db54 Privacy Policy — How We Handle Your Personal Data

This Privacy Policy ("Policy") describes how db54 ("db54", "we", "us", "our") collects, uses, stores, discloses and protects the personal data of individuals ("you", "your", "Player", "User") who access or use the db54 website located at db54.io and all associated services, games, betting markets, account features and promotional tools (collectively, the "Platform").

This Policy applies to all users of the db54 Platform, including registered account holders, visitors browsing without an account, and individuals who contact db54's customer support team. It applies regardless of the device or browser used to access the Platform.

This Policy should be read alongside the db54 Terms & Conditions and any game-specific or promotion-specific terms published on the Platform from time to time. In the event of any conflict between this Policy and the Terms & Conditions on a data privacy matter, this Policy shall prevail.

This Policy is effective from 1 January 2026 and supersedes all prior versions. The most current version is always available at db54.io/privacy-policy.

For the purposes of this Policy, db54 acts as the data controller in respect of the personal data it processes about users of the Platform. As data controller, db54 determines the purposes for which personal data is collected and the means by which it is processed.

db54 operates as an online gaming and sports betting platform serving players primarily located in Bangladesh. All data controller responsibilities and obligations set out in this Policy are borne by db54 in its capacity as the operator of the Platform.

If you have any questions about db54's role as data controller in respect of your personal data, please contact the db54 data privacy team at [email protected] with the subject line "Data Privacy Enquiry".

db54 collects the following categories of personal data about users of the Platform. The specific data collected in any given instance depends on how you interact with the Platform and the services you use.

db54 collects your personal data through the following channels and mechanisms:

• Direct Submission: Data you provide actively when completing the db54 registration form, updating your account profile, submitting a withdrawal request, or contacting the support team.
• Automated Collection: Technical and usage data collected automatically when you visit the Platform, including your IP address, device identifiers and browsing behaviour, via server logs, cookies and analytics tools.
• Payment Processors: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Visa, Mastercard and connected banking partners when you initiate a deposit or withdrawal.
• Identity Verification Partners: Confirmation data returned by third-party KYC and document verification services that db54 uses to verify the authenticity of identity documents submitted during account verification.
• Fraud Prevention Services: Device fingerprint data, IP reputation scores and behavioural signals provided by fraud detection partners that help db54 identify and prevent account fraud and bonus abuse.
• Game Providers: Session and outcome data returned by game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe and Ezugi, used to reconcile your account balance and monitor for irregular activity.
• Public Sources: In limited circumstances, publicly available information may be used to supplement identity verification, particularly where a player is subject to an enhanced due diligence review.

db54 processes your personal data only where there is a valid legal basis for doing so. The applicable legal basis for each category of processing activity is summarised below.

• Contractual Necessity: Processing your identity data, contact data, financial data and account data is necessary for db54 to perform the contract it has with you — namely, to operate and maintain your db54 account, process deposits and withdrawals, and settle game outcomes and bets.
• Legal Obligation: Processing your identity and financial data for KYC, age verification and anti-money laundering (AML) checks is required for db54 to comply with applicable legal obligations.
• Legitimate Interests: Processing technical data, usage data and gaming activity data for fraud prevention, platform security, responsible gaming monitoring, and service improvement is carried out on the basis of db54's legitimate interests, where those interests are not overridden by your own rights and interests.
• Consent: Processing your contact data for the purpose of sending you marketing communications (promotional emails, SMS notifications, bonus offers) is carried out on the basis of your explicit consent, which you may withdraw at any time.

db54 uses the personal data it collects for the following specific purposes. Each purpose is linked to the legal basis described in Section 5.

• Account Creation and Management: To create your db54 account, verify your identity and age, maintain your account profile, and administer your account balance.
• Transaction Processing: To process BDT deposits and withdrawals via bKash, Nagad, Rocket, Upay and other supported payment methods, and to maintain an auditable record of all financial transactions on your account.
• Age and Identity Verification: To confirm that you are aged 21 or above and that you are who you claim to be, in compliance with our responsible gaming and anti-fraud obligations.
• Fraud and Crime Prevention: To detect, investigate and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting and any other prohibited conduct on the Platform.
• Responsible Gaming: To monitor your gaming patterns for signs of problem gambling behaviour and to implement any responsible gaming tools you request, such as deposit limits, cool-off periods or self-exclusion.
• Customer Support: To respond to your queries, complaints and requests, and to maintain records of all support interactions for quality assurance and dispute resolution purposes.
• Platform Improvement: To analyse aggregated usage data in order to improve the db54 Platform, fix technical issues, and develop new features that serve our players better.
• Marketing Communications: Where you have consented, to send you information about db54 promotions, bonuses, new game launches, and seasonal offers relevant to Bangladesh market events such as Eid, Pohela Boishakh and BPL cricket season.
• Legal Compliance: To comply with any applicable legal or regulatory obligation, including responding to lawful requests from law enforcement or regulatory authorities.

db54 does not sell your personal data to third parties under any circumstances. We share personal data with third parties only where it is necessary to provide the services you use, to comply with a legal obligation, or to protect the security of the Platform.

