cirkcx Privacy Policy

This Privacy Policy is issued by cirkcx ("cirkcx", "we", "us", "our"), the operator of the online casino and sports betting platform accessible at https://cirkcx.net and all associated mobile and web applications (collectively, the "Platform"). cirkcx acts as the data controller in respect of the personal data it collects from players and visitors.

This Privacy Policy applies to all individuals who:

• Visit or browse the cirkcx website without registering an account;
• Register a personal player account on the cirkcx Platform;
• Make deposits, place wagers, or withdraw funds via the Platform;
• Contact cirkcx customer support by any channel;
• Participate in promotions, tournaments, or any other cirkcx-organised event;
• Subscribe to cirkcx marketing communications.

This Privacy Policy does not apply to third-party websites, platforms, or applications that may be linked from the cirkcx Platform. cirkcx has no control over and accepts no responsibility for the privacy practices of any third-party service.

This Privacy Policy is written in English and is the authoritative version. cirkcx reserves the right to update this Privacy Policy at any time. The most current version will always be published at https://cirkcx.net/privacy-policy. Material changes will be communicated to registered players via email or an in-platform notification. Continued use of the Platform following any update constitutes acceptance of the revised Policy.

If you have any questions about how cirkcx handles your personal data, please contact our data support team at: [email protected]. We aim to respond to all privacy-related enquiries within 4–12 hours Bangladesh Standard Time (BST, UTC+6).

cirkcx collects personal data through a number of channels — directly from you when you register and use our Platform, automatically through your interactions with our website and apps, and in limited circumstances from trusted third-party verification and payment partners. The categories of data we collect are described below.

Registration & Identity Data

When you create a cirkcx account, we collect your full legal name, date of birth, residential address (including city — Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, or Cox's Bazar), email address, and Bangladesh mobile number. This data is essential to verify your identity, confirm your eligibility (18+ requirement), and operate your account in accordance with our Terms & Conditions.

Identity Verification (KYC) Data

To comply with Know Your Customer (KYC) obligations and responsible gaming best practices, cirkcx may request copies of your government-issued Bangladesh National Identity Card (NID), passport, utility bill, or bank statement. These documents are collected solely for the purpose of identity verification and are stored securely with restricted access.

Financial & Transaction Data

cirkcx records all deposit and withdrawal transactions conducted on the Platform, including the payment method used (bKash, Nagad, Rocket, Upay, SureCash, Tap, bank card, or bank transfer), transaction amounts in Bangladeshi Taka (BDT, ৳), timestamps, and transaction reference numbers. We do not store full card numbers or mobile banking PINs — financial credentials are processed directly by our payment partners.

Gameplay & Betting Activity Data

We collect records of all wagers placed on the Platform, including sports betting selections (e.g., BPL cricket, IPL, T20 World Cup markets), casino game sessions (slots, live dealer tables, crash games), stake amounts, outcomes, and session durations. This data is used for account management, dispute resolution, responsible gaming monitoring, and fraud prevention.

Technical & Device Data

We automatically collect technical data when you access the Platform, including your IP address, browser type and version, device type, operating system, screen resolution, referring URL, and pages visited. This data helps us ensure Platform security, optimise user experience, and detect fraudulent access patterns.

Communications Data

When you contact cirkcx customer support — via live chat, email, or any other channel — we retain a record of the communication, including your messages, the date and time, and any attachments you provide. This data is used to resolve your query, train our support team, and maintain an audit trail of account-related decisions.

cirkcx processes your personal data only for specific, legitimate purposes. We rely on one or more of the following lawful bases for each processing activity: performance of a contract (your account agreement with cirkcx), compliance with a legal obligation, your explicit consent, or our legitimate interests in operating a safe and sustainable platform.

Account Management

We use your registration and identity data to create and manage your cirkcx account, verify your eligibility, process your login credentials securely, and communicate account-related updates to you via email or SMS.

Payment Processing

Financial and transaction data is used to process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods; to apply bonus credits and deductions accurately; and to maintain a complete and auditable financial record for each player account.

