Kirkeya Privacy Policy

01 Overview

Kirkeya is an online betting and gaming platform built for players in Bangladesh. We operate the website at kirkeya.com and the Kirkeya mobile application. When you use Kirkeya — whether you're registering an account, making a deposit, placing a bet, or just browsing the site — we collect certain information about you. This Privacy Policy explains what that information is, why we need it, and how we handle it.

We take privacy seriously at Kirkeya. We don't sell your data. We don't share it with advertisers. We collect only what we genuinely need to run the platform, keep your account secure, comply with our legal obligations, and give you the best possible experience. That's it.

This Privacy Policy applies to all personal data collected through the Kirkeya website, mobile app, and any communications between you and Kirkeya — including live chat, email, and any other support channels. By creating a Kirkeya account or using the platform, you confirm that you have read and understood this Privacy Policy.

02 Data We Collect

Kirkeya collects personal data in two main ways: information you provide directly to us, and information we collect automatically when you use the platform. Here is a breakdown of both categories.

Information you provide directly:

• Full legal name, date of birth, and gender — collected during account registration for identity verification purposes.
• Email address and mobile phone number — used for account communications, security alerts, and support.
• Payment information — including your bKash or Nagad mobile number, used to process deposits and withdrawals. Kirkeya does not store full payment credentials; transactions are handled via secure payment gateways.
• Identity documents — such as a copy of your National ID card or passport, collected when we are required to verify your identity under our KYC (Know Your Customer) obligations.
• Communications — any messages, emails, or chat transcripts you send to Kirkeya's support team.
• Responsible gaming information — such as deposit limits, session limits, or self-exclusion requests that you set through your account.

Information collected automatically:

• Device information — including device type, operating system, browser type, and unique device identifiers.
• IP address and approximate location — used for fraud prevention, regulatory compliance, and to ensure the platform is being accessed from eligible locations.
• Usage data — including pages visited, games played, bets placed, session duration, and click patterns. This helps us improve the platform and personalise your experience.
• Cookies and similar tracking technologies — see Section 6 for full details on how Kirkeya uses cookies.

03 How We Use Your Data

Kirkeya uses your personal data only for legitimate, clearly defined purposes. We do not use your data for anything beyond what is described in this Privacy Policy without first obtaining your explicit consent.

• Account management: To create, maintain, and secure your Kirkeya account, including processing your registration, verifying your identity, and managing your account settings.
• Transaction processing: To process deposits and withdrawals via bKash and Nagad, and to maintain accurate records of all financial transactions on your account.
• Legal compliance: To meet our obligations under applicable laws and regulations, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and responsible gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and any other illegal or prohibited conduct on the Kirkeya platform.
• Customer support: To respond to your queries, resolve disputes, and provide assistance through our live chat and email support channels.
• Platform improvement: To analyse how players use Kirkeya, identify areas for improvement, and develop new features and products that better serve our players.
• Personalisation: To tailor your Kirkeya experience — including relevant promotions, game recommendations, and content — based on your preferences and activity on the platform.
• Marketing communications: To send you information about Kirkeya promotions, bonuses, and new features — but only where you have opted in to receive such communications. You can opt out at any time.
• Responsible gaming: To monitor your gaming activity and, where necessary, reach out to you about responsible gaming tools or apply limits in accordance with our responsible gaming obligations.

04 Legal Basis for Processing

Kirkeya processes your personal data on one or more of the following legal bases, depending on the specific purpose for which the data is being used:

• Contractual necessity: Processing your data is necessary to perform the contract between you and Kirkeya — i.e., to operate your account, process transactions, and deliver the services you have signed up for.
• Legal obligation: Kirkeya is required by law to collect and retain certain data, including identity verification documents and transaction records, to comply with AML and KYC regulations.
• Legitimate interests: Kirkeya processes certain data — such as usage data and technical data — on the basis of our legitimate interests in operating a secure, fair, and well-functioning platform. We always balance these interests against your privacy rights.
• Consent: Where we rely on your consent to process your data — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

05 Sharing Your Data

Kirkeya does not sell your personal data to any third party, full stop. We do not share your data with advertisers, data brokers, or any other commercial third parties for their own marketing purposes.

There are limited circumstances in which Kirkeya may share your personal data with third parties, and these are set out below:

• Payment providers: We share the minimum necessary financial data with bKash and Nagad to process your deposits and withdrawals. These providers are bound by their own privacy policies and data protection obligations.
• Identity verification providers: Where we use third-party KYC services to verify your identity, we share the relevant identity documents and data with those providers. They are contractually bound to use your data only for verification purposes.
• Technology and infrastructure providers: Kirkeya uses third-party cloud hosting, analytics, and security services to operate the platform. These providers process data on our behalf and are bound by strict data processing agreements.
• Legal and regulatory authorities: Kirkeya may be required to disclose your personal data to law enforcement agencies, regulatory bodies, or courts where we are legally obligated to do so — for example, in connection with an AML investigation or a court order.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of Kirkeya's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and your rights will be protected.

