Privacy Policy — vc44

1 Data Controller Identity

For the purposes of this Privacy Policy, the data controller responsible for the personal information of registered players on the vc44 platform is the operator of the website at https://vc44.io. When this Policy refers to "vc44", "we", "us" or "our", it refers to that operator entity in its capacity as data controller.

Questions, requests and formal notices relating to this Privacy Policy or to your personal data should be directed to our support team using the contact details provided in Section 14 of this document. We have designated a responsible point of contact for all data-related enquiries who will ensure your request is handled within the timeframes set out herein.

2 Personal Data We Collect

vc44 collects personal data that falls into the following categories, depending on the nature of your interaction with the platform:

2.1 Identity and Contact Data

• Full legal name as it appears on a government-issued identity document
• Date of birth (used for age verification — all players must be 21 or older)
• Residential address in Bangladesh (city, district, postal code)
• Mobile phone number registered with your account
• Email address used for account registration
• Profile photograph or image uploaded during KYC, where applicable

2.2 Identity Verification (KYC) Data

• National Identity Card (NID) number and scanned copy
• Passport number and scanned copy, where provided as alternative ID
• Driving licence number and scanned copy, where provided as alternative ID
• Proof of address documents (utility bills, bank statements) dated within 90 days
• Selfie or liveness check images submitted during identity verification

2.3 Financial and Transaction Data

• bKash, Nagad, Rocket and Upay mobile wallet identifiers linked to deposit/withdrawal transactions
• Bank account details (BRAC Bank, Dutch-Bangla Bank, City Bank, Islami Bank, Sonali Bank) where bank transfer is used
• Visa/Mastercard card last four digits and billing address, where card payment is used
• Full deposit and withdrawal transaction history including amounts in BDT, timestamps and payment method identifiers
• Bonus and promotion redemption history

2.4 Account Activity Data

• Sports betting history — event, market, stake, odds, settlement result and payout in BDT
• Casino game session history — game title, provider, stake, outcome and session duration
• Login timestamps, session durations and logout events
• Responsible gaming tool usage — deposit limit configurations, session time limits, cooling-off requests, self-exclusion dates
• Customer support interaction records including chat transcripts and email correspondence

2.5 Technical and Device Data

• IP address at the time of each login and each transaction
• Device type, operating system version and browser type/version
• Mobile device identifier (where the platform is accessed via a mobile browser)
• Referring URL and navigation path within the platform
• Cookie identifiers and local storage tokens (see Section 9)

3 How We Collect Your Data

vc44 collects personal data through the following mechanisms:

• Direct submission: Information you provide voluntarily when completing the registration form, submitting KYC documents, initiating a deposit or withdrawal, contacting customer support, or responding to a survey or promotion.
• Automated technical collection: Device, IP, browser and session data collected automatically by our platform infrastructure each time you access the site.
• Payment provider data: Confirmation data returned by mobile financial services (bKash, Nagad, Rocket, Upay) and card processors (Visa, Mastercard) when a transaction is initiated from your account.
• Identity verification services: Verification outcomes and risk scores returned by our third-party KYC and identity verification technology partners when you submit identity documents.
• Cookies and tracking technologies: Session and preference data collected via cookies placed on your device during platform usage (see Section 9 for full cookie details).
• Fraud and security tools: Behavioural and risk data generated by our fraud detection systems to identify unusual account activity, multiple account usage or payment anomalies.

4 Purposes of Data Processing

The following table summarises the primary purposes for which vc44 processes your personal data and the categories of data used for each purpose:

Purpose	Data Categories Used
Account creation and authentication	Identity, contact, device/IP
Age and identity verification (KYC)	Identity, KYC documents, selfie/liveness
Processing deposits and withdrawals	Financial, identity, transaction history
Operating sports betting and casino games	Account activity, financial, device
Administering bonuses and promotions	Account activity, financial, identity
Responsible gaming monitoring	Account activity, financial, responsible gaming settings
Customer support and complaint handling	Identity, contact, support interaction records
Fraud detection and prevention	All categories, device/IP, transaction history
Legal and regulatory compliance	Identity, KYC, financial, transaction history
Platform improvement and analytics	Technical, account activity (aggregated/anonymised)
Direct marketing (with consent)	Contact, account activity preferences

vc44 does not process your personal data for any purpose not listed above or otherwise communicated to you at the point of data collection without first obtaining your explicit consent.

5 Legal Basis for Processing

Every data processing activity carried out by vc44 is grounded in one or more of the following recognised legal bases:

• Contractual necessity: Processing required to deliver the services you have registered for — account management, bet processing, payment handling and customer support.
• Legal obligation: Processing required to comply with applicable anti-money-laundering regulations, age verification obligations, fraud prevention requirements and financial record-keeping standards.
• Legitimate interests: Processing carried out for purposes that serve vc44's legitimate business interests where those interests are not overridden by your privacy rights — including fraud detection, platform security, responsible gaming risk monitoring and aggregated platform analytics.
• Consent: Processing for purposes beyond those listed above — primarily direct marketing communications and optional profiling for personalised offers — where we have obtained your express, freely given and withdrawable consent. You may withdraw consent at any time via your account settings or by contacting support.

