Privacy Policy — ace123

This Privacy Policy ("Policy") describes the practices of ace123 ("we", "us", "our", "the Platform") with respect to the collection, use, storage, disclosure, and protection of personal information relating to players, visitors, and prospective users of the ace123 platform at ace123.club ("the Service").

ace123 takes privacy seriously. We recognise that players in Bangladesh entrust us with sensitive personal and financial information when they register and transact on our platform. This Policy explains exactly what we do with that information, why we do it, and what choices you have in relation to your own data.

This Policy should be read alongside our Terms and Conditions and our Responsible Gaming Policy, all of which together govern your relationship with ace123. Defined terms used but not defined in this Policy carry the same meaning given to them in the Terms and Conditions.

ace123 collects personal data through multiple channels depending on how you interact with the platform. The categories of data we collect include the following:

2.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, email address, phone number, and residential address provided when creating your ace123 account.
• Identity Verification Documents: Copies of government-issued photo identification (National ID, passport, or driving licence) and proof of address submitted during KYC verification.
• Payment Data: Details of your registered payment methods including bKash account number, Nagad number, Rocket number, bank account information, or card details (where applicable). Full card numbers are never stored directly on our systems — payment tokenisation is applied.
• Communications: Records of messages, emails, live chat transcripts, or other correspondence you send to ace123's support team.
• Responsible Gaming Inputs: Deposit limit preferences, cool-off period requests, or self-exclusion instructions submitted through your account settings.

2.2 Data Collected Automatically

• Device and Technical Data: IP address, browser type, operating system, screen resolution, and device identifiers collected when you access the ace123 platform.
• Usage Data: Pages viewed, games played, bets placed, session duration, click patterns, and navigation paths on the ace123 website.
• Location Data: General geographic location derived from your IP address. ace123 does not collect precise GPS location data.
• Cookies and Tracking Technologies: Data collected via cookies, local storage, and similar technologies as described in Section 6 of this Policy.

2.3 Data Received from Third Parties

• Identity Verification Partners: Confirmation of identity and age verification results from our third-party KYC service providers.
• Payment Processors: Transaction status, reference numbers, and fraud signals from bKash, Nagad, Rocket, Upay, and other payment partners.
• Fraud and Risk Services: Risk scores and fraud indicators from specialist third-party fraud prevention providers.

ace123 uses collected personal data for the following purposes:

ace123 does not use personal data for automated decision-making or profiling that produces legal or similarly significant effects on players, except where such processing is required for fraud detection or responsible gaming interventions, in which case human review is available upon request.

ace123 processes personal data on one or more of the following legal grounds:

• Contractual Necessity: Processing that is required to fulfil our obligations to you under the Terms and Conditions, including account management, payment processing, and customer support.
• Legitimate Interests: Processing carried out to pursue ace123's legitimate business interests, including fraud prevention, platform security, and service improvement, where those interests are not overridden by your fundamental rights and freedoms.
• Legal Obligation: Processing required to comply with applicable legal requirements, including anti-money laundering obligations, record-keeping requirements, and cooperation with regulatory or law enforcement authorities.
• Consent: Where we rely on consent as a legal basis — primarily for direct marketing communications — you may withdraw that consent at any time by contacting support or updating your account notification preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

ace123 does not sell, rent, or otherwise trade your personal data to third parties for commercial gain. We may share personal data with the following categories of recipients for the purposes set out in this Policy:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, SureCash, Visa, Mastercard, and bank transfer partners require access to relevant transaction and identity data to process payments and meet their own regulatory obligations.
• Identity Verification Providers: Specialist KYC and age verification services that process identity documents on our behalf under strict data processing agreements.
• Fraud Prevention Services: Third-party providers that analyse transaction patterns and device data to detect and prevent fraud, money laundering, and bonus abuse.
• Game Technology Providers: Game studios and platform providers including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, and Spribe may receive session and game-play data necessary to deliver their services.
• Legal and Regulatory Authorities: ace123 will disclose personal data to law enforcement agencies, regulatory bodies, or courts where required by applicable law, valid legal process, or where we have a good-faith belief that disclosure is necessary to protect rights, property, or safety.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of ace123's business assets, player data may be transferred to the acquiring entity, subject to the same or equivalent privacy protections.

