dkwim Privacy Policy — Your Data, Your Rights

1. Introduction

This Privacy Policy ("Policy") describes how dkwim ("we", "us", "our") collects, uses, stores, shares, and protects personal data submitted by users ("you", "Player") when accessing or using the dkwim online gaming platform available at dkwim.org. This Policy forms part of our overall Terms and Conditions, and by using the dkwim platform you confirm that you have read and understood this Policy.

dkwim takes data privacy seriously. We collect only the information we genuinely need to operate a secure, compliant, and functional gaming platform for Bangladeshi players. We do not sell your personal data to third parties, and we do not share it with any party that is not directly involved in the legitimate operation of the dkwim platform.

2. Information We Collect

dkwim collects personal information in four broad categories. The specific data points within each category depend on the actions you take on the platform and the stage of your account lifecycle.

We do not collect sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, or health data) and we do not require or encourage you to provide it. If you voluntarily include sensitive information in a support message or complaint, we will use it only to address your specific query and will not retain it beyond what is necessary for that purpose.

3. How We Use Your Information

dkwim uses the personal data it collects only for purposes that are directly related to the operation of the platform and the delivery of services to you. We do not use your data for purposes beyond those listed below without first obtaining your explicit consent.

• Account creation, verification, and ongoing account management, including KYC identity checks required before withdrawal processing.
• Processing deposits and withdrawals via bKash, Nagad, Rocket, and approved bank transfer channels, including reconciling transaction records.
• Operating the gaming platform correctly, including delivering game results, calculating and crediting winnings, and applying bonus wagering requirements.
• Fraud detection, money laundering prevention, and compliance with applicable anti-financial-crime obligations, including transaction monitoring and suspicious activity reporting.
• Responsible gaming monitoring, including tracking session duration, detecting unusual betting patterns, and providing deposit limit alerts and self-exclusion management.
• Customer support — responding to queries, complaints, and dispute submissions sent to [email protected], and maintaining a record of support interactions for quality assurance and regulatory purposes.

4. Legal Basis for Processing Your Data

dkwim processes your personal data on the following legal grounds, depending on the specific processing activity in question.

• Contractual necessity — processing your registration data, payment data, and gaming activity data is necessary for dkwim to fulfil its obligations to you under the Terms and Conditions agreement you accepted when registering.
• Legal obligation — identity verification (KYC), transaction monitoring, and anti-money-laundering record-keeping are required by applicable financial crime prevention obligations. dkwim must retain certain records to comply with these requirements regardless of your preferences.
• Legitimate interests — fraud detection, platform security monitoring, and responsible gaming monitoring are carried out in our legitimate interest and in the interest of all players to maintain a safe and fair gaming environment.
• Consent — where we send you promotional communications or use optional analytics cookies, we do so only where you have given explicit consent. You may withdraw this consent at any time.

5. Sharing Your Information

dkwim does not sell, rent, or trade your personal data. We share your information only in the limited circumstances described below, and only with parties who are bound by appropriate confidentiality and data protection obligations.

• Payment processors — we share transaction data with bKash, Nagad, Rocket, and approved banking partners to the extent necessary to process your deposits and withdrawals. Each payment partner is bound by its own privacy obligations under Bangladesh financial regulation.
• Game providers — game studios such as Pragmatic Play, Evolution Gaming, Microgaming, NetEnt, and Spribe receive session identifiers and stake data to the extent required to deliver their game services. They do not receive your full registration or financial data.
• Fraud prevention and financial crime compliance — we may share data with fraud detection service providers and, where legally required, with relevant financial intelligence or law enforcement authorities. Such disclosures are made only where we have a legal obligation or a legitimate legal basis to do so.
• Technical infrastructure providers — hosting, content delivery, and platform monitoring services may have access to server-level data. These providers operate under strict data processing agreements and are prohibited from using your data for any purpose other than providing the specified technical service to dkwim.

Where data is shared with any third party, dkwim takes reasonable steps to ensure that the receiving party maintains data protection standards equivalent to those described in this Policy. We do not transfer your personal data outside of our approved service provider network without appropriate safeguards.

6. Payment Data and Financial Information

All financial transactions on dkwim are processed via Bangladesh-regulated mobile financial service providers (bKash, Nagad, Rocket) or approved banking partners. dkwim uses secure, encrypted channels for all payment data transmissions. We do not store mobile wallet PINs, mobile banking passwords, or any authentication credentials belonging to your payment provider account.

Transaction records — including deposit amounts, withdrawal amounts, transaction reference numbers, and timestamps — are retained by dkwim as part of our financial record-keeping obligations. These records may be used to resolve payment disputes, respond to regulatory enquiries, and produce account statements on request.

