bq111 Privacy Policy —
Your Data, Protected

1. Data Controller & Contact Details

For the purposes of this Privacy Policy, bq111 — the operator of the platform accessible at https://bq111.club — acts as the data controller responsible for the personal information collected from users of the platform. As data controller, bq111 determines the purposes and means of processing your personal data and is accountable for ensuring that processing activities comply with applicable data protection obligations.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which bq111 handles your personal data, you may contact our dedicated data protection point of contact using the details below. All privacy-related enquiries are reviewed by a senior member of our compliance team.

This Privacy Policy applies to all users of the bq111 website and platform, regardless of the device used to access it. It covers data collected through account registration, gameplay, payment processing, customer support interactions, and general browsing of the bq111 website. By using the bq111 platform, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

bq111 collects personal data through several distinct channels: directly from you during registration and account management; automatically through your use of the platform; from third-party payment and identity verification providers; and, where required, from publicly available sources for AML and fraud-prevention purposes. The table below sets out the categories of data collected, the specific data points within each category, and the primary purpose of collection.

3. Legal Basis for Processing

bq111 processes your personal data only where a valid legal basis exists for doing so. We rely on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing your identity, contact, financial, and account data is necessary to fulfil our contractual obligations to you under the bq111 Terms & Conditions — specifically to operate your account, process deposits and withdrawals, credit bonuses, and provide access to games and betting markets.
• Legal Obligation: bq111 is required by applicable law and regulation to collect and retain certain data for anti-money-laundering (AML) compliance, Know Your Customer (KYC) verification, fraud prevention, and age verification. This processing is non-negotiable and cannot be opted out of; without it, bq111 cannot lawfully provide its services to you.
• Legitimate Interests: bq111 processes technical and usage data on the basis of its legitimate interest in maintaining platform security, detecting and preventing fraud, improving product quality, and conducting internal analytics. We have assessed that these legitimate interests are not overridden by your privacy rights, given the limited sensitivity of the data involved and the safeguards in place.
• Consent: Where bq111 sends you personalised marketing communications (promotional emails, SMS offers, WhatsApp bonus alerts), this processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without penalty by updating your communication preferences in your account settings or by contacting our support team.
• Vital Interests: In exceptional circumstances — for example, if we become aware that a player is at serious risk of self-harm related to problem gambling — bq111 may process limited data to protect that individual's vital interests. This is a narrow and infrequently invoked basis.

4. How We Use Your Data

bq111 uses your personal data for the following defined purposes. We do not use your data for any purpose that is incompatible with those listed below. If we intend to use your data for a new purpose in the future, we will update this Privacy Policy and notify you before that processing begins.

• Account Management: Creating, maintaining, and securing your bq111 account; processing logins; managing your balance and transaction history; applying VIP tier upgrades; enabling account recovery when requested.
• Payment Processing: Facilitating deposits via bKash, Nagad, Rocket, Upay, and Bangladeshi bank accounts; processing withdrawal requests; verifying payment method ownership to prevent fraud and money laundering.
• Identity Verification: Conducting age verification checks at registration; performing full KYC document review before processing your first withdrawal; carrying out ongoing AML screening against relevant watchlists where required by law.
• Responsible Gaming: Monitoring gameplay patterns to identify signs of problem gambling; delivering responsible gaming alerts and cooling-off prompts; enforcing self-exclusion orders; sharing anonymised behavioural data with responsible gaming research bodies where legally permitted.
• Customer Support: Responding to support queries submitted via live chat, WhatsApp, or email; investigating complaints; resolving disputes; maintaining records of interactions for quality assurance and training purposes.
• Fraud and Security: Detecting multi-accounting, bonus abuse, collusion, and other fraudulent activity; investigating suspicious transactions; maintaining the integrity of the bq111 platform for all genuine players.
• Product Improvement: Analysing aggregated, anonymised usage data to understand how players interact with the platform; identifying features that need improvement; testing new functionality before full release.
• Marketing (Consent-Based): Sending you promotional communications about new games, bonuses, VIP rewards, and seasonal offers (e.g., Eid specials, BPL cricket promotions) — only where you have given explicit consent and have not subsequently withdrawn it.
• Legal Compliance: Meeting bq111's obligations under applicable data protection, financial crime, and consumer protection laws; responding to lawful requests from regulatory or law enforcement authorities.

5. Cookies & Tracking Technologies

bq111 uses cookies and similar tracking technologies (including local storage, session storage, and device fingerprinting) to make the platform function correctly, to keep your session secure, and to understand how users interact with the site. This section explains the categories of cookies we use and how you can manage your cookie preferences.

