Privacy Policy for ppee

ppee ("we", "our", "us") is committed to protecting the privacy and personal data of all users of the ppee platform at ppee.io (the "Platform"). This Privacy Policy has been prepared to provide full transparency regarding our data handling practices in accordance with applicable international data protection standards and gaming regulatory requirements.

This policy applies to all personal data collected from players based in Bangladesh and any other jurisdiction in which ppee operates. It covers data collected through the ppee website, mobile-compatible web application, customer support channels (email, WhatsApp, and live chat), and all interaction logs generated during your use of the Platform's products, including sports betting, live casino, slot games, and crash games.

Throughout this document, "personal data" means any information that identifies you or that could reasonably be used to identify you, either alone or in combination with other data held by ppee. "Processing" means any operation performed on personal data, including collection, storage, use, disclosure, and deletion.

ppee is an online betting and casino platform operating at ppee.io and serving players primarily in the Bangladesh market. ppee operates under an international gaming licence and is the data controller responsible for the personal data collected through the Platform.

As data controller, ppee determines the purposes and means by which your personal data is processed. Where ppee engages third-party service providers to process data on its behalf, those providers act as data processors under written data processing agreements that bind them to the same data protection standards described in this policy.

If you have questions about our role as data controller or wish to exercise any of your data rights, please contact us using the details provided in Section 15 of this policy.

ppee collects personal data in the following ways:

3.1 Data You Provide Directly

• Registration data: full name, date of birth, email address, Bangladesh mobile number, and chosen password when you create a ppee account.
• Identity verification documents: scanned copies or photographs of government-issued identification (National ID card, passport, or driving licence) submitted as part of our KYC process.
• Payment data: mobile financial service account numbers (bKash, Nagad, Rocket, Upay, SureCash), and the last four digits and expiry date of any Visa or Mastercard used for deposits.
• Support communications: the content of any email, live chat, or WhatsApp messages you send to ppee customer support.
• Responsible gaming data: deposit limits, loss limits, self-exclusion elections, and session reminder preferences you configure in your account dashboard.

3.2 Data Collected Automatically

• Technical data: IP address, device type (desktop, mobile, tablet), operating system, browser type and version, screen resolution, and approximate geographic location derived from IP address.
• Usage data: pages visited, features accessed, time spent on each page, betting and gaming activity logs, session start and end times, and error logs.
• Cookie and tracking data: identifiers set by ppee's own cookies and, where applicable, by authorised third-party analytics providers. See Section 6 for full details of our cookie practices.

3.3 Data Received from Third Parties

• Identity verification providers: confirmation of identity and age from third-party KYC services where automated verification is used.
• Payment processors: transaction status updates, fraud flags, and chargeback notifications from bKash, Nagad, Rocket, Visa, and Mastercard processing networks.
• Fraud prevention services: risk scores and device fingerprinting data from third-party fraud detection providers used to protect player accounts.

ppee uses the personal data it collects for the following specific purposes:

• Account creation and management: to register your account, verify your identity, maintain your profile, and enable you to access all ppee products.
• Age verification: to confirm that you are 21 years of age or older before permitting access to real-money betting and gaming products, in compliance with ppee's strict 21+ policy.
• Payment processing: to execute deposits, process withdrawal requests, and maintain accurate financial records of all transactions conducted on your ppee account.
• Fraud and AML prevention: to monitor for suspicious activity, detect potential money laundering, identify multi-accounting, and protect the integrity of the ppee platform.
• Customer support: to respond to your queries, resolve disputes, investigate complaints, and provide technical assistance.
• Responsible gaming: to monitor your betting and gaming patterns, apply the responsible gaming limits you have set, and proactively reach out where our systems flag potential signs of problem gambling behaviour.
• Legal compliance: to fulfil our obligations under applicable gaming regulations, anti-money laundering laws, and any lawful request from regulatory or law enforcement authorities.
• Platform improvement: to analyse usage patterns, identify technical issues, test new features, and improve the overall quality and security of the ppee platform.
• Marketing communications: to send you promotional offers, deposit bonus notifications, and platform updates — but only where you have given explicit consent to receive such communications. You may withdraw marketing consent at any time.

