c100i Privacy Policy

1 Introduction

c100i ("we", "us", "our") operates the online gaming and sports betting platform available at c100i.io. We act as the data controller for personal information collected through this platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data belonging to players, visitors, and any other individuals who interact with our platform ("you", "your").

We are committed to protecting the privacy and security of all individuals whose personal data we hold. This Policy has been drafted in accordance with internationally recognised data protection principles and reflects the standard practices applied by licensed offshore gaming operators serving players in Bangladesh and other jurisdictions.

This Policy should be read alongside our Terms & Conditions and our Responsible Gaming policy, both of which form part of the agreement between you and c100i. Defined terms used in this Policy have the same meaning as in the Terms & Conditions unless otherwise stated.

If you are a player based in Bangladesh, this Policy applies to all personal data you submit when registering, verifying your identity (KYC), making deposits or withdrawals via bKash, Nagad, Rocket, or Upay, participating in promotions, or contacting our support team.

2 Data We Collect

c100i collects the following categories of personal data, depending on how you interact with our platform:

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, unless directly required for responsible gaming purposes (for example, if you voluntarily disclose a gambling-related health condition when requesting self-exclusion).

3 How We Collect Data

c100i collects personal data through the following channels:

• Direct Submission: Information you provide when you register an account, complete KYC verification, submit a deposit or withdrawal request, contact our support team, or respond to a survey or promotion.
• Automated Technologies: Data collected automatically when you visit or use our platform, including cookies, session tokens, server logs, and device fingerprinting technologies.
• Payment Providers: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and other payment partners when you deposit or withdraw funds.
• Identity Verification Partners: Data received from third-party KYC service providers used to verify the authenticity of identity documents you submit.
• Game Providers: Gameplay data and session statistics received from game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi via integrated APIs.
• Fraud Prevention Services: Risk signals and flagging data received from third-party fraud detection and anti-money laundering screening services.
• Publicly Available Sources: In limited circumstances, we may verify information against publicly available records or sanctions lists as part of AML due diligence.

4 How We Use Your Data

c100i processes your personal data for the following purposes. We only use data where we have a valid legal basis to do so (see Section 5):

• Account Management: To create and maintain your player account, authenticate your identity at login, and administer your account settings and preferences.
• Service Delivery: To provide you with access to our casino games, live dealer tables, crash games, slots, and sports betting markets — including those from providers like Spribe, Pragmatic Play, and Evolution Gaming.
• Payment Processing: To process deposits and withdrawals in Bangladeshi Taka (BDT) via bKash, Nagad, Rocket, Upay, and bank transfer, and to maintain accurate financial records.
• KYC and AML Compliance: To verify your identity, confirm you meet the 21+ age requirement, and conduct ongoing anti-money laundering and counter-terrorism financing checks in line with international gaming industry standards.
• Responsible Gaming: To monitor your gaming behaviour for signs of problem gambling, apply deposit limits or self-exclusion periods you have requested, and intervene proactively where patterns of harmful play are detected.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, account takeover attempts, bonus abuse, multi-accounting, and other prohibited conduct described in our Terms & Conditions.
• Customer Support: To respond to your enquiries, complaints, and support requests efficiently and maintain a record of all communications for quality and compliance purposes.
• Marketing and Promotions: With your consent, to send you promotional offers, bonus notifications, and information about new games, seasonal campaigns (Eid, BPL, T20 World Cup, Pohela Boishakh), and other c100i updates via email or in-platform messaging. You may opt out at any time.
• Platform Analytics: To analyse how players use our platform, identify areas for improvement, test new features, and optimise the overall user experience for our Bangladesh player base and international users.
• Legal Obligations: To comply with applicable law, regulatory requirements, court orders, and lawful requests from competent authorities, including the retention of financial records for the period required by relevant regulations.

