zitben Privacy Policy

1 Introduction

zitben operates as an online casino and sports betting platform serving players in Bangladesh. As part of delivering that service, we necessarily collect and process certain personal information about you. We take that responsibility seriously. This Policy sets out our practices in a transparent and straightforward manner so that you can make informed decisions about your personal data at every stage of your relationship with zitben.

This Policy applies to all personal data collected through the zitben website at https://zitben.app, through any mobile-optimised version of the platform, and through any communications between you and the zitben support team. It should be read alongside the zitben Terms & Conditions and Responsible Gaming policy, both of which form part of the overall agreement governing your use of the platform.

2 Personal Data We Collect

zitben collects personal data in three principal ways: information you provide directly, information generated automatically by your use of the platform, and information obtained from trusted third-party verification services. The categories of data we collect are set out in the table below.

Category	Examples	How Collected
Identity Data	Full legal name, date of birth, National ID number, passport number	Provided by you at registration or during KYC verification
Contact Data	Email address, mobile phone number, residential address	Provided by you at registration
Financial Data	bKash/Nagad/Rocket account numbers, transaction history, deposit and withdrawal amounts in BDT	Provided by you when transacting; automatically recorded by our payment system
Account Data	Username, encrypted password, account balance, betting history, bonus history	Created at registration; generated automatically through platform use
Technical Data	IP address, device type, browser type and version, operating system, session tokens	Collected automatically via cookies and server logs
Usage Data	Pages visited, games played, time spent on platform, click patterns, search queries	Collected automatically via analytics tools
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Generated when you contact our support team
Verification Data	Copies of government-issued ID, utility bills, payment method screenshots	Provided by you during KYC document verification

3 How We Use Your Personal Data

zitben processes your personal data for the following specific purposes. We do not use your data for any purpose that is incompatible with those listed here without first obtaining your explicit consent.

3.1 Account Management and Service Delivery

We use your identity and contact data to create and manage your zitben account, authenticate your zitben login sessions, respond to your support enquiries, and send you essential service notifications such as transaction confirmations and security alerts. This processing is necessary for the performance of our contract with you.

3.2 Payment Processing

Your financial data is processed to facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard. We pass the minimum necessary financial information to our payment processing partners to execute your transactions securely in BDT.

3.3 Identity Verification and Fraud Prevention

We use your identity and verification data to confirm that you meet the eligibility requirements to use the zitben platform — including the 18+ age requirement — and to detect, investigate, and prevent fraudulent activity, money laundering, and other financial crimes. This processing is necessary for compliance with our legal obligations and for the pursuit of our legitimate interest in maintaining platform integrity.

3.4 Responsible Gaming Obligations

Your account and usage data enables us to monitor gambling behaviour patterns, identify players who may be at risk of problem gambling, and fulfil our responsible gaming duties. This includes enforcing self-exclusion requests, deposit limits, and cooling-off periods set by you or applied by our responsible gaming team.

3.5 Platform Improvement and Analytics

We use technical and usage data in aggregated, anonymised form to analyse how players navigate the zitben platform, which games are most popular, and where the user experience can be improved. This analysis is conducted in our legitimate interest to provide a better and more reliable service.

3.6 Marketing Communications

With your explicit consent, we may send you promotional emails, SMS notifications, or in-platform messages about new games, bonus offers, and special promotions relevant to the Bangladesh market. You may withdraw your consent to marketing communications at any time by contacting support at support@zitben.app or by using the unsubscribe option in any marketing email.

4 Legal Basis for Processing

zitben processes your personal data on one or more of the following legal grounds depending on the specific processing activity:

• Contractual Necessity: Processing required to perform the contract between you and zitben (e.g., creating your account, processing deposits and withdrawals, settling bets)
• Legal Obligation: Processing required to comply with applicable legal requirements (e.g., identity verification, anti-money laundering checks, age verification, record-keeping obligations)
• Legitimate Interests: Processing necessary for zitben's legitimate business interests, provided those interests are not overridden by your privacy rights (e.g., fraud prevention, platform security, internal analytics, improving customer service)
• Consent: Processing based on your freely given, specific, and informed consent (e.g., sending marketing communications, using non-essential analytics cookies)

5 Data Sharing and Disclosure

zitben does not sell your personal data. We do not share it with advertisers, data brokers, or unrelated commercial third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

5.1 Payment Service Providers

When you make a deposit or request a withdrawal, we transmit the necessary financial and identity data to the relevant payment provider (bKash, Nagad, Rocket, Upay, Visa, Mastercard) to process your transaction. These providers are bound by their own privacy obligations and are not permitted to use your data for any other purpose.

5.2 Identity Verification Services

During KYC verification, we may share your identity documents with specialist third-party verification providers who check the authenticity of documents on our behalf. These providers process data solely on our instructions and under strict confidentiality obligations.

