences
• Sports betting selections, odds accepted, markets browsed, and bet settlement results
• Login timestamps, session lengths, device type, and geographic location at time of access (city-level only)
• Responsible gaming tool usage (e.g., deposit limits set, cool-off periods activated, self-exclusion requests)

2.5 Technical & Device Data

When you access the habee platform, we automatically collect certain technical information:

2.6 Support & Communication Data

When you contact habee's support team, we retain a record of all correspondence including the subject matter, timestamps, resolution status, and any attachments or screenshots shared during the interaction. This data is used to resolve your query, improve our support quality, and maintain an accurate account history.

⚙️ 3. How We Use Your Data

habee processes personal data only where we have a lawful basis to do so. The primary legal bases we rely on are: performance of a contract (your account agreement with habee), compliance with legal obligations, our legitimate interests in operating a safe and compliant platform, and in limited cases, your explicit consent.

3.1 Account Management & Platform Operation

• Creating, verifying, and maintaining your habee account
• Processing deposits, withdrawals, and account balance adjustments in BDT via bKash, Nagad, Rocket, and other supported methods
• Delivering the gaming and sports betting services you access on the platform
• Sending account-related notifications (deposit confirmations, withdrawal updates, security alerts, KYC requests)
• Enforcing the habee Terms & Conditions and resolving account disputes

3.2 Legal Compliance & Fraud Prevention

• Verifying that account holders meet the 18+ age requirement before allowing real-money play
• Conducting anti-money laundering (AML) checks and reporting suspicious transaction patterns as required by applicable standards
• Detecting and preventing the creation of duplicate accounts, bonus abuse, and other fraudulent activity
• Complying with lawful requests from regulatory bodies or law enforcement authorities with appropriate jurisdiction

3.3 Responsible Gaming

• Monitoring gameplay patterns to identify signs of problem gambling behaviour
• Enforcing player-set deposit limits, session-time reminders, cool-off periods, and self-exclusion requests
• Communicating with players who have shown indicators of excessive or compulsive gambling in accordance with habee's Responsible Gaming policy

3.4 Service Improvement & Analytics

• Analysing aggregated, anonymised gameplay and navigation data to improve platform performance and user experience
• Testing new features, games, and promotional formats with anonymised user cohorts
• Monitoring platform uptime, error rates, and load performance

3.5 Marketing Communications

With your consent at the point of registration or subsequently through your account notification settings, habee may send you promotional communications about new games, bonuses, seasonal offers (such as Eid promotions, Pohela Boishakh free bets, BPL cricket cashback offers, and T20 World Cup enhanced odds), and VIP loyalty programme updates. You may opt out of marketing communications at any time via your account settings or by contacting habee support. Opting out of marketing will not affect essential account or transaction notifications.

🤝 4. Data Sharing & Third Parties

habee does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the limited circumstances described below, and only to the minimum extent necessary for the stated purpose.

4.1 Payment Processors

To process deposits and withdrawals, habee shares relevant transaction data with our payment processing partners including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard. The data shared is limited to what is strictly necessary to complete the transaction (e.g., account identifier, amount, timestamp). Each payment partner operates under its own privacy policy and data security standards.

4.2 Game Providers

The games available on the habee platform are provided by licensed third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may receive a pseudonymous player identifier and session token necessary to deliver the game experience and record game outcomes for audit purposes. Your full identity details are not shared with game providers.

4.3 Identity Verification Partners

habee may use trusted third-party identity verification services to assist with KYC document checks. These partners process your identity documents solely for the purpose of confirming your name, date of birth, and document authenticity. They are contractually prohibited from using this data for any other purpose.

4.4 Legal & Regulatory Authorities

habee will disclose personal data to government bodies, regulatory authorities, or law enforcement agencies when required to do so by applicable law, a valid legal order, or court process. Where legally permissible, habee will notify the affected account holder before making such a disclosure.

4.5 Business Transfers

In the event that habee undergoes a merger, acquisition, restructuring, or sale of assets, player personal data may be transferred to the acquiring entity as part of that transaction. habee will notify registered players via their verified email address before any such transfer takes effect and will ensure that the receiving entity is bound by data protection standards no less protective than those described in this policy.

🍪 5. Cookies & Tracking Technologies

habee uses cookies and similar tracking technologies (including local storage, session storage, and pixel tags) to operate the platform efficiently, remember your preferences, maintain your login session, and analyse aggregate usage patterns. This section explains the types of cookies habee uses and how you can manage your cookie preferences.

5.1 Types of Cookies Used

5.2 Strictly Necessary Cookies

Strictly necessary cookies cannot be disabled as they are essential for the habee platform to function. They do not collect personal data beyond what is required for the current session and are deleted automatically when you close your browser or log out of your habee account.

5.3 Managing Your Cookie Preferences

You may configure your browser to refuse non-essential cookies or to alert you when cookies are being set. Please note that disabling functional or analytics cookies may affect certain platform features, such as saved preferences and personalised game recommendations. Most modern browsers — including Chrome, Firefox, Samsung Internet, and the browsers built into Grameenphone and Robi device bundles — provide accessible cookie management settings in their privacy or settings menu.

🗄️ 6. Data Retention

habee retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal obligations, and to resolve any disputes or enforce our agreements. The following retention periods apply as a general guide:

When the applicable retention period expires, habee securely deletes or anonymises the relevant personal data. Where deletion is not immediately possible due to backup schedules, the data is isolated from active processing until it can be securely erased.

If you request the deletion of your habee account, we will action that request within 30 days. However, please be aware that certain categories of data (particularly financial transaction records and KYC documents) must be retained for the legally mandated periods described above, even after account closure. Retained data is kept in a restricted-access archive and is not used for any marketing or operational purpose.