5 Legal Basis for Processing

c100i processes your personal data on the following legal bases, consistent with internationally recognised data protection frameworks:

Where we rely on legitimate interests as our legal basis, we have assessed that our interests are not overridden by your data protection rights and freedoms. You may request details of these assessments by contacting us at the email address in Section 14.

6 Data Sharing & Disclosure

c100i does not sell your personal data to third parties for their own marketing purposes. We share your data only in the limited circumstances described below, and always with appropriate contractual protections in place:

• Payment Processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, Visa, Mastercard, and other payment partners receive transaction data necessary to process your deposits and withdrawals.
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other integrated studios receive your account identifier and session token to deliver gameplay. They do not receive your full identity or payment details.
• KYC and Compliance Providers: Third-party identity verification and AML screening services receive the document data you submit during verification in order to confirm your identity and screen against sanctions lists.
• Fraud Detection Services: Specialist risk management providers receive technical data (IP address, device fingerprint, behavioural signals) to assess fraud risk and flag suspicious activity.
• Cloud and Hosting Infrastructure: Our platform is hosted on secure cloud infrastructure. Hosting providers process data on our behalf under strict data processing agreements and are not permitted to use your data for their own purposes.
• Professional Advisors: Lawyers, auditors, and accountants acting as our professional advisors may access personal data to the extent required to provide their services, subject to professional confidentiality obligations.
• Law Enforcement and Regulatory Bodies: We will disclose personal data to competent authorities, regulators, or law enforcement agencies when required to do so by applicable law, court order, or where we believe in good faith that disclosure is necessary to prevent fraud, money laundering, or serious harm.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of the assets of c100i, your personal data may be transferred to the successor entity. We will notify you of any such transfer and your rights in relation to it.

7 Cookies & Tracking Technologies

c100i uses cookies, web beacons, pixel tags, local storage objects, and similar tracking technologies to operate and improve the platform. When you first visit our site, you will be presented with information about our use of cookies.

• Strictly Necessary Cookies: Required for the platform to function. These enable you to log in, maintain your session, access your account balance, and use core features. They cannot be disabled without disrupting platform functionality.
• Performance and Analytics Cookies: Collect anonymised or pseudonymised data about how players use the platform — pages visited, session duration, error events — to help us identify performance issues and improve the user experience.
• Functional Cookies: Remember your preferences such as language settings, game display options, and responsible gaming tool configurations to personalise your experience across sessions.
• Marketing and Targeting Cookies: Used, with your consent, to deliver relevant promotional content on and off the c100i platform. These cookies may be set by c100i or by trusted third-party marketing partners. You may withdraw consent at any time via your browser or device settings.

Most web browsers allow you to control cookies through their settings. Restricting or disabling certain cookies may affect the functionality of the c100i platform. Session and authentication cookies are strictly necessary for you to remain logged in and for your bets and account balance to be correctly tracked.

8 Data Retention

c100i retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming licence obligations. The following retention periods apply as a general guide:

Where retention beyond these periods is required by a legal obligation, ongoing investigation, or active dispute, we will retain the relevant data until the matter is fully resolved. At the end of the applicable retention period, data is securely deleted or anonymised so it can no longer be associated with any individual.

9 Data Security

c100i applies a multi-layered security framework to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our technical and organisational measures include:

• Encryption in Transit: All data transmitted between your browser or device and the c100i platform is encrypted using TLS 1.3, the current industry standard for secure communications.
• Encryption at Rest: Sensitive data stored in our databases — including passwords, payment account references, and identity document data — is encrypted using strong, industry-standard algorithms.
• Password Security: Account passwords are hashed using bcrypt with a sufficiently high cost factor. Plain-text passwords are never stored or transmitted within our systems.
• Access Controls: Access to personal data within c100i's systems is restricted on a need-to-know basis using role-based access control (RBAC). All internal access is logged and subject to regular review.
• Two-Factor Authentication: Players are strongly encouraged to enable 2FA on their accounts. Internal staff accounts with access to player data require 2FA as a mandatory control.
• Vulnerability Management: Our platform undergoes regular security assessments, penetration testing, and code reviews. Known vulnerabilities are patched promptly in accordance with our security response policy.
• Incident Response: In the event of a data breach that is likely to result in a risk to your rights and freedoms, c100i will notify affected individuals and relevant authorities in accordance with applicable notification requirements and without undue delay.