5.3 Game Technology Providers

Our casino games are powered by third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. A session token and anonymised player identifier are shared with the relevant provider when you launch a game. No directly identifying personal data is shared with game studios beyond what is required to run the game session.

5.4 Legal and Regulatory Authorities

zitben may disclose your personal data to relevant authorities, law enforcement agencies, or regulatory bodies where we are legally required to do so, or where such disclosure is necessary to protect the rights, property, or safety of zitben, our players, or the general public.

5.5 Corporate Transactions

In the event of a merger, acquisition, or sale of all or part of zitben's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to how your data is processed as a result.

6 Data Retention

zitben retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The general retention periods we apply are as follows:

Data Category	Retention Period	Reason
Account and identity data	Duration of account + 5 years after closure	Legal and regulatory compliance
Financial transaction records	7 years from transaction date	Anti-money laundering obligations
KYC verification documents	5 years after account closure	Regulatory record-keeping requirements
Support communications	3 years from last interaction	Quality assurance and dispute resolution
Technical and usage data (logs)	12 months on a rolling basis	Security monitoring and fraud detection
Marketing consent records	Until consent is withdrawn + 2 years	Evidence of lawful basis for marketing

When the applicable retention period expires, personal data is securely deleted or irreversibly anonymised in accordance with our internal data destruction procedures.

7 Cookies and Tracking Technologies

7.1 What We Use Cookies For

The zitben platform uses cookies and similar tracking technologies (including local storage and session tokens) for the following purposes:

• Essential cookies: Required for the platform to function. These maintain your login session, remember your language and display preferences, and protect against cross-site request forgery (CSRF). These cannot be disabled without significantly impairing platform functionality.
• Analytics cookies: Used to understand how players navigate and use the zitben platform in aggregate. Data collected by analytics cookies is anonymised before analysis and is not linked back to your personal identity.
• Performance cookies: Help us identify and resolve technical errors, measure page load speeds, and optimise the zitben experience across different devices and browsers.

zitben does not use third-party advertising or retargeting cookies. No cookies are used to build profiles of you for use by external advertisers.

7.2 Managing Your Cookie Preferences

You can control and manage cookies through your browser settings at any time. Please note that disabling essential cookies will affect your ability to log in to and use the zitben platform. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

8 Data Security

zitben implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data in transit between your device and the zitben servers
• Encryption of sensitive data fields (including passwords and payment details) at rest in our databases
• Role-based access controls ensuring that zitben staff can only access personal data that is necessary for their specific job function
• Regular security audits and penetration testing conducted by independent security specialists
• Intrusion detection systems and real-time monitoring of our server infrastructure
• Strict third-party vendor security assessments before any data-sharing relationship is established

9 Your Privacy Rights

As a player on the zitben platform, you have the following rights with respect to your personal data. To exercise any of these rights, please contact us at support@zitben.app with your request. We will respond within a reasonable timeframe and at no charge to you.

• Right of Access: You may request a copy of all personal data that zitben holds about you, along with an explanation of how it is being processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it promptly.
• Right to Erasure ("Right to be Forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where the data has been processed unlawfully. This right is subject to overriding legal retention obligations.
• Right to Restriction of Processing: You may request that we limit how we process your data in certain circumstances — for example, while a dispute about its accuracy is being resolved.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format so that you can transfer it to another service provider where technically feasible.
• Right to Object: You have the right to object to processing based on our legitimate interests at any time. You also have an unconditional right to object to processing for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

10 Children's Privacy

The zitben platform is strictly intended for adults aged 18 years and above. We do not knowingly collect personal data from any person under the age of 18. If we become aware that personal data has been collected from a person under 18, we will take immediate steps to delete that data and close the associated account.

Parents and guardians who believe that a minor may have registered on the zitben platform or provided personal data without authorisation are encouraged to contact us immediately at support@zitben.app. We will investigate and act promptly on all such reports.

11 Third-Party Links

The zitben platform does not contain links to external third-party websites. However, our game content is delivered by licensed third-party studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others). Once you launch a game session hosted by a third-party provider's technology, that provider's own privacy policy and data practices may apply to data generated within the game session. zitben is not responsible for the privacy practices of third-party game technology providers beyond the contractual obligations we impose on them as our service partners.

12 Updates to This Privacy Policy

zitben reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, changes in applicable law, or the introduction of new features on the zitben platform. When we make material changes, we will notify registered players by email and by displaying a prominent notice on the platform prior to the changes taking effect.

The "Last updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how zitben protects your personal data. Your continued use of the zitben platform after any update to this Policy constitutes your acceptance of the revised terms.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way zitben handles your personal data, please contact our Data Protection team using the details below. We are committed to resolving all privacy-related enquiries promptly and transparently.

For urgent matters such as suspected unauthorised access to your account or a potential data breach, please mark your email subject line as "URGENT – Privacy" to ensure it is escalated to our security team immediately.