almlock Privacy Policy — How We Handle Your Personal Data

1 Information We Collect

When you interact with the almlock platform — whether registering an account, making a deposit, playing a game, or contacting support — we may collect and process the following categories of personal data:

1.1 Registration & Identity Data

When you create your almlock account, we collect:

• Full legal name (as it appears on your government-issued identification document)
• Date of birth (to verify you meet the 18+ age requirement)
• Residential address in Bangladesh (city, district, postal code)
• Valid email address
• Mobile phone number (used for account OTP verification and linked to your bKash, Nagad, or Rocket account)
• Username and encrypted password (we do not store passwords in plain text)

1.2 Identity Verification (KYC) Data

To comply with know-your-customer (KYC) requirements and prevent fraud, almlock may request:

• A copy of a government-issued photo ID (National Identity Card, passport, or driving licence)
• A recent utility bill or bank statement confirming your residential address
• A selfie photograph for face-matching verification where required

KYC documents are processed securely and retained only for the period required by applicable regulations.

1.3 Financial & Transaction Data

almlock collects data related to deposits and withdrawals, including:

• Mobile financial service identifiers (bKash account number, Nagad number, Rocket number, Upay ID) in tokenised form
• Bank account details where bank transfer is used (account holder name, bank name, account number)
• Transaction amounts, timestamps, and transaction reference numbers
• Bonus usage history and wagering records

1.4 Usage & Technical Data

When you use the almlock platform, we automatically collect certain technical information:

Data Type	Examples	Purpose
Device information	Device type, operating system, browser version	Platform compatibility, fraud detection
IP address	IPv4/IPv6 address at time of login	Geo-verification, duplicate account detection
Session data	Login timestamps, session duration, pages visited	Security monitoring, responsible gaming tools
Game history	Games played, bet amounts, win/loss outcomes	Account statement, dispute resolution
Communication logs	Support chat transcripts, email correspondence	Quality assurance, complaint resolution

1.5 Marketing Preferences

With your consent, almlock may collect your communication preferences to send promotional emails, SMS messages about upcoming cricket BPL betting offers, slot tournaments, and seasonal promotions around Eid or Pohela Boishakh. You may update or withdraw your marketing consent at any time through your account settings or by emailing [email protected].

2 How We Use Your Data

almlock uses the personal data we collect for the following clearly defined purposes:

2.1 Account Creation & Management

Your registration data is used to create and maintain your almlock account, enable you to log in securely, and ensure only one account is held per person. Your identity data allows us to personalise your experience and address you correctly in all communications.

2.2 Payment Processing

Financial data is used exclusively to process your deposits via bKash, Nagad, Rocket, Upay, or bank transfer, and to return winnings or refunds to your registered payment method. almlock does not use your financial data for any purpose unrelated to your own transactions.

2.3 Identity Verification & Fraud Prevention

KYC data and usage data are used to verify your identity, confirm your age (18+), detect duplicate accounts, prevent money laundering, and identify potentially fraudulent activity. These measures protect both you and the integrity of the almlock platform.

2.4 Legal Compliance

almlock is required to retain certain records — including transaction histories and identity verification documents — to comply with applicable financial regulations and respond to lawful requests from regulatory or law enforcement authorities. This processing is carried out on the basis of legal obligation.

2.5 Responsible Gaming

Usage and session data is used to power almlock's responsible gaming tools, including monitoring for signs of problem gambling behaviour, enforcing self-exclusion requests, applying deposit limits, and triggering time-out periods requested by the player. These protections are a core commitment of almlock and cannot be opted out of.

2.6 Customer Support

Communication logs and account data are used to resolve your support queries efficiently, investigate complaints, and improve the quality of our support services. Support agents access only the data necessary to address your specific enquiry.

2.7 Platform Improvement

Aggregated and anonymised usage data may be analysed to understand how players interact with the almlock platform, which games are most popular among Bangladeshi users, and where technical improvements can be made. This analysis does not involve identifying individual players.

