e2be Privacy
Policy & Data Practices

1. About This Policy

This Privacy Policy ("Policy") describes how e2be ("the Company", "we", "us", "our"), the operator of the online gaming platform accessible at https://e2be.onl ("the Platform"), collects, processes, stores, shares, and protects personal data relating to individuals who visit, register on, or use the Platform ("you", "your", "the Player").

This Policy applies to all personal data collected through the Platform, including data submitted during account registration, identity verification, payment processing, customer support interactions, promotional participation, and general browsing activity on the Platform. It applies to all players located in Bangladesh and any other jurisdiction from which the Platform is accessed.

This Policy should be read alongside our Terms & Conditions (available at /terms-conditions) and our Responsible Gaming Policy (available at /responsible-gaming), both of which are incorporated herein by reference. In the event of any conflict between this Policy and any other document, this Policy governs with respect to data protection matters.

e2be is committed to handling your personal data in accordance with applicable international data protection standards, including principles aligned with the General Data Protection Regulation (GDPR) framework, even where such frameworks may not be directly applicable in your jurisdiction. We adopt these standards because we believe strong data protection is a mark of a trustworthy operator — not merely a legal obligation.

2. Data We Collect

e2be collects personal data in two ways: data you provide directly to us, and data collected automatically when you use the Platform. The following table summarises the categories of personal data we process:

e2be does not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data for the purposes of platform operation. Where identity documents submitted for KYC purposes may incidentally contain such data, it is processed solely for identity verification and is not extracted or used for any other purpose.

3. How We Use Your Data

e2be uses the personal data it collects for the following clearly defined purposes. We do not use your data for any purpose not listed below without first notifying you and, where required, obtaining your consent:

• Account creation and management: To register your account, authenticate your identity at login, and manage your account settings throughout the lifecycle of your relationship with e2be.
• Identity and age verification (KYC): To verify that you are at least 21 years of age and to confirm that you are who you claim to be, in accordance with our Know Your Customer obligations under our offshore operating licence.
• Payment processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, and any other supported payment method, and to maintain an accurate record of all financial transactions on your account.
• Platform delivery and personalisation: To present the Platform's games, sports betting markets, and promotions in a manner relevant to your usage patterns and stated preferences.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorised account access, money laundering, bonus abuse, and other prohibited conduct as defined in our Terms & Conditions.
• Customer support: To respond to your queries, complaints, and support requests via live chat, email, or WhatsApp, and to maintain records of those interactions for quality assurance and dispute resolution purposes.
• Responsible gaming compliance: To monitor your gaming behaviour for indicators of problem gambling and to fulfil our obligations under our responsible gaming framework, including administering self-exclusion, deposit limits, and time-out requests.
• Legal and regulatory compliance: To comply with our obligations under our offshore operating licence, applicable anti-money laundering (AML) regulations, and any lawful orders from competent authorities.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications. You may opt out at any time by contacting [email protected] or adjusting your account notification settings.
• Platform improvement and analytics: To analyse aggregate usage data and identify opportunities to improve the Platform's functionality, game library, user experience, and reliability.

4. Legal Basis for Processing

e2be processes your personal data on one or more of the following legal bases, consistent with internationally recognised data protection principles:

• Contractual necessity: Processing is necessary to perform our contract with you — namely, to provide you with access to the Platform and all associated services (account management, payments, game access, support).
• Legal obligation: Processing is necessary to comply with legal obligations imposed by our offshore operating licence, AML regulations, and any other applicable regulatory requirements.
• Legitimate interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and analytics — provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: For marketing communications and any non-essential cookies or tracking technologies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Where we rely on legitimate interests as our legal basis, we carry out a balancing test to ensure that our interests do not override your rights. The results of these assessments are documented internally. If you wish to obtain further information about the legitimate interests balancing tests we have conducted, please contact us at [email protected].