6 Sharing Your Personal Data

vc44 does not sell your personal data. Data may be shared with the following categories of third parties only to the extent necessary to fulfil the purposes described in this Policy:

6.1 Payment and Financial Service Providers

Processing your deposits and withdrawals requires sharing relevant account and transaction data with mobile financial service operators (bKash, Nagad, Rocket, Upay), card networks (Visa, Mastercard) and banking partners (Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank) as necessary to complete the transaction. These entities operate under their own privacy policies and are subject to applicable financial services regulations.

6.2 Identity Verification Service Providers

To fulfil our KYC obligations, identity document images and biometric data may be transmitted to our contracted third-party identity verification technology providers. These providers are engaged under data processing agreements that prohibit use of your data for any purpose other than delivering verification services to vc44.

6.3 Game Content Providers

Certain technical session data (session token, stake, outcome) is exchanged with game content providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe and Ezugi to facilitate game loading, round settlement and win/loss reconciliation. These providers do not receive your identity or contact details in identifiable form.

6.4 Fraud Prevention and Security Services

IP addresses, device identifiers and behavioural signals may be shared with third-party fraud detection and cybersecurity platforms to identify suspicious account activity, prevent unauthorised access and protect the integrity of the platform and its player community.

6.5 Legal and Regulatory Disclosure

vc44 may disclose personal data to law enforcement agencies, regulatory bodies or courts of competent jurisdiction where required by applicable law, court order or regulatory directive. In all such cases, vc44 will disclose only the minimum data necessary to satisfy the legal requirement and will, where legally permissible, notify the affected player of the disclosure.

6.6 Business Transfers

In the event of a merger, acquisition, restructuring or sale of substantially all of vc44's assets, player personal data may be transferred to the acquiring entity as part of that transaction. Affected players will be notified of any such transfer and the privacy terms applicable to their data following the transaction.

7 Data Retention Periods

vc44 retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable legal or compliance obligations. The following retention schedule applies:

Data Category	Retention Period	Basis
Account registration data	Duration of active account + 5 years post-closure	Legal / AML compliance
KYC identity documents	Duration of active account + 5 years post-closure	Legal / regulatory requirement
Financial transaction records	7 years from transaction date	Financial record-keeping law
Betting and gaming activity logs	5 years from date of activity	Dispute resolution / compliance
Customer support records	3 years from last interaction	Legitimate interest / complaints
Marketing consent records	Until consent withdrawn + 1 year	Consent / audit trail
Device/IP/technical logs	12 months from collection	Security / fraud prevention
Self-exclusion records	Duration of exclusion period + 7 years	Responsible gaming / legal

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to an identifiable individual.

8 Security Measures

vc44 implements a layered technical and organisational security framework to protect player personal data against unauthorised access, disclosure, alteration or destruction. Key measures include:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser and vc44 servers is encrypted using TLS 1.3, preventing interception of data in transit. This is evidenced by the HTTPS protocol and SSL padlock indicator in your browser address bar.
• Encryption at rest: Sensitive personal data stored in vc44 databases is encrypted using AES-256 symmetric encryption. KYC documents and identity images are stored in encrypted object storage with access restricted to authorised verification workflows.
• Password hashing: Account passwords are never stored in plain text. vc44 uses bcrypt hashing with a per-account salt to ensure that even in the unlikely event of a database exposure, password values cannot be recovered.
• Access controls: Internal access to player personal data is restricted on a strict need-to-know basis. vc44 operations staff access only the minimum data required to perform their role, and all access events are logged and auditable.
• Two-factor authentication (2FA): Players are strongly encouraged to enable SMS-based 2FA on their accounts. vc44 staff with access to sensitive systems are required to use 2FA for all system logins.
• Penetration testing and vulnerability management: vc44 conducts periodic security assessments of its platform infrastructure and remediates identified vulnerabilities on a risk-prioritised basis.
• Incident response: vc44 maintains a documented data breach response procedure. In the event of a confirmed breach affecting player personal data, affected players will be notified within 72 hours of discovery.

While vc44 takes all reasonable precautions to protect your data, no online platform can guarantee absolute security. You also have a responsibility to protect your account credentials — use a strong unique password, enable 2FA, and do not share your login details with anyone.