The categories of third parties with whom db54 may share your personal data are as follows:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, Visa, Mastercard and connected banking partners receive the minimum financial data necessary to process your deposit or withdrawal transaction.
• Identity Verification Services: Third-party KYC providers receive copies of identity documents you submit, solely for the purpose of verifying their authenticity and confirming your identity.
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi and other studio partners receive anonymised session identifiers and stake/result data necessary to operate their games within the db54 environment.
• Fraud Prevention Partners: Specialist fraud detection services receive technical signals including IP addresses and device fingerprints for the purpose of assessing the fraud risk of specific transactions or account actions.
• Analytics Providers: Aggregated, anonymised usage data may be shared with analytics platforms to support db54's Platform improvement activities. No personally identifiable information is shared for analytics purposes.
• Law Enforcement and Regulatory Bodies: db54 may disclose personal data to government authorities, law enforcement agencies or regulatory bodies where required to do so by applicable law, court order or other mandatory legal process.
• Professional Advisers: db54's legal, accounting and auditing advisers may have access to personal data on a strictly confidential basis where necessary to provide professional services to db54.

All third parties with whom db54 shares personal data are contractually required to process that data only for the specified purpose, to maintain appropriate security standards, and to treat it with at least the same level of confidentiality that db54 applies.

db54 uses cookies and similar tracking technologies on the Platform to ensure the site functions correctly, to remember your preferences, and to collect aggregated analytics data that helps us improve the user experience.

The following categories of cookies are used on the db54 Platform:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They enable you to log in to your db54 account, maintain your session, and navigate securely between pages. These cookies cannot be disabled without severely impairing your use of the Platform.
• Functional Cookies: These cookies remember your preferences such as language settings, game lobby display options and responsible gaming tool configurations, so that you do not have to re-enter them on each visit.
• Analytics Cookies: These cookies collect anonymised information about how visitors use the Platform, including which pages are visited most frequently and where users encounter errors. This data helps db54 identify areas for improvement.
• Security Cookies: These cookies support db54's fraud prevention and account security systems by helping to identify unusual patterns of access that may indicate unauthorised account use.

You may control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Please note that blocking strictly necessary cookies will prevent you from logging in to your db54 account. For full details on managing cookies in your specific browser, consult your browser's help documentation.

db54 takes the security of your personal data seriously and implements a comprehensive set of technical and organisational security measures to protect your information against unauthorised access, accidental loss, destruction or disclosure.

The security measures currently in place include:

• Encryption: All personal data is encrypted at rest using AES-256 encryption and in transit using TLS 1.2 or higher. The db54 Platform is served exclusively over HTTPS.
• Access Controls: Access to systems containing personal data is restricted to authorised db54 personnel on a need-to-know basis. All access is authenticated via multi-factor authentication and logged for audit purposes.
• Password Security: Player passwords are stored as salted hashes using a strong one-way hashing algorithm. db54 does not store passwords in plain text and cannot retrieve your password — only reset it.
• Intrusion Detection: db54 employs continuous network monitoring and intrusion detection systems to identify and respond to potential security incidents in real time.
• Vulnerability Management: The db54 Platform undergoes regular security assessments. Known vulnerabilities are patched on a priority basis in accordance with db54's internal security response policy.
• Staff Training: All db54 personnel who handle personal data receive regular data protection training and are bound by strict confidentiality obligations.

db54 retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, tax or accounting obligations. The following retention periods apply as a general guide:

At the end of the applicable retention period, personal data is securely deleted from db54's active systems or irreversibly anonymised so that it can no longer be associated with any individual. Anonymised aggregate data may be retained indefinitely for statistical and analytical purposes.

As a user of the db54 Platform, you hold the following rights in respect of your personal data. To exercise any of these rights, contact db54 at [email protected] with the subject line "Data Rights Request". db54 will respond to all valid requests within 30 days.

