Privacy Policy — jubali Bangladesh

1. Introduction

This Privacy Policy ("Policy") describes how jubali ("jubali", "we", "us", "our"), the operator of the online gaming and sports betting platform at jubali.club ("Platform"), collects, uses, stores, shares, and protects personal data relating to individuals who visit, register with, or interact with the Platform ("you", "Player", "User").

jubali operates primarily for the benefit of players in Bangladesh. All services are delivered in the English language. All monetary amounts processed through the Platform are denominated in Bangladeshi Taka (৳). jubali takes the privacy of its players seriously and is committed to handling personal data in a fair, transparent, and secure manner consistent with applicable data protection principles.

This Policy should be read alongside jubali's Terms & Conditions and Responsible Gaming Policy. Where any conflict exists between this Policy and those documents on the subject of personal data, this Policy prevails.

2. Data Controller

jubali is the data controller in respect of personal data collected through the Platform. This means jubali determines the purposes for which and the manner in which your personal data is processed. jubali is responsible for ensuring that personal data is handled in accordance with this Policy.

jubali's designated point of contact for all privacy-related inquiries is the Privacy Team. You may reach the Privacy Team at any time using the contact details set out in Section 15 of this Policy. jubali will acknowledge all privacy inquiries and respond substantively within a reasonable period.

3. Categories of Personal Data jubali Collects

jubali collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Identity and Registration Data

• Full legal name
• Date of birth (to verify minimum age of 18)
• Username chosen during registration
• Government-issued identification details (National ID number, passport number, or driving licence number) collected during KYC verification
• Gender (optional, where provided)

3.2 Contact Data

• Email address
• Mobile telephone number
• Residential address (collected during KYC verification)
• City and district within Bangladesh (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh)

3.3 Financial and Transaction Data

• Deposit and withdrawal amounts in Bangladeshi Taka (৳)
• Payment method details (bKash account number, Nagad account number, Rocket account number, Upay account, or bank account reference — not full card numbers)
• Transaction timestamps and reference numbers
• Account balance history

3.4 Gaming and Betting Activity Data

• Bets placed, games played, and wagering history
• Game session durations
• Bonus and promotion usage
• Win and loss records
• Sports betting markets accessed (cricket, football, kabaddi, and others)

3.5 Technical and Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type
• Unique device identifiers
• Session logs, login timestamps, and page navigation data

3.6 Communications Data

• Records of live chat conversations with jubali's support team
• Email correspondence with jubali
• Responses to surveys or feedback requests (where you choose to participate)

4. How jubali Collects Your Personal Data

jubali collects personal data through the following mechanisms:

• Direct provision by you: When you register an account, complete KYC verification, deposit or withdraw funds, contact support, or respond to a survey, you provide data directly to jubali.
• Automated collection: jubali's Platform automatically collects technical and device data when you access the Platform, using cookies, server logs, and similar technologies. See Section 12 for more detail on cookies.
• Third-party sources: jubali may receive data from identity verification providers (to confirm your identity during KYC), payment processors (to confirm transaction success), and fraud prevention services (to check for suspicious activity patterns).

5. How jubali Uses Your Personal Data

jubali uses personal data for the following purposes:

Purpose	Data Categories Used
Account creation and management — setting up and maintaining your jubali account	Identity, Contact
Age and identity verification (KYC) — confirming you meet the 18+ eligibility requirement	Identity, Contact
Payment processing — handling deposits and withdrawals via bKash, Nagad, Rocket, Upay, and partner banks	Financial, Identity
Delivering gaming services — running games, processing bets, and calculating outcomes	Gaming Activity, Technical
Responsible gaming monitoring — detecting patterns of potentially problematic gambling behaviour and applying player-requested limits	Gaming Activity, Financial
Fraud prevention and security — detecting suspicious activity, preventing multi-accounting, and protecting Platform integrity	Technical, Identity, Financial
Anti-money-laundering (AML) compliance — monitoring transactions for suspicious patterns	Financial, Identity
Customer support — responding to queries, complaints, and account assistance requests	Communications, Identity, Gaming Activity
Promotional communications — sending offers and promotions (where you have opted in)	Contact, Gaming Activity
Platform improvement — analysing usage patterns to improve jubali's products and services	Technical, Gaming Activity (aggregated/anonymised)