10 Your Data Rights

Depending on the data protection laws applicable to you, you may have some or all of the following rights in relation to your personal data held by c100i. We will respond to all valid requests within a reasonable timeframe, typically within 30 days of receipt:

• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how we use it. This is sometimes called a Subject Access Request (SAR).
• Right to Rectification: You have the right to request correction of any personal data that is inaccurate or incomplete. You may update some account information directly through your account settings; for changes to identity documents, contact support.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purpose it was collected, or where you withdraw your consent and no other legal basis applies. Note that this right is subject to our legal retention obligations (see Section 8).
• Right to Restrict Processing: You have the right to request that we limit how we use your data in certain circumstances, for example while a dispute about its accuracy is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing based on our legitimate interests, including profiling. You have an unconditional right to object to direct marketing at any time.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact our data team at [email protected], clearly identifying your request type and providing sufficient information for us to verify your identity before responding. We will not charge a fee for reasonable requests but reserve the right to charge for manifestly unfounded or excessive requests.

11 Children and Minors

During registration, all players must confirm that they are aged 21 or older. We use age verification procedures, including KYC document checks, to enforce this requirement. If we discover or have reasonable grounds to believe that personal data has been collected from an individual under 21, we will take immediate steps to delete that data and close the associated account. All funds held in the account will be returned to a verified legal guardian or parent where possible.

Parents and guardians who believe that a minor may have registered an account on c100i are encouraged to contact us immediately at [email protected]. We take all such reports seriously and will investigate and act promptly.

We also recommend that parents and guardians use parental control software to restrict minors' access to online gambling platforms as an additional safeguard. Our Responsible Gaming page provides further guidance on available tools.

12 International Data Transfers

c100i operates as an international gaming platform. To deliver our services, your personal data may be processed in countries other than Bangladesh, including countries where our servers, cloud infrastructure, or third-party service providers are located. These countries may have data protection laws that differ from those in your home jurisdiction.

When we transfer personal data internationally, we take steps to ensure that appropriate safeguards are in place to protect your data. These safeguards may include:

• Standard contractual clauses approved by relevant data protection authorities, incorporated into our contracts with international service providers.
• Data processing agreements that impose obligations on recipients equivalent to those we apply ourselves.
• Transfers to jurisdictions that maintain an adequate level of data protection as recognised by international standards.

By using the c100i platform, you acknowledge and consent to the transfer of your personal data to countries outside Bangladesh for the purposes described in this Policy. If you require further information about the safeguards we have in place for international data transfers, please contact us using the details in Section 14.

13 Changes to This Policy

c100i reserves the right to update or replace this Privacy Policy at any time to reflect changes in our data practices, new legal obligations, updates to our platform, or changes in the services we offer. When we make material changes, we will update the effective date at the top of this page and, where the changes are significant, notify registered players via email or an in-platform message.

We encourage you to review this page periodically to remain informed about how we handle your personal data. The version of the Policy in force at the time you use the platform governs the processing of your data. Your continued use of c100i following the publication of an updated Policy constitutes acceptance of the revised terms.

If we propose to use your personal data for a materially different purpose than originally collected, we will seek your fresh consent before doing so, or provide you with a clear opportunity to object.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or our data practices, please reach out to our team using the contact details below. We aim to acknowledge all privacy-related enquiries within 48 hours and to resolve them fully within 30 days.

When contacting us about a data rights request, please include your registered username and a clear description of your request. For Subject Access Requests or requests for erasure, we may ask you to verify your identity before processing the request to ensure we are responding to the correct individual.

If you are not satisfied with our response, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction, or to seek appropriate legal remedy.