kirkay Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") sets out how kirkay ("kirkay", "we", "us", "our") collects, stores, uses, discloses, and protects personal data provided by or generated by individuals ("Player", "you", "your") who access or use the kirkay website at https://kirkay.ws and all associated services (the "Platform"). This Policy forms part of, and should be read alongside, the kirkay Terms & Conditions.

kirkay is committed to handling personal data responsibly, transparently, and in a manner consistent with generally accepted data protection principles. We collect only the data that is necessary to deliver our services, verify eligibility, process transactions, maintain security, and comply with applicable legal obligations.

This Policy applies to all current and former Players, visitors to the Platform who do not hold an account, and any individuals who contact kirkay through our support channels. If you do not agree to the terms of this Policy, you must not use the Platform or provide any personal data to kirkay.

2. Data We Collect and How We Collect It

2.1 Data You Provide Directly

When you register an account, complete the verification process, make a deposit or withdrawal, participate in a promotion, or contact our support team, you provide personal data directly to kirkay. This includes identity data, contact data, financial data, and communications data as described in the categories section above.

2.2 Data Collected Automatically

When you access the Platform, certain technical and device data is collected automatically through our servers, cookies, and similar technologies. This includes your IP address, device identifiers, browser settings, session duration, pages visited, and interaction patterns. This data helps us operate the Platform securely, detect fraudulent activity, and improve the user experience.

2.3 Data from Third Parties

In certain circumstances we may receive personal data about you from third parties. This includes identity verification data from document-checking service providers, fraud-screening data from payment processors such as bKash, Nagad, and Rocket, and publicly available information used to satisfy our anti-money-laundering obligations. We handle such third-party data with the same level of care as data collected directly from you.

3. How We Use Your Personal Data

kirkay uses personal data for the following specific purposes:

• Account management: creating, maintaining, and administering your kirkay account, including verifying your age (21+ requirement) and identity.
• Transaction processing: processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods, and maintaining accurate financial records.
• Service delivery: providing access to sports betting markets (including BPL, T20, IPL, and international cricket), casino games, slots, and VIP programme features.
• Security and fraud prevention: detecting, investigating, and preventing fraudulent activity, money laundering, unauthorised account access, and other prohibited conduct.
• Customer support: responding to your enquiries, resolving disputes, and maintaining records of support interactions.
• Legal compliance: fulfilling our obligations under applicable laws, responding to lawful requests from authorities, and retaining records for audit purposes.
• Responsible gaming: monitoring gambling patterns to identify potential problem gambling indicators and applying responsible gaming tools such as deposit limits and self-exclusion where appropriate.
• Platform improvement: analysing aggregated, anonymised usage data to improve Platform performance, game offerings, and the overall player experience.
• Communications: sending transactional messages such as deposit confirmations, withdrawal notifications, and account security alerts. Promotional communications are only sent where you have opted in.

4. Legal Basis for Processing

kirkay processes personal data on the following legal bases, depending on the specific purpose:

• Contractual necessity: processing required to fulfil our obligations to you under the Terms & Conditions, such as verifying your account and processing transactions.
• Legal obligation: processing required to comply with applicable law, including age verification, identity checks, anti-money-laundering requirements, and record-keeping obligations.
• Legitimate interests: processing for fraud prevention, Platform security, responsible gaming monitoring, and service improvement, where our interests are not overridden by your data protection rights.
• Consent: processing for optional purposes such as promotional communications, where you have given explicit, freely withdrawn consent. You may withdraw consent at any time by contacting support.

5. Data Sharing and Disclosure

5.1 Service Providers

kirkay shares personal data with trusted third-party service providers who assist us in operating the Platform. These include payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard), identity verification providers, cloud hosting providers, and game technology providers (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi). All service providers are contractually required to handle your data securely and only for the specific purpose for which it was shared.

5.2 Legal and Regulatory Disclosure

kirkay may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required to do so by applicable law, court order, or lawful authority. We will notify affected Players of such disclosures where permitted by law.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of kirkay's business, personal data held by us may be transferred to the acquiring entity. Affected Players will be notified of any such transfer and any resulting changes to this Privacy Policy with reasonable advance notice.