• Strictly Necessary Cookies: These cookies are essential for the bq111 platform to operate. They enable core functions such as account login, session management, game loading, and payment flow integrity. Because they are technically essential, they cannot be disabled without breaking the platform's core functionality.
• Performance & Analytics Cookies: These cookies collect aggregated, anonymised data about how users navigate the bq111 website — which pages are visited most frequently, where users encounter errors, and how long sessions last. This data is used solely to improve platform performance and user experience. No personally identifiable information is included in these reports.
• Functional Cookies: These cookies remember your preferences — such as your chosen language setting, display preferences, and last-played game — so that you do not need to re-enter them each time you visit. Disabling functional cookies may reduce personalisation features.
• Targeting / Marketing Cookies: These cookies are used only if you have consented to receive personalised marketing from bq111. They track which promotions you have viewed and help us avoid showing you the same offer repeatedly. They do not track your activity on any website other than bq111. You may withdraw consent for marketing cookies at any time via your account settings.
• Security Cookies: These cookies support bq111's fraud detection and bot prevention systems. They help identify unusual activity patterns — such as simultaneous logins from multiple geographic locations — and protect your account from unauthorised access.

You can manage cookie preferences through your browser's cookie settings. Please note that disabling strictly necessary or security cookies may prevent you from accessing certain areas of the bq111 platform or completing transactions. Detailed instructions for managing cookies in Chrome, Firefox, Safari, and Edge are available from each browser's help centre.

6. Data Sharing & Third Parties

bq111 does not sell your personal data to any third party. We share your data only in the limited circumstances described below, and only with parties who are bound by appropriate data protection obligations. All third-party service providers engaged by bq111 are contractually required to process your data strictly in accordance with our instructions and for no other purpose.

• Payment Processors: To process deposits and withdrawals, bq111 shares the minimum necessary data (wallet numbers, transaction amounts, account identifiers) with bKash, Nagad, Rocket, Upay, and Bangladeshi banking partners. These providers operate under their own regulatory data protection frameworks and are not permitted to use your data for any purpose beyond processing the specific transaction.
• Identity Verification Partners: To complete KYC verification, scanned identity documents and verification selfies may be shared with a third-party identity verification service. This provider processes documents in a secure, certified environment and returns only a verification outcome (pass / fail) to bq111. Documents are not retained by the verification partner beyond the legally required period.
• Game Providers: When you play a game powered by a third-party provider — such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi — a session token and anonymised player identifier are shared with that provider to enable game operation. Your full name, contact details, and payment information are never shared with game providers.
• Fraud Prevention Services: Aggregated device and behavioural signals may be shared with third-party fraud detection platforms to identify multi-accounting, bot activity, and financial crime. These providers process data on bq111's behalf and are not permitted to use it for any independent purpose.
• Regulatory and Law Enforcement Authorities: bq111 may disclose personal data to regulatory bodies or law enforcement agencies where required to do so by law, court order, or in response to a lawful investigation. bq111 will, where legally permitted, notify you of such a disclosure.
• Business Transfers: In the event that bq111's business or assets are acquired, merged with another entity, or restructured, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any material changes to this Privacy Policy that result from it.

bq111 does not transfer your personal data to countries outside your region without ensuring that adequate data protection safeguards are in place — whether through standard contractual clauses, binding corporate rules, or equivalent recognised mechanisms.

7. Data Retention

bq111 retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or for as long as is required by applicable law and regulation. The following retention periods apply to the main categories of personal data we hold:

• Account and Identity Data: Retained for the duration of your account's active period plus a minimum of five years following account closure, to comply with AML record-keeping obligations and to facilitate the resolution of any disputes or regulatory enquiries arising after closure.
• Financial Transaction Records: Retained for a minimum of five years from the date of each transaction, in accordance with applicable financial crime regulations. This includes deposit receipts, withdrawal records, bonus transaction logs, and payment method verification documents.
• KYC Documents: Identity documents submitted for KYC verification are retained for five years following the closure of your account or the date of submission if verification was unsuccessful. After this period, documents are securely and permanently deleted from all bq111 systems.
• Customer Support Communications: Live chat transcripts, email correspondence, and WhatsApp message records are retained for three years from the date of the interaction, to enable dispute resolution and quality assurance reviews.
• Usage and Analytics Data: Anonymised, aggregated analytics data may be retained indefinitely as it contains no personally identifiable information. Individual usage logs that are linked to your account are retained for 24 months.
• Marketing Preferences: Records of your marketing consent (or withdrawal of consent) are retained for five years to demonstrate compliance with consent obligations, even after the underlying marketing processing has ceased.
• Responsible Gaming Records: Self-exclusion records, deposit limit settings, and problem gambling support interactions are retained for the duration of the exclusion period plus five years, to prevent re-registration during an active exclusion and to support the continuity of welfare obligations.

