ctk44 Privacy Policy

1 Who We Are

This Privacy Policy is issued by ctk44 ("ctk44", "we", "us", or "our"), the operator of the online betting and casino platform available at ctk44.io and any associated mobile applications or sub-domains (collectively, the "Platform"). ctk44 is the data controller responsible for the personal information of members and visitors who interact with the Platform.

This Privacy Policy applies to all personal data collected from you when you visit the ctk44 website, register a member account, place bets or wagers, use casino or game services, communicate with our support team, or otherwise interact with the Platform. By registering an account and using the ctk44 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you have any questions about our data practices or wish to exercise your rights in respect of your personal data, please contact us using the details provided in Clause 13 of this Policy.

2 Data We Collect

ctk44 collects personal data from you through a number of different channels. The categories of personal data we collect are set out below.

2.1 Registration & Account Data

When you create a ctk44 account, we collect the information you provide during the registration process, including:

• Full legal name;
• Date of birth (for age verification — all members must be 21 or older);
• Residential address in Bangladesh (city, district, full postal address);
• Mobile number and email address;
• Username and encrypted password;
• Preferred currency (BDT).

2.2 Identity Verification (KYC) Data

To comply with our platform's Know Your Customer (KYC) policy and to prevent fraud, we may collect and process:

• Copies of government-issued photo ID (National Identity Card, passport, or driving licence);
• Proof of address documentation (utility bills, bank statements dated within three months);
• Selfie or live facial verification images where required to confirm identity;
• Proof of ownership of the payment method used (e.g., bKash or Nagad account confirmation).

2.3 Financial & Transaction Data

When you make deposits or withdrawals through bKash, Nagad, Rocket, Upay, bank transfer, or card payment, we collect:

• Transaction amount, date, and time;
• Payment method type and last four digits of card or mobile wallet number (where applicable);
• Transaction reference numbers;
• Deposit and withdrawal history associated with your account.

2.4 Betting & Gaming Activity Data

We collect records of your activity on the ctk44 Platform, including:

• Bets placed, games played, and wagers settled;
• Win/loss records, bet amounts, and account balance history;
• Game session duration and activity timestamps;
• Bonus and promotional offers claimed and their wagering status.

2.5 Technical & Device Data

When you access the Platform, we automatically collect certain technical information, including:

• IP address and approximate geographic location derived from IP;
• Browser type, version, and operating system;
• Device type (mobile, tablet, or desktop) and device identifiers;
• Pages visited, time spent on page, click paths, and referral source;
• Session tokens and authentication logs.

2.6 Communications Data

If you contact ctk44 via Live Chat, email, or WhatsApp support, we retain records of those communications, including:

• The content of your messages;
• Date, time, and channel of communication;
• Support tickets, resolutions, and escalation records.

3 How We Use Your Data

ctk44 uses the personal data we collect for the following purposes:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or where otherwise required.

4 Legal Basis for Processing

ctk44 processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and ctk44 — specifically, to operate your account, process payments, and deliver betting and gaming services;
• Legitimate interests: ctk44 processes certain data based on our legitimate interests in operating a secure, fraud-resistant platform, preventing money laundering, and improving service quality — provided those interests are not overridden by your rights and freedoms;
• Consent: Where you have given explicit consent — for example, opting in to receive promotional communications by email or WhatsApp — we process your data on that basis. You may withdraw consent at any time by contacting support;
• Compliance with platform policies: Certain processing activities, including KYC identity verification and responsible gaming monitoring, are carried out to comply with ctk44's internal operational and security policies.

5 Data Sharing

ctk44 does not sell your personal data to third parties. We may share your data with the following categories of trusted service providers and partners, strictly on a need-to-know basis and subject to appropriate confidentiality and data protection obligations:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard — to process your deposits and withdrawals securely;
• Identity verification providers: Third-party KYC service providers who assist with document verification and fraud screening;
• Game technology providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive the minimum session data required to deliver their games on the Platform;
• IT infrastructure and hosting: Secure cloud hosting and server management providers who process data on ctk44's behalf under strict data processing agreements;
• Customer support tools: Live chat and communication platform providers used to deliver 24/7 English-language support;
• Analytics providers: Anonymised and aggregated usage data may be shared with web analytics tools to help us understand Platform performance. No personally identifiable information is included in these reports;
• Professional advisors: Legal counsel, auditors, and compliance consultants who require access to certain data to provide professional services to ctk44.

All third-party processors engaged by ctk44 are required to implement appropriate technical and organisational security measures and are prohibited from using your personal data for their own independent purposes.

6 Cookies & Tracking Technologies

ctk44 uses cookies and similar tracking technologies on the Platform to enhance your browsing experience, maintain your session state, and gather analytics about how the Platform is used. The types of cookies we use are described below:

• Strictly necessary cookies: These are essential for the Platform to function correctly. They enable core functionality such as account authentication, session management, and security. These cookies cannot be disabled;
• Functional cookies: These remember your preferences (such as language settings and display options) so you do not need to reconfigure them on each visit;
• Analytics cookies: These help us understand how members navigate the Platform — which pages are most visited, how long sessions last, and where members encounter difficulties. Analytics data is aggregated and does not identify you personally;
• Marketing cookies: With your consent, we may place cookies that allow us to present relevant promotional content when you visit ctk44. You can withdraw consent to marketing cookies at any time through your account settings or browser controls.

