kub9 Privacy Policy

This Privacy Policy ("Policy") describes how kub9 ("we", "us", "our", or the "Company") collects, uses, stores, shares, and protects the personal data of individuals ("you", "your", or the "Player") who access or use the kub9 online casino and sports betting platform at kub9.io (the "Platform"). This Policy applies to all players based in Bangladesh and to all interactions you have with the Platform, including account registration, deposits, gameplay, withdrawals, and customer support.

By registering an account or continuing to use the Platform, you confirm that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Policy, please discontinue use of the Platform immediately.

This Privacy Policy forms part of the overall legal framework governing your use of kub9, alongside the Terms and Conditions. In the event of a conflict between this Policy and any other document, this Policy shall prevail with respect to data privacy matters.

kub9 collects different categories of personal data depending on your level of interaction with the Platform. The following table summarises the main categories of data we collect and the purposes for which each category is processed.

We collect only the data that is necessary for the stated purposes. Where data collection is optional, we will make this clear at the point of collection.

kub9 collects personal data through the following channels:

• Direct Interactions: Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, respond to a survey, or participate in a promotion.
• Automated Technologies: As you navigate the Platform, we automatically collect technical and gameplay data through cookies, server logs, and similar technologies. This includes your IP address, browser characteristics, pages visited, time spent on each page, and clickstream data.
• Payment Processors: When you initiate a transaction via bKash, Nagad, Rocket, Upay, or a partner bank (Dutch-Bangla Bank, City Bank, BRAC Bank), we receive transaction confirmation data from those providers sufficient to credit or debit your kub9 wallet.
• Game Providers: Third-party game providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may pass back session and result data to kub9 for settlement and dispute-resolution purposes.
• KYC and Identity Verification Services: Where we engage a third-party identity verification service to validate the documents you submit, that service will return a pass/fail result and relevant extracted data fields to kub9.
• Publicly Available Sources: In rare circumstances related to fraud prevention or AML compliance, we may review publicly available information such as published sanctions lists or public legal records.

kub9 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your kub9 player account, including processing your login credentials and managing your wallet balance.
• Transaction Processing: To process deposits and withdrawals in Bangladeshi Taka (BDT) via your chosen payment method and to maintain accurate financial records of all transactions.
• Identity and Age Verification: To verify that you are aged 21 or above and to confirm your identity as required by our KYC programme. kub9 is committed to preventing underage gambling.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, bonus abuse, money laundering, and other prohibited activities as defined in our Terms and Conditions.
• Responsible Gaming: To monitor gameplay patterns that may indicate problem gambling behaviour, to enforce deposit limits and self-exclusion requests, and to provide timely responsible gaming interventions.
• Customer Support: To respond to your enquiries, investigate complaints, and resolve disputes relating to your account, transactions, or gameplay.
• Marketing and Promotions: Where you have opted in, to send you information about kub9 promotions, bonuses tied to events such as the BPL cricket season, Eid, and Pohela Boishakh, and personalised game recommendations. You may opt out of marketing communications at any time.
• Platform Improvement: To analyse aggregate usage data, identify technical issues, test new features, and improve the overall player experience on kub9.io.
• Legal and Regulatory Compliance: To comply with applicable anti-money laundering obligations, respond to lawful requests from regulatory authorities, and maintain records as required by law.

kub9 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing that is necessary to perform our contract with you — namely, operating your player account, processing your transactions, and delivering the gameplay services you have requested.
• Legal Obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, KYC requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out in pursuit of our legitimate business interests, including fraud detection, platform security, responsible gaming monitoring, and product analytics — where those interests are not overridden by your fundamental privacy rights.
• Consent: Processing carried out on the basis of your explicit consent, most notably the sending of direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

Where processing is based on consent, you have the right to withdraw that consent at any time by contacting our support team. Withdrawal of consent will not affect any processing already carried out on that legal basis prior to the withdrawal date.

kub9 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guideline:

Following expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with you as an individual. Anonymised aggregate data may be retained indefinitely for statistical and analytical purposes.

kub9 does not sell your personal data. We share your data only with the following categories of third parties, and only to the extent necessary for the stated purpose:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and BRAC Bank receive the transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are responsible for the security of data within their own systems.
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed studio partners receive session and stake data necessary to facilitate real-time gameplay and settle winnings.
• Identity Verification Partners: Third-party KYC providers receive the identity documents you submit and return verification results to kub9. These partners are contractually bound to process your data solely for verification purposes.
• IT Infrastructure Providers: Cloud hosting, database management, and content delivery providers who process data on our behalf under strict data processing agreements that prohibit any independent use of your data.
• Regulatory and Law Enforcement Authorities: Where required by law or a lawful order from a competent authority, kub9 may disclose personal data to government bodies, regulators, or law enforcement agencies. We will notify you of such a disclosure where we are legally permitted to do so.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of kub9's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you before your data becomes subject to a different privacy policy.