2.8 Marketing Communications (Consent-Based)

Where you have provided explicit consent, almlock may use your email address and mobile number to send promotional updates about new games, cricket betting markets, bonus offers, and seasonal promotions. You can withdraw this consent at any time without affecting the operation of your account.

3 Legal Basis for Processing

almlock processes your personal data on the following legal grounds:

• Contract performance: Processing necessary to create and manage your account, process payments, and deliver the gaming services you have registered to use.
• Legal obligation: Processing required to comply with KYC, anti-money-laundering (AML), and data retention obligations applicable to online gambling platforms operating in or targeting the Bangladesh market.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics — where these interests are not overridden by your rights and interests as a data subject.
• Consent: Processing for optional marketing communications, where you have freely given, specific, and informed consent. This consent may be withdrawn at any time.

4 Data Sharing & Third Parties

almlock does not sell, rent, or trade your personal data. We share personal data with third parties only in the limited circumstances described below, and only to the extent necessary for the specific purpose.

4.1 Payment Service Providers

To process your deposits and withdrawals, almlock shares necessary transaction data with your chosen payment provider — bKash, Nagad, Rocket, Upay, or your bank. These providers process your data under their own privacy policies and are subject to applicable financial sector regulations. almlock shares only the minimum data required to complete each transaction.

4.2 Game Content Providers

almlock's platform hosts games from licensed third-party studios including Pragmatic Play, NetEnt, Microgaming, Evolution Gaming, Ezugi, and Spribe. These providers may receive session tokens and pseudonymised player identifiers to deliver game content and validate game outcomes. They do not receive your full name, address, or payment details.

4.3 Identity Verification Services

almlock uses third-party KYC verification services to authenticate identity documents and perform age verification checks. These providers process your identity data in accordance with their own data processing agreements and applicable regulations. almlock selects KYC partners that maintain ISO 27001-certified information security standards.

4.4 Legal & Regulatory Authorities

almlock may be required to disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction in response to lawful orders, legal proceedings, or regulatory investigations. In such cases, almlock will disclose only the data specifically requested and will, where permitted by law, notify the affected player of any such disclosure.

4.5 Business Transfers

In the event that almlock undergoes a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity as part of that transaction. almlock will notify affected players in advance and ensure the successor entity agrees to honour the terms of this Privacy Policy.

5 Cookies & Tracking Technologies

5.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. They allow the site to remember information about your visit — such as your logged-in status, language preferences, and session details — to make your next visit easier and the site more useful to you. almlock uses cookies and similar tracking technologies including local storage tokens and session identifiers.

5.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential / Functional	Maintain your login session, remember account preferences, prevent CSRF attacks	Session / up to 30 days
Security	Detect suspicious login attempts, enforce rate limiting, support two-factor authentication flows	Session
Performance / Analytics	Measure page load times, identify technical errors, understand navigation patterns (anonymised)	Up to 13 months
Responsible Gaming	Track session duration for time-limit tools, store player-set deposit limit preferences	Persistent until updated

5.3 Managing Cookies

Essential and security cookies are required for the almlock platform to function and cannot be disabled without significantly impairing your experience. Performance cookies may be managed through your browser settings. Most modern browsers allow you to block or delete cookies; however, blocking essential cookies will prevent you from logging in to your account. For guidance on managing cookies in your specific browser, refer to your browser's help documentation.

almlock does not use third-party advertising cookies. No cookie data from the almlock platform is shared with advertising networks.