5.4 No Commercial Data Sales

kirkay does not sell, rent, or trade personal data to any third party for their independent commercial or marketing purposes. Period.

6. Cookies and Tracking Technologies

The kirkay Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, to maintain your session while you are logged in, to detect and prevent fraudulent activity, and to understand how Players interact with different parts of the Platform.

Essential cookies are required for the Platform to function and cannot be disabled. Analytics cookies help us understand aggregate usage patterns so we can improve the Platform — these are processed on an anonymised or pseudonymised basis. Preference cookies remember settings you have selected, such as language or notification preferences.

You may control non-essential cookies through your browser settings. Please be aware that disabling certain cookies may affect the functionality of the Platform. Continued use of the Platform following acceptance of this Policy constitutes consent to the use of cookies as described herein.

7. Data Retention

kirkay retains personal data for as long as necessary to fulfil the purposes for which it was collected, to maintain your account in an active state, and to comply with applicable legal obligations. Specifically:

• Account data is retained for the duration of your account plus a minimum of five (5) years following account closure, to meet financial record-keeping and anti-money-laundering requirements.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Support communication records are retained for a minimum of two (2) years from the date of the interaction.
• Technical and device data (including IP logs) is retained for a minimum of one (1) year for security and fraud investigation purposes.

Where data is no longer required for any active legal, contractual, or operational purpose, kirkay will securely delete or anonymise it in accordance with our internal data lifecycle procedures.

8. Data Security

kirkay implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include SSL/TLS encryption for all data transmitted between your device and our servers, encrypted storage of sensitive data fields, access controls limiting staff access to personal data on a need-to-know basis, regular security assessments of our Platform infrastructure, and incident response procedures designed to detect and contain data security events promptly.

While we take the security of your data seriously, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your kirkay account credentials. If you suspect that your account has been accessed without authorisation, contact our support team immediately via Telegram at @kirkaySupport or by email at [email protected].

9. Your Data Rights

You have the following rights in relation to the personal data kirkay holds about you:

• Right of access: you may request a copy of the personal data kirkay holds about you and information about how it is used.
• Right to rectification: you may request correction of inaccurate or incomplete personal data.
• Right to erasure: you may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to restriction: you may request that we restrict the processing of your personal data in certain circumstances, such as while a complaint is being investigated.
• Right to data portability: where processing is based on consent or contractual necessity and carried out by automated means, you may request a machine-readable copy of your personal data.
• Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to object: you may object to processing carried out on the basis of legitimate interests, including direct marketing.

To exercise any of these rights, please contact the kirkay data team at [email protected] or via Telegram at @kirkaySupport. We will respond to all valid requests within a reasonable period, and in any event within thirty (30) days of receipt. We may need to verify your identity before processing your request.

10. Children and Minors

The kirkay Platform is strictly for individuals aged 21 years or older. We do not knowingly collect personal data from anyone under the age of 21. If we become aware that personal data belonging to a person under 21 has been collected, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

11. International Data Transfers

kirkay primarily processes personal data in connection with its services to players located in Bangladesh. Where data is transferred to or processed by third-party service providers located outside Bangladesh (for example, cloud infrastructure or game technology providers), kirkay ensures that appropriate data protection measures are in place, including contractual safeguards that require recipients to protect personal data to a standard consistent with this Policy.

12. Changes to This Policy

kirkay reserves the right to update or amend this Privacy Policy at any time. When changes are made, the revised Policy will be published on the Platform with an updated effective date. Where changes are material, we will notify active Players via the contact details held on their account with reasonable advance notice. Continued use of the Platform following publication of a revised Policy constitutes acceptance of the updated terms.

13. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way kirkay handles your personal data, please contact our support team:

• Email: [email protected] (plain text — this address is not a clickable link)
• Telegram: @kirkaySupport

We take all privacy enquiries seriously and aim to respond promptly. If you are not satisfied with our response, you may have the right to escalate the matter to a relevant supervisory authority in your jurisdiction.