• Right of Access: You have the right to request a copy of all personal data that db54 holds about you, together with information about how that data is used and with whom it is shared.
• Right to Rectification: You have the right to request that db54 correct any inaccurate or incomplete personal data held about you. Minor account details such as your contact number or address can be updated directly in your account settings.
• Right to Erasure: You have the right to request that db54 delete your personal data in certain circumstances, for example where the data is no longer necessary for the purpose for which it was collected. This right is subject to db54's legal obligation to retain certain data for AML and financial compliance purposes.
• Right to Restriction of Processing : You have the right to request that db54 restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to its processing, while db54 investigates your request.
• Right to Data Portability: You have the right to receive a copy of the personal data you have provided to db54 in a structured, commonly used, machine-readable format, and to request that db54 transmit that data directly to another data controller where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where db54 relies on legitimate interests as the legal basis for processing. db54 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests or rights.
• 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 prior to withdrawal. Marketing communications consent may be withdrawn via the unsubscribe link in any marketing email or by contacting support.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a relevant data protection authority if you believe that db54 has processed your personal data in a manner that does not comply with applicable data protection law.

The db54 Platform is strictly intended for adults aged 21 years or older. db54 does not knowingly collect, process or retain personal data from any person under the age of 21. If you are under 21, you must not attempt to register an account, access the Platform or provide any personal data to db54.

As part of the account registration process, db54 requires all applicants to confirm that they are aged 21 or above. db54 also conducts mandatory age verification checks using identity documents as part of its KYC process. Any account found to have been registered by a person under 21 will be immediately suspended, any balance held on the account will be dealt with in accordance with applicable legal requirements, and all personal data associated with the account will be deleted as soon as legally permissible.

With your consent, db54 may send you marketing communications about promotions, bonus offers, new game releases, seasonal events and other db54 Platform news that may be of interest to you. Marketing messages may be delivered via email or SMS to the contact details registered on your db54 account.

db54 may reference Bangladesh market events in its marketing communications where relevant, including BPL and T20 cricket seasons, Eid al-Fitr, Eid al-Adha, Pohela Boishakh, Victory Day on 16 December, and Independence Day on 26 March. All marketing communications will be written in English.

You may opt out of marketing communications at any time by:

• Clicking the unsubscribe link at the bottom of any marketing email sent by db54
• Replying STOP to any SMS marketing message sent by db54
• Contacting db54 support at [email protected] and requesting removal from the marketing list
• Updating your communication preferences in your db54 account settings

Please allow up to 5 business days for an opt-out request to take full effect across all db54 marketing channels. Opting out of marketing communications does not affect the delivery of transactional or account service messages, such as deposit confirmations, withdrawal notifications, and security alerts, which are sent regardless of marketing preferences as they are necessary for the operation of your account.

The db54 Platform may, from time to time, contain references to or integrations with third-party services such as game providers, payment processors and identity verification partners. While db54 selects its third-party partners carefully and requires them to meet minimum data security standards contractually, db54 is not responsible for the privacy practices of any third-party organisation.

Any personal data you provide directly to a third-party service — for example, when setting up a bKash wallet or Nagad account — is governed exclusively by that third party's own privacy policy and terms of service. db54 encourages all users to review the privacy policies of any third-party service they use in connection with the db54 Platform.

Game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe and Ezugi operate their game engines within the db54 environment and may collect anonymised session telemetry for game performance purposes. db54 ensures that data sharing agreements with all game providers prohibit the use of player data for any purpose other than delivering and improving the specific game services used on the db54 Platform.

db54 reviews this Privacy Policy periodically and may update it from time to time to reflect changes in our data processing practices, changes in applicable law, improvements to the Platform, or feedback received from users and regulators. The effective date at the top of this Policy will be updated whenever a material change is made.

Where a change to this Policy is material — meaning it significantly affects your rights or how your data is used — db54 will notify registered account holders by email to the address on file. Non-material changes, such as clarifications of existing language or corrections of typographical errors, may be made without direct notification.

Your continued use of the db54 Platform after any updated version of this Policy has been published constitutes your acceptance of the revised Policy. If you do not agree to the revised Policy, you should cease using the Platform and contact db54 support to request account closure.

All previous versions of the db54 Privacy Policy are archived and available on request by contacting [email protected] with the subject line "Privacy Policy Archive Request".

If you have any questions, concerns or requests relating to this Privacy Policy or to the way in which db54 processes your personal data, please contact the db54 data privacy team using the details below. All privacy-related communications are handled in English.

• Privacy Enquiries: [email protected] — subject line "Data Privacy Enquiry"
• Data Rights Requests: [email protected] — subject line "Data Rights Request"
• Marketing Opt-Out: [email protected] — subject line "Marketing Opt-Out"
• Support Hours: 24 hours a day, 7 days a week, including Bangladeshi public holidays
• Response Time: Privacy enquiries within 5 business days; data rights requests within 30 calendar days

For questions about responsible gaming or to request a self-exclusion, deposit limit or cooling-off period, please visit our Responsible Gaming page or contact support directly. For general account queries and game-related questions, our FAQ page covers the most common topics in detail.