All third parties with whom we share personal data are required to maintain appropriate technical and organisational security measures and to process your data only for the purposes specified in their agreements with kub9.

kub9 uses cookies and similar tracking technologies (such as web beacons and local storage objects) to operate the Platform, remember your preferences, maintain your login session, and analyse how the Platform is used. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential to enable you to navigate the Platform and use its core features, such as maintaining your login session and remembering items in your wallet. These cookies cannot be disabled without impairing Platform functionality.
• Functional Cookies: These cookies remember choices you make — such as your preferred language, currency display (BDT), or game layout — to provide a more personalised experience. Disabling these cookies may affect the level of personalisation available to you.
• Analytics Cookies: These cookies collect anonymised data about how visitors use the Platform, such as which pages are visited most frequently and whether users encounter errors. This information is used solely to improve Platform performance and the player experience.

kub9 does not use advertising cookies or retargeting cookies that track your activity across third-party websites. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent certain features of the Platform from functioning correctly.

kub9 takes the security of your personal data seriously and has implemented a range of technical and organisational measures designed to protect your information against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and kub9 servers is encrypted using TLS 1.2 or higher, preventing interception by third parties.
• Encryption at Rest: Sensitive personal data — including identity documents, financial data, and password hashes — is encrypted at rest using AES-256 or equivalent standards.
• Access Controls: Access to personal data is granted only to kub9 personnel who need it to perform their job functions. Access rights are reviewed regularly and revoked immediately when no longer required.
• Two-Factor Authentication (2FA): kub9 supports 2FA for player accounts to provide an additional layer of protection against unauthorised access even if your password is compromised.
• Penetration Testing: kub9's infrastructure undergoes regular security assessments, including penetration tests conducted by independent security professionals, to identify and remediate vulnerabilities.
• Incident Response: kub9 maintains a formal data breach response procedure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected players without undue delay.

Whilst kub9 employs robust security measures, no method of electronic transmission or storage is 100% secure. We cannot guarantee the absolute security of your data. You are responsible for keeping your account login credentials confidential and for ensuring that you log out of your account when using a shared or public device.

As a kub9 player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team at [email protected] with your full name, registered email address, and a clear description of your request. We will respond within 30 days.

Please note that some rights are subject to limitations. For example, kub9 cannot delete data that it is legally required to retain for AML or KYC compliance purposes. Where we are unable to fulfil a request, we will explain the reason clearly in our response.

kub9 is strictly an adults-only platform. The Platform is not directed at, and is not intended for use by, individuals under the age of 21. kub9 does not knowingly collect personal data from anyone under the age of 21.

During the registration process, all players are required to confirm that they are 21 years of age or older. kub9 reserves the right to request age verification documents from any player whose age is in doubt. If kub9 discovers that a player under the age of 21 has registered an account, that account will be immediately suspended, all funds will be frozen pending investigation, and the player's personal data will be deleted in accordance with applicable law.

If you believe that a minor has registered an account on kub9 using your details or otherwise, please contact us immediately at [email protected]. We will investigate and take appropriate action without delay.

kub9 reserves the right to update or amend this Privacy Policy at any time. When we make material changes — for example, changes to the categories of data we collect, the purposes for which we use it, or the third parties with whom we share it — we will notify registered players by email and by displaying a prominent notice on the Platform prior to the changes taking effect.

Non-material changes (such as corrections of typographical errors or minor clarifications that do not affect how your data is processed) may be made without prior notice, though the effective date at the top of this document will always reflect the most recent revision.

Your continued use of the Platform after the effective date of any revision to this Policy constitutes your acceptance of the updated terms. If you disagree with any changes, you should stop using the Platform and close your account before the revised Policy takes effect.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way kub9 processes your personal data, please reach out to our support team using the contact details below. All privacy-related correspondence is handled in English and with strict confidentiality.

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week from any page on the Platform
• Response Time: Privacy requests acknowledged within 5 business days; resolved within 30 calendar days
• Operating Hours: 24/7 — Bangladesh Standard Time (BST, UTC+6)

When submitting a data subject request, please include your registered email address and account ID to allow our team to locate your records efficiently. Requests submitted without sufficient identifying information may be delayed while we verify your identity.