In all cases where Kirkeya shares your data with third parties, we ensure that appropriate safeguards are in place to protect your privacy and that the data is used only for the specific purpose for which it was shared.

06 Cookies & Tracking Technologies

Kirkeya uses cookies and similar tracking technologies on the kirkeya.com website and in the Kirkeya mobile app. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and understand how you use the platform.

• Essential cookies: These are necessary for the Kirkeya platform to function. They enable core features like account login, session management, and security. You cannot opt out of essential cookies without disabling the platform entirely.
• Functional cookies: These remember your preferences — such as your preferred language, display settings, and recently played games — to give you a more personalised experience on Kirkeya.
• Analytics cookies: These help us understand how players use Kirkeya — which pages are most visited, where players drop off, and how features are being used. This data is aggregated and anonymised where possible.
• Security cookies: These help us detect and prevent fraudulent activity, including bot traffic and account takeover attempts.

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking certain cookies may affect the functionality of the Kirkeya platform. Kirkeya does not use third-party advertising cookies or share cookie data with advertisers.

07 Data Retention

Kirkeya retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five years after account closure, in accordance with our AML and KYC obligations.
• Transaction records: Retained for a minimum of five years from the date of the transaction, as required by financial regulations.
• Identity verification documents: Retained for a minimum of five years after account closure or the completion of the relevant verification process.
• Support communications: Retained for up to three years from the date of the communication, unless a longer retention period is required for dispute resolution or legal purposes.
• Usage and analytics data: Retained in anonymised or aggregated form indefinitely for platform improvement purposes. Identifiable usage data is retained for up to two years.
• Marketing preferences: Retained until you withdraw your consent or close your account.

When your personal data is no longer required, Kirkeya will securely delete or anonymise it in accordance with our data retention and disposal procedures.

08 Security

Kirkeya takes the security of your personal data seriously. We implement a range of technical and organisational measures to protect your data against unauthorised access, loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Kirkeya platform.
• Encryption of sensitive data at rest, including identity documents and financial information.
• Two-factor authentication (2FA) available for all Kirkeya accounts to protect against unauthorised login.
• Regular security audits and penetration testing of the Kirkeya platform and infrastructure.
• Strict access controls — only authorised Kirkeya personnel with a legitimate need can access your personal data.
• Fraud detection systems that monitor account activity in real time for signs of unauthorised access or suspicious behaviour.

While Kirkeya takes all reasonable steps to protect your data, no online platform can guarantee absolute security. If you believe your Kirkeya account has been compromised, contact our support team immediately via live chat or at [email protected].

09 Your Rights

As a Kirkeya player, you have a number of rights in relation to your personal data. Kirkeya is committed to honouring these rights promptly and transparently. Your rights include:

• Right to access: You have the right to request a copy of the personal data Kirkeya holds about you. We will provide this within 30 days of receiving your request.
• Right to rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. You can update most of your account information directly through the Mine section of your account.
• Right to erasure: In certain circumstances, you have the right to request that Kirkeya delete your personal data. Note that we may be required to retain certain data for legal or regulatory reasons even after your account is closed.
• Right to restrict processing: You have the right to request that Kirkeya restricts the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to request that we transfer it to another service provider where technically feasible.
• Right to object: You have the right to object to Kirkeya processing your personal data for direct marketing purposes. You can opt out of marketing communications at any time through your account settings or by contacting support.
• Right to withdraw consent: Where Kirkeya processes your data on the basis of your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact Kirkeya's support team at [email protected]. We will respond to all data rights requests within 30 days. In complex cases, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

10 Minors

Kirkeya is strictly an 18+ platform. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, you must not use the Kirkeya platform or provide any personal data to us.

If Kirkeya becomes aware that personal data has been collected from a person under the age of 18, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on Kirkeya, please contact us immediately at [email protected].

Kirkeya uses age verification tools as part of our registration process and may request proof of age at any time. We take our responsibility to prevent underage gambling seriously and invest in robust age verification measures to protect young people.

11 Changes to This Policy

Kirkeya may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or the services we offer. When we make material changes to this Privacy Policy, we will notify registered players via email and/or a prominent notice on the Kirkeya platform.

The updated Privacy Policy will take effect from the date specified in the notice. Your continued use of the Kirkeya platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised policy. We recommend reviewing this page periodically to stay informed of any changes.

The date at the top of this page always reflects when this Privacy Policy was last updated. If you have questions about any changes, contact us at [email protected].

12 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way Kirkeya handles your personal data, please get in touch. Our support team is available 24/7 and will respond to all privacy-related enquiries promptly.