7. Cookies and Tracking Technologies

dkwim uses cookies and similar tracking technologies to operate the platform, maintain session state, and collect the technical data described in Section 2 of this Policy. We use the following categories of cookies.

• Strictly necessary cookies — these are essential for the platform to function. They maintain your login session, remember your language preference, and enable the cashier and game loading functions. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies — these remember your platform preferences such as display settings and notification preferences. They improve your experience but are not required for the core gaming functions to operate.
• Analytics cookies — where you have consented, these track aggregated usage patterns (pages visited, session duration, feature interaction counts) to help dkwim improve the platform. Individual players are not identifiable from analytics data. Analytics cookies are optional.
• Security and fraud detection cookies — these are used to identify suspicious login attempts, detect automated bot activity, and protect your account from unauthorised access. They are strictly necessary from a security standpoint and cannot be disabled.

You can manage cookie preferences through your device browser settings. Please note that disabling strictly necessary cookies will prevent the dkwim platform from functioning correctly and may make it impossible to log in or place bets. dkwim does not use third-party advertising cookies or cross-site tracking technologies.

8. Data Retention

dkwim retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention periods apply, subject to any longer period required by law.

Account registration and KYC data is retained for a minimum of 5 years from account closure. Financial transaction records are retained for a minimum of 5 years from the date of the transaction. Gaming activity logs are retained for 2 years from the date of the activity. Technical and device data is retained for 12 months from collection. Support correspondence is retained for 3 years from the date of the last interaction. Where a dispute, legal claim, or regulatory investigation is ongoing, relevant data will be retained until that matter is fully resolved, regardless of the standard retention period.

9. Your Data Rights

As a user of the dkwim platform, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact us at [email protected] with the subject line "Data Rights Request" and include your registered mobile number for identification.

• Right of access — you may request a copy of the personal data dkwim holds about you, including what categories of data we hold, why we hold it, and with whom it has been shared.
• Right to rectification — if you believe any personal data we hold about you is inaccurate or incomplete, you may request that we correct it. We will action valid rectification requests within 10 Bangladesh Standard Time business days.
• Right to erasure — in certain circumstances (for example, where data is no longer necessary for the purpose it was collected, or where you withdraw consent), you may request erasure of your personal data. This right is subject to our legal retention obligations — we cannot erase data we are legally required to keep.
• Right to restrict processing — you may request that we restrict our processing of your personal data in certain circumstances, for example while a rectification request is being reviewed or while a dispute is pending.
• Right to object — where we process your data on the basis of legitimate interests, you have the right to object. We will stop processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

dkwim will respond to all data rights requests within 30 days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension within the initial 30-day period.

10. Security Measures

dkwim implements a multi-layered approach to data security. At the network level, all platform traffic is served exclusively over HTTPS using 256-bit SSL/TLS encryption. At the application level, all passwords are stored as one-way cryptographic hashes — we cannot retrieve your password, only reset it. Payment account identifiers are stored in encrypted form. Access to production systems containing personal data is restricted to authorised personnel only, under a principle of least privilege.

dkwim conducts periodic internal security reviews of its data handling practices. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, dkwim will notify affected players promptly via their registered contact details and will take immediate steps to contain and remediate the breach.

11. Children's Privacy

The dkwim platform is strictly for adults aged 21 and above. We do not knowingly collect, use, or retain personal data from individuals under the age of 21. Age verification is a mandatory step in the dkwim account registration and KYC process, and any account found to belong to a person under 21 will be immediately closed and all associated data securely deleted, subject only to any data we are legally required to retain for anti-fraud or regulatory purposes.

If you are a parent or guardian and believe that a person under the age of 21 has registered an account on dkwim, please contact us immediately at [email protected]. We will investigate the report promptly, close any confirmed underage account, and securely delete the personal data associated with it.

12. Changes to This Privacy Policy

dkwim reserves the right to update or amend this Privacy Policy at any time. Where a material change is made — for example, a change to what data we collect, how we use it, or with whom we share it — we will provide advance notice to registered players via their registered mobile number or email address, or by displaying a prominent notice on the platform, at least 7 days before the change takes effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We recommend that you review this Policy periodically to stay informed about how dkwim protects your personal information. Your continued use of the dkwim platform after any update constitutes acceptance of the revised Policy.

13. Contact Us About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data dkwim holds about you, please contact us using the details below. Our support team operates on Bangladesh Standard Time (UTC+6) and aims to respond to all privacy-related enquiries within 5 business days.