Identity Verification & KYC Compliance

KYC document data is processed to verify your identity before your first withdrawal and in response to any regulatory request. This processing is necessary for cirkcx to comply with its anti-money-laundering (AML) and responsible gaming obligations.

Fraud Prevention & Platform Security

Technical, financial, and gameplay data is analysed by our security team to detect and prevent fraudulent activity, including account takeover attempts, payment fraud, bonus abuse, collusion, and the use of automated betting software. This processing is based on cirkcx's legitimate interest in maintaining a safe platform for all players.

Responsible Gaming Monitoring

Gameplay and financial data — including betting frequency, session duration, deposit patterns, and chasing-loss behaviour — is monitored to identify players who may be developing problematic gambling habits. Where such patterns are detected, cirkcx may proactively reach out to offer support, apply protective limits, or suggest self-exclusion options.

Customer Support

Communications data is used to respond to your queries, resolve disputes, process account closure requests, and maintain an audit trail of all material account events. Support interactions are also reviewed periodically for staff training and quality assurance purposes.

Marketing Communications

With your explicit consent at registration or via your account preferences, cirkcx may send you promotional emails or SMS notifications about bonuses, seasonal promotions (e.g., Eid, Pohela Boishakh, BPL season, Victory Day specials), and new game launches. You may withdraw this consent at any time by updating your notification preferences or emailing [email protected].

Platform Improvement

Aggregated and anonymised technical and gameplay data is used to analyse Platform usage patterns, identify performance bottlenecks, and improve the overall user experience. This processing uses data in a form that cannot identify you as an individual.

cirkcx does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. We share personal data only in the limited circumstances described in this section, and only to the extent strictly necessary for the stated purpose.

Payment Service Providers

To process your deposits and withdrawals, cirkcx shares the minimum necessary transaction data with licensed payment service providers including bKash, Nagad, Rocket, Upay, SureCash, Tap, Dutch-Bangla Bank, City Bank, BRAC Bank, and international card networks (Visa, Mastercard). Each payment partner operates under its own privacy and security framework. cirkcx is not responsible for the data practices of payment partners once data has been transmitted to them.

Identity Verification Partners

cirkcx may engage specialist KYC and identity verification providers to assist with document validation and fraud screening. These providers process your identity documents solely on behalf of cirkcx and under strict contractual data processing agreements. They are prohibited from using your data for any purpose other than the verification task for which they are engaged.

Game & Technology Providers

Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive limited gameplay session data (such as session identifiers and stake amounts) in order to deliver their games and resolve technical disputes. These providers do not receive your full personal profile and are contractually restricted from using any data for secondary purposes.

Regulatory & Law Enforcement Authorities

cirkcx may disclose personal data to regulatory authorities, law enforcement agencies, financial intelligence units, or courts of competent jurisdiction where required by applicable law, a court order, or a lawful regulatory request. cirkcx will inform affected players of such disclosures where legally permitted to do so.

Business Transfers

In the event that cirkcx undergoes a merger, acquisition, restructuring, or sale of all or part of its business assets, your personal data may be transferred to the acquiring entity as part of that transaction. cirkcx will notify affected players by email prior to any such transfer and will ensure that the acquiring entity agrees to handle your data in a manner consistent with this Privacy Policy.

International Transfers

As cirkcx operates as an internationally-oriented platform, some of the third parties described above may be located outside Bangladesh. Where personal data is transferred internationally, cirkcx takes reasonable steps to ensure that appropriate data protection safeguards are in place, including contractual data processing agreements that require the receiving party to maintain standards of protection equivalent to those applied by cirkcx.

The cirkcx Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, to remember your preferences, to analyse usage patterns, and to protect the Platform against fraudulent access. This section describes the types of cookies we use and how you can manage them.

What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognise your device on subsequent visits and to store preferences or session information. Cookies cannot execute code, carry viruses, or access files stored on your device.