5. Sharing Your Data

e2be does not sell, rent, or otherwise transfer your personal data to third parties for their own commercial purposes. We share personal data only in the following circumstances, and only to the minimum extent necessary:

• Payment service providers: Your financial data is shared with mobile wallet operators (bKash, Nagad, Rocket, Upay) and any other payment processing partners strictly as required to process your deposits and withdrawals. These providers are bound by their own data protection obligations and are not permitted to use your data for any purpose other than payment processing.
• Identity verification providers: Where third-party KYC or AML screening services are used to verify your identity and screen for sanctions or PEP status, the minimum necessary identity data is shared with those providers under strict contractual data processing agreements.
• Game content providers: Game studios and live dealer providers (including Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, and Microgaming) may receive technical data (such as session tokens or pseudonymised player IDs) necessary to deliver their game content through the Platform. These providers do not receive your personally identifiable information unless specifically required by the game's jackpot verification process.
• Customer support platforms: Live chat and support ticketing system providers may process your communications data on our behalf as data processors under contractual data processing agreements.
• Analytics and platform infrastructure providers: Technical and usage data may be shared with hosting, cloud infrastructure, and analytics providers solely for the purpose of operating and improving the Platform.
• Regulatory and law enforcement authorities: e2be will disclose personal data to competent governmental or regulatory authorities where required to do so by law, court order, or in connection with the investigation of financial crime, fraud, or other serious offences. We will notify you of such disclosure where legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or a substantial part of e2be's business, your personal data may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection obligations being assumed by the acquirer.

6. Cookies & Tracking Technologies

e2be uses cookies and similar tracking technologies (including local storage, session tokens, and pixel tags) to operate the Platform effectively and to improve your experience. The following categories of cookies are in use:

• Strictly necessary cookies: These cookies are essential for the Platform to function. They enable core features such as user authentication, session management, fraud prevention, and load balancing. These cookies cannot be disabled without severely impairing your ability to use the Platform.
• Functional cookies: These cookies remember your preferences (such as your last-played game, preferred language settings, or notification preferences) to provide a more personalised experience. They are set only with your consent.
• Analytics cookies: These cookies collect aggregated, pseudonymised data about how players use the Platform — including which pages are visited most frequently, how long sessions last, and which features are used most often. This data helps us identify areas for improvement. Analytics cookies are set only with your consent.
• Marketing cookies: If you have consented to receive personalised promotional communications, marketing cookies may be used to track your engagement with those communications and to measure the effectiveness of our promotional campaigns. No marketing cookies are placed without your prior consent.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies will prevent you from accessing certain core features of the Platform, including account login and payment processing. Disabling other categories of cookies will not affect your ability to place bets or access games but may result in a less personalised experience.

e2be does not use third-party advertising networks or cross-site tracking technologies that would enable your activity on the Platform to be tracked across unrelated third-party websites. All tracking is confined to activity within the e2be Platform itself.

7. Data Retention

e2be retains personal data for as long as is necessary to fulfil the purpose for which it was collected, subject to any longer retention periods required by our regulatory obligations. The following retention schedules apply as a general guide:

• Account and identity data: Retained for the duration of your active account relationship with e2be, plus a minimum of 5 years following account closure, in compliance with our offshore licensing authority's AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, in accordance with anti-money laundering regulatory requirements.
• KYC and verification documents: Retained for the duration of your account, plus a minimum of 5 years following account closure. Documents are stored in encrypted form with access restricted to authorised compliance personnel only.
• Customer support communications: Retained for 3 years from the date of the interaction, for quality assurance, dispute resolution, and regulatory compliance purposes.
• Usage and technical data: Retained in identifiable form for 2 years, after which data is either deleted or anonymised for long-term aggregate analytics purposes.
• Marketing preference records: Retained for the duration of your account. Opt-out records are retained indefinitely to ensure your preferences are respected even if you later reopen an account.

At the expiry of the applicable retention period, personal data is securely deleted from active systems and backups in accordance with our data destruction procedures. Where complete deletion is not technically feasible (for example, in certain encrypted backup systems), the data is rendered permanently inaccessible and scheduled for deletion at the next available backup rotation cycle.

8. Data Security

e2be implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes, but is not limited to:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the Platform.
• Encryption at rest for all sensitive stored data, including identity documents, financial records, and authentication credentials.
• Role-based access controls (RBAC) that restrict access to personal data to only those employees and contractors with a documented business need.
• Multi-factor authentication (MFA) required for all administrative access to systems that store or process personal data.
• Regular penetration testing and vulnerability assessments conducted by qualified independent security professionals.
• Intrusion detection and monitoring systems that generate real-time alerts for anomalous access patterns or potential data breach indicators.
• Incident response procedures that require affected individuals to be notified within 72 hours in the event of a personal data breach that poses a risk to their rights and freedoms.

