xbaee Privacy Policy — How We Handle Your Data

1Introduction

xbaee operates the online gaming platform accessible at xbaee.ws and is committed to protecting the privacy and personal data of every individual who uses the platform. This Privacy Policy ("Policy") sets out in detail what personal information xbaee collects from you when you visit or use xbaee.ws, the purposes for which that information is processed, the lawful basis on which processing takes place, how long xbaee retains your data, and the rights available to you as a data subject.

By registering an account or using any service on xbaee.ws, you acknowledge that you have read and understood this Policy. This Policy should be read alongside the Terms and Conditions published at xbaee.ws/terms-conditions. If you have any questions about how xbaee handles your personal data, please contact the support team via live chat or at the email address provided at the end of this Policy.

2Information We Collect

xbaee collects personal information from you across several categories. The specific data collected depends on how you interact with the platform — some data is provided directly by you, while other data is collected automatically as part of normal platform operation:

3How We Use Your Information

xbaee processes personal data only for legitimate purposes that are consistent with the expectations of users and the requirements of applicable data protection principles. The following are the primary purposes for which xbaee uses your personal information:

• To create and manage your xbaee account, verify your identity, and ensure that only the registered account holder accesses the account.
• To process your deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard and other supported payment channels, and to maintain accurate transaction records.
• To provide customer support, respond to your queries and complaints, and resolve disputes relating to your account or gaming activity.
• To detect, prevent and investigate fraudulent activity, money laundering, unauthorised account access, bonus abuse, and any other conduct that violates xbaee's Terms and Conditions.
• To monitor gaming patterns for responsible gaming purposes, identify players who may be showing signs of problem gambling, and to apply or facilitate any self-exclusion, deposit limit, or time-out arrangements requested by the player or required by xbaee's responsible gaming obligations.
• To improve the xbaee platform by analysing aggregate usage patterns, identifying technical issues, and developing new features or content offerings that better serve the needs of Bangladeshi players.

4Legal Basis for Processing

xbaee processes your personal data on the following legal bases depending on the specific processing activity involved:

• Contractual necessity: processing your registration details, managing your account, and facilitating deposits and withdrawals is necessary to perform the contract between xbaee and you as a registered user.
• Legitimate interests: platform security monitoring, fraud detection, abuse prevention, and the aggregated analysis of usage data to improve platform performance are carried out on the basis of xbaee's legitimate business interests, which do not override your fundamental privacy rights.
• Consent: where xbaee sends you optional marketing communications about promotions or new platform features, this is done on the basis of your express consent. You may withdraw consent for marketing communications at any time by contacting xbaee support.
• Legal obligation: processing necessary to comply with applicable laws, including anti-money laundering obligations, KYC requirements, and any lawful requests from competent authorities, is carried out on the basis of legal obligation.

5Sharing Your Information

xbaee does not sell your personal data to any third party. xbaee does not share your personal data with advertisers, data brokers, or marketing companies. The principle governing all data sharing by xbaee is strict necessity: your data is shared with a third party only when doing so is directly required to deliver the services you use.

The circumstances under which xbaee shares your personal data with third parties are limited to the following:

• Payment service providers: when you make a deposit or request a withdrawal, transaction data is shared with the relevant payment provider (bKash, Nagad, Rocket, Upay, Visa network, Mastercard network) solely to process the transaction. These providers operate under their own privacy policies.
• Game technology providers: your account identifier and gaming session data are shared with the game studio providers (such as Evolution Gaming, Pragmatic Play, Ezugi) in real time during active gaming sessions in order to operate the game correctly and record outcomes accurately.
• Regulatory and law enforcement authorities: xbaee will disclose personal data to competent governmental or regulatory authorities where required to do so by law, court order, or other binding legal instrument. xbaee will, where permitted by law, notify affected users of any such disclosure.
• Fraud prevention and platform integrity partners: where xbaee suspects fraudulent activity, account takeover, or a serious breach of the Terms and Conditions, relevant data may be shared with fraud prevention services or security specialists engaged by xbaee for that specific purpose.

6Cookies and Tracking Technologies

xbaee uses cookies and similar tracking technologies on xbaee.ws to enable essential platform functionality, improve performance, and understand how users interact with the platform. A cookie is a small text file placed on your device by a website when you visit it; it allows the website to recognise your device on subsequent visits and retain information about your session.

xbaee uses the following categories of cookies on xbaee.ws:

• Strictly necessary cookies: these are essential for the platform to function and cannot be disabled. They include session authentication cookies that keep you logged in during an active session and security tokens that protect your account from cross-site request forgery attacks.
• Performance and analytics cookies: these collect anonymous, aggregated data about how users navigate the platform — for example, which pages are visited most often and where users encounter difficulties. This data is used solely to improve platform usability and does not identify you personally.
• Functional cookies: these remember your preferences on the platform, such as your preferred language setting, so that you do not need to re-enter them on each visit. You may disable functional cookies through your browser settings, but doing so may affect certain platform features.