6 Data Retention

almlock retains your personal data for no longer than is necessary to fulfil the purpose for which it was collected, or as required by applicable legal or regulatory obligations. The following retention periods apply:

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years after closure	Legal compliance, dispute resolution
KYC / identity documents	5 years after account closure	AML and KYC regulatory requirements
Transaction records	5 years from date of transaction	Financial reporting obligations
Game history logs	3 years from date of activity	Dispute resolution, responsible gaming audits
Support correspondence	3 years from date of communication	Quality assurance, complaints handling
Marketing preferences	Until consent is withdrawn or account closed	Consent management
Cookie / session data	Session to 13 months (varies by cookie type)	Platform functionality, security

After the applicable retention period expires, personal data is securely deleted or anonymised in a manner that makes re-identification impossible. Anonymised aggregate data may be retained indefinitely for statistical and analytical purposes.

7 Your Rights & Choices

As a player on the almlock platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request — [Your Account ID]".

7.1 Right of Access

You have the right to request a copy of all personal data almlock holds about you. We will provide this in a readable format within 30 days of receiving your verified request. There is no charge for a first access request in any 12-month period.

7.2 Right to Correction

If any personal data almlock holds about you is inaccurate or incomplete, you have the right to request correction. For minor corrections (e.g., email address, phone number), you may update these directly within your account settings. For identity data corrections, please contact support with supporting documentation.

7.3 Right to Erasure

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 (and no other legal basis applies), or where the data has been unlawfully processed. Note that almlock is required by law to retain certain records (transaction data, KYC documents) for a minimum period even after account closure — these records cannot be deleted early.

7.4 Right to Restrict Processing

You may request that almlock restricts processing of your data in certain circumstances — for example, while you contest the accuracy of data we hold, or while a complaint is being investigated. Restricted data will not be actively processed but will be retained during the restriction period.

7.5 Right to Data Portability

Where almlock processes your data on the basis of contract or consent, you have the right to receive a copy of your data in a structured, commonly used, machine-readable format (such as CSV or JSON). This right applies to data you have actively provided (e.g., registration data, transaction history) but not to derived or inferred data.

7.6 Right to Withdraw Consent

Where almlock processes your data on the basis of your consent (primarily for marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. To withdraw marketing consent, use the unsubscribe link in any marketing email or contact [email protected].

7.7 Right to Object

You have the right to object to processing carried out on the basis of legitimate interests. almlock will consider your objection and cease the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims.

8 Data Security

8.1 Technical Safeguards

almlock implements the following technical security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• AES-256 encryption at rest for all stored personal data and financial records.
• Password hashing using bcrypt with salting — almlock never stores passwords in plain text.
• Tokenisation of payment identifiers — bKash, Nagad, and Rocket numbers are stored as secure tokens, not raw values.
• Two-factor authentication (OTP) available to all players via registered mobile number.
• Intrusion detection systems monitoring for unauthorised access attempts in real time.
• Regular penetration testing and security audits carried out by independent third-party specialists.

8.2 Organisational Safeguards

Access to personal data within almlock's organisation is governed by strict role-based access controls. Only staff members with a legitimate operational need are granted access to personal data, and all such access is logged and audited. almlock staff handling personal data are required to undergo regular data protection training.

8.3 Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, almlock will notify affected players as soon as reasonably practicable and will take immediate steps to contain the breach, assess its scope, and implement remediation measures. almlock maintains a documented data breach response procedure tested on a regular basis.

8.4 Your Responsibilities

While almlock takes every reasonable precaution to protect your data, account security also depends on actions you take. almlock strongly recommends that you:

• Use a strong, unique password for your almlock account not shared with any other service.
• Enable OTP two-factor authentication via your registered mobile number.
• Never share your username, password, or OTP codes with any other person.
• Log out of your almlock account when using a shared or public device.
• Report any suspicious activity on your account immediately to [email protected].

8.5 Policy Updates

almlock may update this Privacy Policy from time to time to reflect changes in our data practices, operational requirements, or applicable regulations. Where material changes are made, we will notify active players via their registered email address at least 14 days before the changes take effect. Continued use of the almlock platform after notification of changes constitutes acceptance of the revised Privacy Policy.

Effective date: January 2026  |  Contact: [email protected]  |  Platform: almlock.net