9 Cookies and Tracking Technologies

vc44 uses cookies and similar client-side tracking technologies to enable platform functionality, maintain your login session, personalise your experience and gather aggregate usage analytics. The following categories of cookies are in use:

9.1 Strictly Necessary Cookies

These cookies are essential for the platform to function correctly. They include your authenticated session token, CSRF protection tokens, and load-balancing identifiers. Without these cookies, core platform features including login, game play and the cashier cannot operate. These cookies do not require your consent and cannot be disabled without preventing platform use.

9.2 Functional Cookies

Functional cookies remember your preferences — such as your chosen language settings and display preferences — so that you do not have to re-configure them on every visit. These cookies persist for up to 12 months from last visit.

9.3 Analytics Cookies

vc44 uses anonymised analytics data to understand how players navigate the platform, which game categories are most popular and where technical issues may arise. Analytics data is aggregated and cannot be used to identify individual players. You may opt out of analytics cookies at any time via your account privacy settings.

9.4 Fraud Detection and Security Cookies

Our security and fraud prevention systems set cookies that help identify unusual login patterns, detect automated bot activity and flag accounts that may be operating in violation of our Terms and Conditions. These cookies are strictly necessary for platform security and cannot be opted out of.

You can manage cookie preferences through your browser settings, though disabling strictly necessary cookies will prevent normal use of the vc44 platform. We do not use third-party advertising cookies or behavioural retargeting pixels.

10 Your Data Rights

As a registered player on the vc44 platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us using the details in Section 14. We will respond to all verified requests within 30 calendar days:

• Right of Access: You may request a copy of all personal data vc44 holds about you, together with information about how it is used and with whom it has been shared.
• Right to Rectification: If any of your personal data held by vc44 is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing was unlawful. Note that certain data must be retained by vc44 to meet legal and regulatory obligations (see Section 7) and cannot be deleted on request.
• Right to Restriction of Processing: You may request that vc44 restrict processing of your personal data in defined circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to Data Portability: You may request that vc44 provide your personal data in a structured, machine-readable format (CSV or JSON) for transfer to another service provider, where technically feasible.
• Right to Object: You may object to processing of your personal data where vc44 relies on legitimate interests as its legal basis, including profiling for personalised promotional offers.
• Right to Withdraw Consent: Where processing is based on your consent (primarily direct marketing), you may withdraw that consent at any time via your account settings or by contacting support. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

vc44 will not charge a fee for exercising any of the above rights unless a request is manifestly unfounded or excessive. In such cases, we will inform you of the applicable fee before proceeding.

11 Minors and Age Restrictions

The vc44 platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, store or process personal data relating to any individual under the age of 21. Age verification is a mandatory step in the account registration and KYC process, and vc44 employs automated and manual controls to detect and prevent underage access.

If vc44 becomes aware that personal data has been collected from an individual who is under 21 years of age, the account will be suspended immediately, the data will be securely deleted from our systems without undue delay, any deposited funds will be returned via the original payment method, and all betting activity conducted on the account will be voided. Parents or guardians who become aware that a minor may have registered on vc44 should contact our support team immediately so that the account can be identified and closed promptly.

12 International Data Transfers

The vc44 platform serves players based in Bangladesh. Certain technical infrastructure components, third-party service providers (including identity verification partners and game content providers) may process or store data on servers located outside of Bangladesh. Where personal data is transferred internationally, vc44 ensures that appropriate safeguards are in place — including contractual data processing agreements that impose obligations equivalent to those described in this Privacy Policy.

vc44 does not transfer player data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual protections. If you have concerns about the international transfer of your data, please contact us using the details in Section 14.

13 Changes to This Privacy Policy

vc44 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the services we offer. Material changes will be communicated to registered players via email notification to the address on file and/or via an in-platform banner displayed upon next login, no less than 7 calendar days before the changes take effect.

The "Last Updated" date displayed at the top of this page will be updated whenever a new version is published. Your continued use of the vc44 platform after the effective date of any revision constitutes your acknowledgement of the updated Policy. If you do not agree with the revised Policy, you should cease using the platform and request account closure before the effective date.

All prior versions of this Privacy Policy are retained in our document archive and are available upon written request to our support team.

14 Contact and Data Requests

For all privacy-related enquiries, data subject access requests, consent withdrawals, complaints or formal notices relating to this Privacy Policy, please contact the vc44 data team through the following channel:

• Email: support at vc44.io (plain text — not a clickable link)
• Subject line for data requests: DATA REQUEST — [Your Registered Username]
• Live Chat: Available 24/7 directly within the platform
• Response time: We aim to acknowledge all data-related requests within 3 business days and to resolve them within 30 calendar days of receipt of a verified request.
• Verification: To protect your data, vc44 will verify your identity before processing any data subject request. You will be asked to confirm your registered account details and may be asked to provide additional identification in line with our KYC standards.

All correspondence is handled in English. Support hours are 24/7, Bangladesh Standard Time (BST, UTC+6).