When a retention period expires, bq111 will either permanently delete your data from all live systems and backups, or irreversibly anonymise it so that it can no longer be linked back to you. You may request early deletion of your data subject to the conditions described in the Your Privacy Rights section below.

8. Your Privacy Rights

As a user of the bq111 platform, you hold the following rights with respect to your personal data. bq111 is committed to honouring these rights promptly and transparently. All requests are handled free of charge and responded to within 30 calendar days of receipt. If a request is complex or numerous, bq111 may extend this period by a further 30 days, in which case you will be notified of the extension and the reason for it.

To exercise any of the above rights, please contact bq111's data protection point of contact at support@bq111.club with the subject line "Privacy Rights Request". You will be asked to verify your identity before your request is processed, to ensure that personal data is not disclosed to or acted upon by an unauthorised party.

9. Data Security

bq111 implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. The following controls are in place at all times:

• Transport Layer Security: All data in transit between your browser and the bq111 platform is encrypted using TLS 1.2 or higher. Our SSL certificate is maintained and renewed by a trusted certificate authority. Connections over unencrypted HTTP are automatically redirected to HTTPS.
• Encryption at Rest: Sensitive data stored in bq111's databases — including identity documents, payment details, and password hashes — is encrypted at rest using AES-256 encryption. Encryption keys are managed separately from the data they protect and are rotated on a regular schedule.
• Access Controls: Access to personal data within bq111's internal systems is restricted on a strict need-to-know basis. All staff with access to personal data undergo background screening and receive mandatory data protection training. Access rights are reviewed and updated quarterly, and any access by a staff member who leaves the organisation is revoked immediately upon departure.
• Two-Factor Authentication: bq111's internal administrative systems require two-factor authentication for all staff. We strongly recommend that players also enable two-factor authentication on their bq111 accounts to add an additional layer of security against unauthorised access.
• Penetration Testing & Vulnerability Scanning: bq111's platform and infrastructure undergo regular penetration testing by independent security specialists. Vulnerability scans are conducted on a continuous basis, and identified issues are triaged and remediated according to a risk-prioritised patching schedule.
• Data Backup & Recovery: All personal data is backed up on a regular schedule to geographically distributed, encrypted storage facilities. Our disaster recovery plan is tested periodically to ensure that data can be fully restored within defined recovery time objectives in the event of a system failure or incident.
• Incident Response: bq111 maintains a documented data breach incident response procedure. In the event of a confirmed breach affecting personal data, our response team is activated immediately to contain the breach, assess its scope, remediate the vulnerability, and notify affected individuals and relevant authorities within the timeframes required by applicable law.
• Third-Party Security Standards: All third-party service providers who process personal data on bq111's behalf are required to demonstrate compliance with industry-standard security frameworks as a condition of their engagement. Contracts with processors include binding data protection and security obligations.

Despite these measures, no digital platform can guarantee absolute security. You are responsible for keeping your bq111 account credentials — including your password and any two-factor authentication codes — confidential and for logging out of your account when using shared or public devices. If you suspect that your account has been compromised, please contact bq111's support team immediately at support@bq111.club or via WhatsApp at +880 1700 000 111.

10. Changes to This Policy

bq111 reviews this Privacy Policy on a regular basis and may update it from time to time to reflect changes in our data processing activities, legal obligations, or best-practice guidance. The date at the top of this page indicates when this version of the policy was last revised. We distinguish between two types of changes:

• Material Changes: If we make a change that significantly affects your rights, the types of data we collect, or the purposes for which we use your data, we will notify you directly via email and via an on-platform notification at least 14 days before the change takes effect. If the change requires your consent, we will seek that consent before the new processing begins.
• Minor Changes: Corrections to typographical errors, clarifications of existing policy language, or minor structural reorganisations that do not affect the substance of the policy may be published without advance notice. The updated date at the top of the page will reflect any such revision.
• Your Continued Use: By continuing to use the bq111 platform after a revised Privacy Policy has come into effect, you acknowledge that you have read and understood the updated policy. If you do not accept the revised terms, you must cease using the platform and may request account closure by contacting our support team.
• Policy Archive: Previous versions of the bq111 Privacy Policy are available upon request. If you wish to review an earlier version of this policy — for example, to understand what terms were in effect at the time of a specific transaction — please contact support@bq111.club with the subject line "Privacy Policy Archive Request".
• Questions About Changes: If you have any questions about a change to this Privacy Policy — including what specifically has changed and why — our support team is available 24 hours a day, seven days a week, and will be happy to explain the changes in plain language.

bq111 is committed to maintaining a clear, honest, and up-to-date Privacy Policy that accurately reflects how your data is handled at all times. If you ever feel that this policy does not accurately describe bq111's data processing activities, or if you identify a discrepancy, we would encourage you to contact us directly so that we can investigate and remedy the situation promptly.