6. Legal Bases for Processing

jubali processes personal data on the following legal bases:

• Performance of a contract: Processing necessary to create and manage your jubali account, process payments, and deliver gaming services is carried out to perform the agreement between you and jubali.
• Legal obligation: Processing required for KYC identity verification, AML compliance, responsible gaming record-keeping, and responding to lawful requests from regulatory or law enforcement authorities is carried out to comply with applicable legal obligations.
• Legitimate interests: Processing for fraud prevention, Platform security, abuse detection, and aggregate analytics is carried out on the basis of jubali's legitimate interest in protecting its Platform and its players, where that interest is not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications (e.g., promotional emails about jubali offers, BPL cricket betting promotions, Eid bonuses) is carried out on the basis of your consent, which you may withdraw at any time by updating your notification preferences in your account settings or by contacting the Privacy Team.

7. Sharing Your Personal Data

jubali does not sell your personal data. jubali may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment service providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and other payment partners receive transaction data necessary to process your deposits and withdrawals. These providers process data under their own privacy policies and are independently regulated.
• Identity verification providers: Third-party KYC and identity verification services receive identity and contact data to confirm your eligibility and comply with AML requirements. These providers process data under binding data processing agreements.
• Game software providers: Providers such as Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, and Microgaming receive session and technical data necessary to deliver their games within the jubali Platform. They do not receive your full identity or financial data.
• Fraud and security services: Specialist fraud prevention providers receive technical and transactional data to detect and prevent suspicious activity on jubali's Platform.
• Legal and regulatory authorities: jubali may disclose personal data to competent authorities, regulators, law enforcement bodies, or courts where required by applicable law, including disclosures related to AML investigations.
• Professional advisers: jubali's legal, accounting, and auditing advisers may access personal data on a confidential, need-to-know basis in connection with the provision of professional services to jubali.

8. International Data Transfers

Some of jubali's third-party service providers — including game software providers and certain technical infrastructure partners — may be located outside Bangladesh. Where personal data is transferred to providers in other countries, jubali ensures that appropriate safeguards are in place to protect your data. These safeguards may include standard contractual clauses, binding corporate rules, or equivalent data transfer mechanisms that provide a level of protection substantively equivalent to that applied within Bangladesh.

jubali will not transfer your personal data internationally in circumstances where adequate safeguards cannot be put in place. If you have questions about the safeguards applicable to any particular transfer, you may contact jubali's Privacy Team using the details in Section 15.

9. How Long jubali Retains Your Data

jubali retains your personal data for as long as your jubali account is active and for a reasonable period thereafter, consistent with the following retention principles:

• Active account data: Retained for the duration of your jubali account and for a minimum period of five (5) years after account closure, to satisfy AML and responsible gaming record-keeping obligations.
• Transaction records: Financial transaction records are retained for a minimum of five (5) years from the date of each transaction.
• KYC verification documents: Identity documents are retained for the period required by applicable AML regulations from the date of verification or account closure, whichever is later.
• Support communications: Live chat transcripts and email correspondence are retained for up to three (3) years from the date of the interaction.
• Marketing data: If you have consented to marketing communications and later withdraw consent, your contact details will be removed from marketing lists within a reasonable period. A suppression record may be retained to ensure your opt-out preference is honoured.
• Technical logs: Server and access logs are retained for up to twelve (12) months and are then deleted or anonymised.

When personal data is no longer required, jubali will securely delete or irreversibly anonymise it so that it can no longer be associated with you as an individual.