ppee processes your personal data only where a valid legal basis exists. The legal bases we rely on are as follows:

• Contract performance: Processing necessary to perform the contract between you and ppee — i.e., to operate your betting account, process transactions, and deliver gaming products you have requested.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, gaming licence conditions, and Know Your Customer requirements that mandate identity and age verification.
• Legitimate interests: Processing necessary for ppee's legitimate business interests, provided those interests are not overridden by your rights and freedoms. This includes fraud prevention, security monitoring, platform analytics, and responsible gaming oversight.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — used for marketing communications and for non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

ppee uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

The categories of cookies used by ppee are as follows:

• Strictly necessary cookies: Essential to the operation of the Platform. These cookies enable core functions such as secure login session management, anti-fraud token validation, and load balancing. They cannot be disabled without preventing you from using the Platform.
• Functional cookies: Used to remember your preferences (such as preferred language and responsible gaming settings) so that you do not have to re-enter them on each visit.
• Analytics cookies: Used by ppee's internal analytics systems to understand how users navigate the Platform, which pages generate errors, and how features are used. This data is aggregated and does not identify individual users by name.
• Marketing cookies: Where you have given consent, these cookies help ppee understand which promotional content you have engaged with, so that future communications can be made more relevant to your stated preferences.

You can manage your cookie preferences at any time through the cookie settings panel accessible from the footer of the ppee website. Blocking certain cookies may affect the functionality of the Platform.

ppee does not sell your personal data. We do not share your data with third parties for their own marketing purposes. Personal data is disclosed to third parties only in the following limited circumstances:

• Payment service providers: Your payment data is shared with the relevant processor (bKash, Nagad, Rocket, Upay, SureCash, Visa, Mastercard) solely for the purpose of completing your requested deposit or withdrawal transaction.
• Identity verification providers: Your identity documents and personal details may be shared with our licensed KYC partner for the purpose of verifying your age and identity in accordance with our legal obligations.
• Fraud prevention services: Technical data and transaction patterns may be shared with our fraud detection service providers to identify and prevent unauthorised account access and financial crime.
• Game software providers: Your account identifier and session token are shared with game providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) solely to authenticate your session and enable gameplay. These providers do not receive your full identity data.
• Regulatory and law enforcement authorities: ppee will disclose personal data to competent regulatory bodies or law enforcement agencies where required to do so by law, court order, or lawful regulatory request.
• Corporate restructuring: In the event of a merger, acquisition, or sale of all or part of ppee's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and of any material change to how your data will be processed before the transfer takes effect.

All third-party processors engaged by ppee are bound by written data processing agreements that prohibit them from using your data for any purpose other than the specific service they provide to ppee.

As an international online gaming platform, ppee may transfer your personal data to servers or service providers located outside Bangladesh. Where such transfers occur, ppee ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that provided under applicable data protection laws.

Safeguards employed by ppee for international transfers include:

• Contractual clauses in agreements with data processors that impose data protection obligations equivalent to applicable legal standards.
• Transferring data only to processors located in jurisdictions or operating under frameworks that provide an adequate level of data protection.
• Encrypting data in transit across all international transfer pathways using TLS 1.2 or higher.

If you would like further information about the specific safeguards applied to any international transfer of your personal data, please contact ppee support using the details in Section 15.

ppee retains personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by applicable law. The specific retention periods applied by ppee are as follows:

• Active account data: Retained for the full duration of your account relationship with ppee, plus a minimum of five years following permanent account closure.
• KYC / identity documents: Retained for a minimum of five years from the date of verification, in accordance with anti-money laundering regulations applicable to licensed gaming operators.
• Financial transaction records: Retained for a minimum of seven years from the date of each transaction, in line with financial record-keeping obligations.
• Support communications: Retained for a period of three years from the date of the most recent communication, to facilitate dispute resolution.
• Technical / log data: Retained for up to 12 months and then securely deleted or anonymised.
• Marketing consent records: Retained for the duration of your account relationship plus three years, to evidence the basis on which marketing was sent.

Upon expiry of the applicable retention period, personal data is either permanently deleted using secure erasure methods or irreversibly anonymised so that it can no longer be associated with an identifiable individual.