Notwithstanding these measures, no data transmission or storage system can be guaranteed to be 100% secure. You are responsible for maintaining the security of your account credentials. If you suspect that your account has been compromised, you must notify e2be immediately via the 24/7 live chat service. e2be will never ask you for your password through any communication channel.

9. Your Rights

As a player on the e2be Platform, you hold the following rights with respect to your personal data. e2be is committed to honouring these rights promptly and without unnecessary barriers. To exercise any of these rights, contact us at [email protected] or via the 24/7 live chat service:

e2be will respond to all data rights requests within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, this period may be extended by a further 60 days, of which you will be notified within the initial 30-day window. e2be reserves the right to refuse requests that are manifestly unfounded, repetitive, or that would require disclosure of information about other individuals.

Please note that the right to erasure does not apply where e2be is required to retain your data to comply with a legal obligation — for example, the 5-year AML retention requirement described in Section 7. In such cases, we will inform you of the specific legal basis for retaining the data and the expected deletion date.

10. Children & Minors

The e2be Platform is strictly prohibited for use by any person under the age of 21 years. e2be does not knowingly collect personal data from individuals under the age of 21. If you are a parent or guardian and have reason to believe that a minor in your care has registered an account or submitted personal data to the Platform, please contact us immediately at [email protected]. Upon receiving a verified report of minor account usage, e2be will promptly close the account and permanently delete all associated personal data from our systems, subject to any mandatory regulatory retention requirements.

e2be employs age verification controls at the point of registration and during the KYC process to minimise the risk of underage access. If our systems detect indicators that an account may be operated by a minor — including through payment analysis or document review — the account will be immediately suspended pending a full age verification investigation.

11. International Data Transfers

e2be operates under an international offshore licence and its Platform infrastructure, data processing systems, and certain service providers may be located outside of Bangladesh. As a result, your personal data may be transferred to and processed in countries other than the country in which you are located. These countries may have data protection laws that differ from those in your jurisdiction.

Whenever e2be transfers personal data internationally, it takes appropriate steps to ensure that the transfer is conducted lawfully and that adequate protections are in place, including:

• Transferring data only to countries or organisations that offer an adequate level of data protection as assessed by recognised international standards.
• Implementing standard contractual clauses or equivalent data processing agreements with all international data recipients.
• Applying technical safeguards — including encryption and pseudonymisation — to data transferred across borders.
• Conducting transfer impact assessments where required to evaluate the risk to data subjects in the destination jurisdiction.

By using the e2be Platform and accepting this Privacy Policy, you acknowledge and consent to the international transfer of your personal data as described in this section, subject to the protections described above.

12. Changes to This Policy

e2be reserves the right to update or modify this Privacy Policy at any time. When we make changes, we will update the "Last Updated" date at the top of this document and publish the revised Policy on this page. Where a change is material — that is, where it significantly affects the way in which we process your personal data or the rights available to you — we will take reasonable steps to notify you directly, such as via a notification on the Platform or by email to your registered address.

Your continued use of the Platform following the publication of any revised Privacy Policy constitutes your acceptance of the changes. If you do not agree to the revised Policy, you must cease using the Platform and contact us to request account closure. We encourage you to review this Policy periodically to stay informed of our current data practices.

13. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way in which e2be processes your personal data, please contact our Data Protection team using the details below. All contact details are provided as plain text only and are not clickable links:

• Email: [email protected] (plain text — not a link)
• Live Chat: Available 24/7 via the on-site chat widget on the Platform
• WhatsApp: +880 1700 000000 (plain text — not a link)
• Response time: Data rights requests are acknowledged within 3 business days and resolved within 30 calendar days (Bangladesh Standard Time, UTC+6).

e2be takes all privacy complaints seriously. If you submit a formal complaint and are not satisfied with our response, you may escalate the matter to the relevant supervisory authority in the jurisdiction under which our offshore operating licence is issued. Details of the applicable supervisory authority are available upon request from our support team.

e2be is committed to working constructively with all players to resolve data protection concerns promptly and fairly. We view every privacy inquiry as an opportunity to demonstrate our commitment to responsible data stewardship and to maintain the trust of the Bangladeshi gaming community we serve.