Most web browsers allow you to control cookie settings through the browser's privacy or settings menu. Please be aware that disabling certain cookies may affect the functionality of the ctk44 Platform, including your ability to log in and maintain an active session.

7 Data Security

ctk44 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security practices include:

• 256-bit SSL/TLS encryption across all Platform pages and API communications;
• Encrypted data storage for sensitive personal data and KYC documents, with access restricted to authorised personnel only;
• Multi-factor authentication options available on member accounts to reduce the risk of unauthorised login;
• Regular security audits and penetration testing conducted by independent security specialists;
• Role-based access controls ensuring that internal staff can only access the categories of personal data necessary for their specific job function;
• Real-time fraud monitoring systems that flag unusual account or transaction activity for review.

Despite the robust security measures we employ, no method of internet transmission or electronic storage is completely impenetrable. While ctk44 takes all reasonable precautions to protect your data, we cannot provide an absolute guarantee of security. In the event of a data breach that is likely to result in a risk to your rights, ctk44 will notify affected members promptly and take all necessary remedial steps.

8 Data Retention

ctk44 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, as described in this Privacy Policy. The key retention periods that apply to different categories of data are set out below:

• Active account data: Retained for the full duration of your membership on ctk44 and for a period of 5 years following permanent account closure, to support audit trails, dispute resolution, and compliance with platform security policies;
• KYC and identity documents: Retained for 5 years following account closure. Documents may be retained for longer where required to address an active investigation or legal proceeding;
• Financial and transaction records: Retained for 7 years from the date of each transaction, consistent with standard financial record-keeping practices;
• Customer support communications: Retained for 3 years from the date of the final communication in a given support thread;
• Technical and device data (logs): Retained for 12 months, after which log data is deleted or anonymised;
• Marketing preferences: Retained until you withdraw your consent or request removal from marketing communications.

At the end of each applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identified or identifiable individual.

9 Your Rights

As a ctk44 member whose personal data is processed by ctk44, you have the following rights in respect of your personal information. To exercise any of these rights, please submit a written request to [email protected] with the subject line "Data Rights Request".

• Right of access: You have the right to request a copy of the personal data ctk44 holds about you, together with information about how it is being used. We will respond to access requests within 30 days;
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request correction. You can update basic account details directly from your account settings panel;
• Right to erasure: You may request that ctk44 delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our obligations to retain certain records under platform policy;
• Right to restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances — for example, while a dispute about accuracy is being resolved;
• Right to object: Where processing is based on legitimate interests, you have the right to object to such processing. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests;
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, machine-readable format, where technically feasible;
• 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.

10 Children & Minors

The ctk44 Platform is strictly intended for adults aged 21 and above. ctk44 does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the registration and KYC process, and ctk44 will refuse or terminate any account where there is evidence that the member is below the minimum age.

If a parent or guardian becomes aware that their child has registered on the ctk44 Platform or provided personal data without appropriate consent, they should contact us immediately at [email protected]. Upon confirmation, ctk44 will promptly delete all associated personal data and close the account.

11 Third-Party Links

The ctk44 Platform may contain references to or integrations with third-party game providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi). While ctk44 takes care to work only with reputable and established technology partners, we are not responsible for the privacy practices of these third parties.

When you interact with embedded third-party game software on the Platform, those providers may process certain technical data — such as session tokens and device identifiers — in order to deliver their games. ctk44 requires all game partners to comply with appropriate data protection standards and to process member data only for the purpose of game delivery. Their own privacy policies govern any additional data practices specific to their platforms.

ctk44 does not include links to unaffiliated third-party websites on the Platform, and this Privacy Policy applies solely to data processed in connection with the ctk44 Platform itself.

12 Changes to This Policy

ctk44 reserves the right to update or revise this Privacy Policy at any time. We will notify registered members of any material changes to this Policy by sending a notification to the email address associated with their account and/or by displaying a prominent notice on the Platform.

The revised Privacy Policy will take effect 7 days after the date it is published, unless a shorter notice period is required by the nature of the change. Your continued use of the ctk44 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

We encourage you to review this Privacy Policy periodically to stay informed about how ctk44 protects your personal information. The "Last Updated" date at the top of this Policy reflects the most recent revision.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by ctk44, please contact our data support team through any of the following channels. All correspondence is handled in English.

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Data Rights Request" as appropriate. We respond to privacy-related emails within 2 business days;
• Live Chat: Available 24/7 via the ctk44 Platform. For data rights requests, we recommend following up with an email to create a written record;
• WhatsApp: Available 08:00 to 24:00 BST for general account and privacy queries.

For formal complaints regarding ctk44's data handling practices, please email [email protected] with the subject line "Formal Privacy Complaint". ctk44 aims to acknowledge all formal complaints within 24 hours and to deliver a full written response within 5 business days.