As a data subject, you have the following rights in relation to the personal data ppee holds about you. To exercise any of these rights, please contact ppee support at [email protected] with the subject line "Data Rights Request".

• Right of Access: You have the right to request a copy of all personal data ppee holds about you, together with information about how it is processed. ppee will respond to access requests within 30 calendar days.
• Right to Rectification: You have the right to request that ppee correct any inaccurate or incomplete personal data held about you. Where a correction is requested in relation to KYC data, we may ask you to submit updated documentation.
• Right to Erasure ("Right to be Forgotten"): You may request that ppee delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been processed unlawfully. This right is subject to ppee's legal obligation to retain certain data for specified minimum periods as described in Section 9.
• Right to Restriction of Processing: You may request that ppee restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of whether ppee's legitimate interests override your rights.
• Right to Data Portability: Where processing is based on your consent or on contract performance and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.
• Right to Object: You have the right to object at any time to processing based on ppee's legitimate interests, including profiling. ppee will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for the establishment, exercise, or defence of legal claims.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

The ppee platform is strictly intended for adults aged 21 years and above. ppee does not knowingly collect personal data from any person under the age of 21. All registration attempts are subject to mandatory age verification checks.

If ppee becomes aware that personal data has been collected from an individual who is under 21 years of age, we will immediately suspend the relevant account, delete or quarantine the collected data, return any deposits where technically possible, and forfeit any winnings in accordance with our Terms & Conditions.

If you believe that a minor may have registered an account on the ppee platform, please contact us immediately at [email protected]. ppee takes all reports of underage access seriously and will investigate promptly.

Parents and guardians are encouraged to make use of internet filtering tools and parental control software to prevent minors from accessing online gambling services. ppee supports the use of third-party parental control tools and will co-operate fully with any parental request to block access to ppee.io.

ppee implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Key security measures include:

• SSL/TLS encryption: All data transmitted between your browser or device and the ppee platform is encrypted using TLS 1.2 or TLS 1.3 protocols.
• Data-at-rest encryption: Sensitive personal data stored in ppee's databases, including identity documents and payment data, is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within ppee's systems is restricted to authorised personnel on a strict need-to-know basis. Access is controlled through role-based permissions and multi-factor authentication.
• Regular security audits: ppee's platform and infrastructure undergo periodic security assessments and penetration testing conducted by qualified independent security professionals.
• Incident response: ppee maintains a formal data breach response procedure. In the event of a security incident affecting your personal data, ppee will notify you and the relevant regulatory authority within the timeframes required by applicable law.

While ppee takes all reasonable precautions to secure your data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your ppee account credentials. If you suspect that your account has been compromised, contact ppee support immediately.

The ppee platform may contain references to third-party payment providers and game studios whose services are integrated into the Platform. Where you interact directly with a third-party service (such as initiating a bKash payment through the bKash interface), that interaction is governed by the third party's own privacy policy and terms of service.

ppee is not responsible for the privacy practices of any third-party service provider. We recommend that you review the privacy policies of any third-party service through which you transact. ppee does not endorse, and is not liable for, the data practices of any third party linked to or integrated within the Platform.

ppee reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or the services we offer. When a material change is made to this policy, ppee will:

• Update the "Last Updated" date displayed at the top of this page.
• Post a prominent notice on the ppee platform informing registered users of the change.
• Where the change materially affects how we process your personal data, send a direct notification to your registered email address at least 14 calendar days before the change takes effect.

Your continued use of the ppee platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you must cease using the Platform and may request account closure by contacting ppee support.

We encourage you to review this Privacy Policy periodically to stay informed about how ppee protects your personal data. The most current version of the policy will always be accessible at ppee.io/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how ppee has handled your personal data, please contact our Data Protection team using the details below:

• Email: [email protected] (Subject line: "Privacy / Data Rights")
• WhatsApp: +880 1700 000 000
• Live Chat: Available 24/7 via your ppee account dashboard

ppee aims to respond to all privacy-related enquiries within 5 business days and to resolve formal data rights requests within 30 calendar days of receipt of a verified request.

If you are not satisfied with ppee's response to your privacy complaint, you have the right to escalate your complaint to the relevant data protection supervisory authority or gaming regulatory body in the jurisdiction under which ppee holds its operating licence.