10. Security Measures

jubali implements a range of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and jubali's servers
• Encryption at rest for sensitive data fields stored in jubali's databases
• Access controls ensuring that internal access to personal data is limited to employees whose job functions require it
• Regular security assessments and vulnerability testing of the Platform's infrastructure
• Multi-factor authentication options for Player accounts
• Incident response procedures for promptly addressing potential data security events

While jubali takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. jubali cannot guarantee absolute security. If you have reason to believe your jubali account has been compromised, please contact jubali's support team immediately at [email protected].

11. Your Data Rights

As a jubali player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact jubali's Privacy Team using the details in Section 15:

11.1 Right of Access

You may request a copy of the personal data jubali holds about you, along with information about how it is used. jubali will provide this information within a reasonable period of receiving a valid request.

11.2 Right to Rectification

If you believe any personal data jubali holds about you is inaccurate or incomplete, you may request that jubali correct or complete it. Many basic account details (such as contact information) can be updated directly within your jubali account settings.

11.3 Right to Erasure

You may request that jubali delete your personal data in certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected. Note that jubali may be required to retain certain data for legal and regulatory compliance reasons (e.g., AML record-keeping) even where an erasure request is made. jubali will explain any such limitations when responding to your request.

11.4 Right to Object to Marketing

You may object to jubali processing your personal data for direct marketing purposes at any time. You may exercise this right by updating your notification preferences in your account settings or by contacting jubali's Privacy Team directly. jubali will act on your objection without delay.

11.5 How to Submit a Data Rights Request

All data rights requests should be submitted in writing to jubali's Privacy Team at the email address provided in Section 15. jubali may need to verify your identity before acting on a request to ensure that personal data is not disclosed to, or acted upon at the instruction of, an unauthorised third party. jubali will respond to all valid requests within a reasonable timeframe.

12. Cookies and Tracking Technologies

jubali uses cookies and similar tracking technologies on the Platform to provide core functionality, enhance the user experience, and collect analytics data. The categories of cookies jubali uses include:

• Strictly necessary cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in as you navigate between pages. These cookies cannot be disabled without disrupting core Platform functionality.
• Functional cookies: Remember your preferences (such as language settings and notification preferences) to personalise your experience.
• Analytics cookies: Collect aggregated, anonymised information about how Players navigate the Platform, which pages are most visited, and where technical errors occur. jubali uses this data to improve the Platform's performance and user experience.
• Security cookies: Help detect and prevent fraudulent account access and protect the integrity of the Platform.

jubali does not use third-party advertising or behavioural targeting cookies that track your activity across other websites. Your browser settings may allow you to control or disable cookies; however, disabling strictly necessary cookies will affect your ability to use the jubali Platform. More information about managing cookies can be found in your browser's help documentation.

13. Minors and Age Protection

jubali's Platform is strictly for adults aged 18 and above. jubali does not knowingly collect personal data from individuals under the age of 18. If jubali discovers that personal data has been submitted by or on behalf of a person under 18, that data will be deleted immediately, the relevant account will be closed, and any associated funds will be dealt with in accordance with jubali's Terms & Conditions.

jubali encourages parents and guardians to use available parental control tools to prevent underage individuals from accessing online gaming platforms. If you believe a minor has registered or attempted to register on jubali, please contact jubali's support team at [email protected] immediately.

14. Changes to This Privacy Policy

jubali reserves the right to update or amend this Privacy Policy at any time to reflect changes in jubali's data practices, Platform features, or applicable legal requirements. When material changes are made, jubali will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending an email notification to the address registered on your account. The revised Policy will take effect on the date specified in the notice.

Your continued use of the jubali Platform following the effective date of a revised Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the revised Policy, you should cease using the Platform and may close your account in accordance with the account closure procedure described in jubali's Terms & Conditions. jubali encourages you to review this Policy periodically to stay informed about how your personal data is protected.

15. How to Contact jubali About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or jubali's data practices, please contact jubali's Privacy Team using the following details:

• Privacy Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the jubali Platform
• Response Time: jubali aims to respond to all privacy inquiries within 5 business days
• Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)

jubali serves players across Bangladesh — including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, and Mymensingh — and welcomes privacy inquiries from any registered player regardless of location within Bangladesh.