7Data Security

xbaee takes the security of your personal data seriously and implements a range of technical and organisational measures designed to protect your information against unauthorised access, accidental loss, destruction, or disclosure. These measures include SSL/TLS encryption for all data transmitted between your device and xbaee.ws, encrypted storage of sensitive account data at rest, access controls limiting internal staff access to personal data on a strict need-to-know basis, and regular security reviews of platform infrastructure and third-party integrations.

While xbaee works diligently to maintain a secure platform environment, no method of electronic data transmission or storage is entirely free from risk. xbaee cannot therefore guarantee absolute security of your personal data. In the event of a data security incident that is likely to result in a high risk to your rights and freedoms, xbaee will notify affected users without undue delay and will take all reasonable steps to contain and remediate the incident.

8Data Retention

xbaee retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, subject to any legal, regulatory, or contractual requirement to retain data for a longer period. In practice, this means that account data, transaction records, and gaming activity logs are retained for a minimum period following account closure to comply with applicable record-keeping obligations. After the applicable retention period expires, your personal data is securely deleted or anonymised.

Specific retention periods applicable to different categories of data are: account registration data is retained for the duration of your account and for a period of five years following permanent account closure; transaction records are retained for seven years from the date of the transaction; gaming activity logs are retained for five years; support correspondence is retained for three years from the date of the last interaction.

9Your Data Rights

As a user of xbaee, you have the following rights in relation to the personal data xbaee holds about you. To exercise any of these rights, please contact xbaee's support team via live chat or at the support email address at the end of this Policy. xbaee will respond to all verified data rights requests within a reasonable timeframe:

Please note that certain rights are subject to limitations. For example, the right to erasure does not apply where xbaee is required by law to retain certain data (such as transaction records retained for legal compliance purposes). Where xbaee is unable to fulfil a data rights request in full, it will explain the reason and the extent to which it can comply.

10Children and Minors

The xbaee platform is strictly intended for adults aged 21 and above. xbaee does not knowingly collect personal data from any individual under the age of 21. The platform's registration process includes an age declaration step, and xbaee actively verifies ages where there is any reason to doubt a user's stated age. If xbaee determines or has reasonable grounds to suspect that a registered user is under 21, the account will be suspended immediately and all associated personal data will be reviewed and handled in accordance with applicable law.

11Third-Party Services and Links

The xbaee platform integrates third-party game technology from providers including Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, and Spribe. When you play games supplied by these providers, limited technical session data is passed to and from the provider in real time as part of normal game operation. These providers are subject to their own privacy policies and data protection obligations, and xbaee has contractual data processing agreements in place with each provider to govern how your data is handled during game play.

Payment providers (bKash, Nagad, Rocket, Upay, Visa, Mastercard) each operate independently under their own privacy frameworks. When you initiate a payment transaction, you are also engaging with the payment provider's own service. xbaee encourages you to review the privacy policies of any third-party payment service you use in connection with your xbaee account, as xbaee does not control the data practices of those independent providers.

12Changes to This Privacy Policy

xbaee reserves the right to update or amend this Privacy Policy at any time. When material changes are made to this Policy, xbaee will notify registered users via a prominent notice on the platform or through direct communication where appropriate. The updated Policy will be published at xbaee.ws/privacy-policy, and the "Last updated" date at the top of this document will be revised accordingly.

Your continued use of xbaee.ws following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should cease using the platform and contact xbaee support to close your account and request deletion of your personal data to the extent permitted by applicable law.

13Contact Us About Your Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way xbaee handles your personal data, please contact the xbaee support team. Our support team is available 24 hours a day, seven days a week, and will aim to respond to all privacy-related enquiries within a reasonable timeframe. For data rights requests (access, rectification, erasure, portability, objection), please identify yourself clearly and specify the right you wish to exercise so that your request can be handled efficiently.

Privacy enquiries and data rights requests can be directed to: [email protected] (plain text only — this is not a clickable link). You may also reach xbaee's support team via the live chat feature available directly on xbaee.ws. xbaee is committed to resolving all privacy concerns promptly and transparently.