Types of Cookies We Use

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They include session authentication tokens, load-balancing identifiers, and security tokens that protect against cross-site request forgery (CSRF). These cannot be disabled without impairing Platform functionality.
• Preference Cookies: These cookies remember your language preference, display settings, and other personalisation choices so that you do not need to reconfigure them on every visit.
• Analytics Cookies: cirkcx uses privacy-respecting analytics tools to collect aggregated, anonymised data about how players navigate the Platform — including pages visited, time spent per section, and navigation paths. This data informs Platform improvement decisions. No personally identifiable information is included in analytics reports.
• Security & Fraud Detection Cookies: These cookies help cirkcx identify unusual access patterns, detect account takeover attempts, and flag sessions originating from flagged IP addresses or devices previously associated with fraudulent activity.

Managing Your Cookie Preferences

You can manage or delete cookies at any time through your browser's settings. Most modern browsers allow you to block third-party cookies, clear all stored cookies, or receive a notification before a cookie is placed. Please note that disabling strictly necessary cookies will impair your ability to log in and use the cirkcx Platform.

cirkcx does not use cookies to serve third-party advertising or to track your activity across other websites for commercial profiling purposes.

cirkcx retains personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable law. Once the retention period has expired, personal data is securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

Active Account Data

While your cirkcx account remains active, we retain all registration, financial, and gameplay data necessary to operate your account, comply with our legal obligations, and provide customer support. This data is reviewed periodically to ensure it remains accurate and up to date.

Post-Closure Retention

Following the closure of your cirkcx account — whether voluntarily or by cirkcx — we retain your personal data for a minimum period of five (5) years from the date of closure. This retention period is required to satisfy AML record-keeping obligations, to respond to any regulatory enquiries or legal proceedings, and to support dispute resolution in respect of historical transactions.

KYC Documents

Identity verification documents (NID copies, passport scans, proof of address) are retained for a minimum of five (5) years following account closure, consistent with standard AML compliance requirements. Access to stored KYC documents is strictly limited to authorised personnel within cirkcx's compliance function.

Support Communications

Records of customer support interactions are retained for a period of three (3) years from the date of the interaction, unless the interaction relates to a dispute or legal matter, in which case it is retained for the duration of that matter plus two (2) years.

Marketing Data

If you have consented to receive marketing communications from cirkcx, your contact preferences and associated data are retained until you withdraw your consent. Upon withdrawal, your data will be removed from our active marketing lists within 30 days. A suppression record may be retained indefinitely to ensure we do not inadvertently contact you again.

Technical & Log Data

Server logs, access logs, and technical session data are retained for up to 12 months for security monitoring and fraud investigation purposes, after which they are automatically purged from our systems.

cirkcx takes the security of your personal data seriously. We implement a range of technical and organisational measures designed to protect your data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security posture is reviewed regularly and updated in line with industry best practices.

Technical Safeguards

All data transmitted between your browser or device and the cirkcx Platform is encrypted using Transport Layer Security (TLS 1.2 or higher). Personal data stored in our databases is encrypted at rest using AES-256 encryption. Player passwords are stored as salted cryptographic hashes — never in plain text — so that even cirkcx staff cannot view your password.

Access Controls

Access to personal data within cirkcx is strictly limited to staff who require it to perform their job functions. All internal access is governed by role-based access controls (RBAC), and every access event is logged for audit purposes. Staff handling personal data undergo regular data protection and security awareness training.

Fraud & Intrusion Detection

cirkcx operates continuous security monitoring tools to detect anomalous access patterns, potential intrusion attempts, and data exfiltration indicators. Our security team is available around the clock to respond to and contain any detected threat.

Data Breach Response

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, cirkcx will notify affected players by email as promptly as practicable and will take immediate steps to contain the breach, assess its scope, and remediate the vulnerability that allowed it to occur.

Your Role in Security

While cirkcx takes extensive measures to protect your data, the security of your account also depends on the steps you take. We strongly recommend that you use a unique, strong password for your cirkcx account, never share your login credentials with anyone, log out of your account when using a shared or public device, and contact support immediately at [email protected] if you suspect unauthorised access to your account.

No Absolute Guarantee

No security system is impenetrable. While cirkcx employs commercially reasonable security measures, we cannot guarantee that your data will never be accessed, disclosed, altered, or destroyed by a breach of our safeguards. By using the cirkcx Platform, you acknowledge and accept this inherent limitation.