⚖️ 7. Your Data Rights

habee respects your rights as a data subject. The following rights are available to all habee account holders and visitors. To exercise any of these rights, please contact habee's support team via the in-account contact form.

7.1 Right of Access

You have the right to request a copy of all personal data habee holds about you. habee will provide this information within 30 days of a verified request, free of charge, in a structured and readable format. For complex or high-volume requests, this period may be extended by an additional 30 days, with notice provided to you.

7.2 Right to Rectification

If any personal data habee holds about you is inaccurate, incomplete, or outdated, you have the right to request that we correct or update it. You may update basic account information (such as your mobile number and email address) directly via your habee account settings. For corrections to identity documents or legal name, please contact habee support.

7.3 Right to Erasure ("Right to be Forgotten")

You may request the 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 the data has been unlawfully processed. habee will assess each erasure request on a case-by-case basis. Certain data categories (financial records, KYC documents) are subject to mandatory retention periods and cannot be deleted ahead of those periods.

7.4 Right to Restriction of Processing

You may request that habee restricts the processing of your data in certain circumstances — for example, while a dispute about data accuracy is being resolved, or where you have objected to processing and habee is considering your objection. During a restriction, habee will continue to store your data but will not actively process it for operational purposes.

7.5 Right to Data Portability

Where processing is based on your consent or on a contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format (such as JSON or CSV) for transfer to another service provider. habee will provide a portability export within 30 days of a verified request.

7.6 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing carried out on the basis of habee's legitimate interests, in which case habee will stop processing unless it can demonstrate compelling legitimate grounds that override your interests.

7.7 Rights Related to Automated Decision-Making

habee uses automated systems to flag potentially fraudulent activity, duplicate accounts, and problem gambling patterns. Where a significant decision affecting your account (such as a temporary suspension or withdrawal hold) is made by an automated process alone, you have the right to request human review of that decision by contacting habee support.

🛡️ 8. Security Measures

habee implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security programme is reviewed and updated continuously to address emerging threats.

8.1 Technical Security Controls

• 256-bit SSL/TLS encryption: All data transmitted between your device and the habee platform is encrypted using industry-standard TLS 1.2 or higher. The habee.app domain maintains a valid SSL certificate at all times.
• Password hashing: Account passwords are hashed using a modern, salted algorithm. habee staff have no ability to view plain-text passwords at any time.
• Two-factor authentication (2FA): habee strongly encourages all players to enable 2FA on their accounts. 2FA codes are delivered via SMS to the registered mobile number (compatible with Grameenphone, Robi, Banglalink, and Teletalk SIMs).
• Intrusion detection: habee's infrastructure is monitored 24/7 by automated intrusion detection systems. Anomalous login attempts trigger immediate account security alerts.
• Data isolation: Player financial data, KYC documents, and gaming records are stored in logically separate, access-controlled environments with role-based access restrictions for habee staff.
• Regular penetration testing: habee engages independent security specialists to conduct penetration tests of the platform on a periodic basis. Critical findings are remediated on a priority basis.

8.2 Organisational Security Controls

• Access to player personal data is granted on a strict need-to-know basis. habee staff are granted only the minimum data access required for their specific role.
• All habee staff with access to personal data are bound by confidentiality obligations and receive data protection training.
• Third-party service providers are vetted for security compliance before being granted any access to habee systems or player data.
• habee maintains an incident response plan. In the event of a data breach affecting your personal data, habee will notify affected players without undue delay and will take immediate remediation steps.

8.3 Your Role in Account Security

While habee takes extensive measures to protect the habee platform, account security is a shared responsibility. habee recommends that all players:

• Use a strong, unique password for their habee account — do not reuse passwords from other platforms.
• Enable two-factor authentication (2FA) in account settings.
• Never share account credentials with any other person, including anyone claiming to be a habee staff member. habee will never ask for your password.
• Log out of their habee account when using a shared or public device.
• Contact habee support immediately if they notice any unrecognised login activity or unexplained account changes.

📬 9. Contact & Data Protection

If you have any questions, concerns, or requests relating to this Privacy Policy or habee's handling of your personal data, please contact habee's support team. habee operates a dedicated data protection function responsible for overseeing compliance with this policy.

9.1 How to Contact habee

The preferred channel for all privacy-related enquiries is through the in-account support form, available after logging in to your habee account. For users who are unable to access their account, privacy-related enquiries may also be submitted by emailing habee's support team directly. All communications are handled in English and responses are provided in English.

Contact details for privacy enquiries:

• Support Email: [email protected]
• Response Time: Within 5 business days (Bangladesh Standard Time, UTC+6)
• Operating Hours: Monday to Sunday, 09:00 – 23:00 BST

9.2 Policy Updates

habee reserves the right to update or amend this Privacy Policy at any time. Where changes are material — for example, where habee introduces a new category of data collection, a new purpose for processing, or a new category of third-party sharing — registered players will be notified via their verified email address at least 14 days before the changes take effect. Minor updates (such as corrections to contact details or clarifications that do not alter the substance of the policy) may be made without advance notice. The date at the top of this page will always reflect the most recent revision.

Continued use of the habee platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any changes to this policy, you should discontinue use of the habee platform and may request account closure by contacting habee support.

9.3 Children & Age Restriction

The habee platform is strictly for adults aged 18 years and above. habee does not knowingly collect personal data from any person under the age of 18. If habee becomes aware that personal data has been collected from a minor, that data will be deleted immediately and the associated account will be permanently closed. If you believe a minor has registered an account on the habee platform, please notify habee support immediately so that the matter can be investigated and resolved without delay.