All third-party service providers who process personal data on behalf of ace123 are required to do so under written contractual terms that mandate adequate security standards and restrict use of data to the specified purpose only.

ace123 uses cookies and similar tracking technologies to operate the platform, analyse usage, and improve the player experience. The types of cookies we use are described below:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They manage session authentication, maintain login state, and enable core security features. They cannot be disabled without disrupting the platform's operation.
• Performance and Analytics Cookies: These cookies collect anonymous data about how players navigate the platform, which pages are visited most frequently, and where errors occur. This data is used exclusively to improve the platform experience.
• Functionality Cookies: These cookies remember your preferences such as language settings and responsible gaming tool configurations, allowing the platform to deliver a more personalised experience on repeat visits.
• Marketing Cookies: With your consent, these cookies track your interactions with ace123 promotional content to help us deliver more relevant offers and measure the effectiveness of campaigns.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent the ace123 platform from functioning correctly. Browser-level cookie controls vary by browser — consult your browser's help documentation for guidance specific to your device and browser version.

ace123 implements a layered approach to data security to protect personal information against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and ace123 servers is encrypted using TLS 1.2 or higher (256-bit SSL). This applies to all platform interactions including login, registration, deposit, and withdrawal flows.
• Encryption at Rest: Sensitive data fields including identity documents and payment details are encrypted at rest using strong symmetric encryption within our database infrastructure.
• Access Controls: Access to personal data within ace123's systems is restricted to authorised personnel on a strict need-to-know basis. Access rights are reviewed regularly and revoked promptly when no longer required.
• Payment Tokenisation: Full payment credentials are never stored on ace123 servers. Payment card data is tokenised by our payment service providers in compliance with applicable payment security standards.
• Intrusion Detection: ace123 employs automated monitoring tools to detect unusual access patterns, potential breaches, or system anomalies in real time.

Despite these measures, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to players' rights or freedoms, ace123 will notify affected players and relevant authorities within a reasonable timeframe in accordance with applicable breach notification obligations.

ace123 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal or regulatory obligations. The following general retention principles apply:

• Active Accounts: Personal data associated with active player accounts is retained for the duration of the account relationship.
• Closed Accounts: Following account closure, personal data is retained for a minimum period of five (5) years from the date of closure to satisfy anti-money laundering record-keeping requirements and to support fraud prevention, dispute resolution, and regulatory investigations.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years in accordance with financial record-keeping obligations.
• Support Communications: Customer support correspondence is retained for a minimum of two (2) years from the date of the most recent interaction, or longer if the communication relates to an ongoing dispute or investigation.
• Marketing Data: Marketing preference data and consent records are retained until you withdraw consent, plus a reasonable period thereafter to demonstrate compliance with consent requirements.

At the end of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with a specific individual.

ace123 respects your rights in relation to your personal data. Depending on your circumstances, you may have the right to:

• Access: Request a copy of the personal data ace123 holds about you, along with information about how it is being used.
• Rectification: Request correction of inaccurate or incomplete personal data. For account details such as your registered address or phone number, you may also update these directly within your account settings.
• Erasure: Request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where you object to processing and there is no overriding legitimate interest. Note that erasure requests may be subject to retention obligations described in Section 8.
• Restriction: Request that ace123 restrict processing of your personal data in certain circumstances, such as while an accuracy dispute is being resolved.
• Objection: Object to processing of your personal data where ace123 relies on legitimate interests as the legal basis, unless ace123 can demonstrate compelling legitimate grounds that override your interests.
• Data Portability: Request a copy of data you have provided to ace123 in a structured, commonly used, machine-readable format where processing is based on your consent or on a contract with you.
• Withdraw Consent: Where processing is based on your consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team at [email protected]. We will respond to all verifiable requests within 30 days. In some cases, for complex or high-volume requests, this period may be extended by a further 30 days, and we will notify you accordingly.

Please note that certain rights may be limited where fulfilling them would conflict with ace123's legal obligations, the rights of other individuals, or our legitimate interests in preventing fraud and maintaining platform security.

The ace123 platform is strictly intended for adults aged 18 years and above. ace123 does not knowingly collect personal data from individuals under 18 years of age. Age verification measures are applied at the point of registration and throughout the account lifecycle to prevent underage access.

If ace123 discovers or is notified that an account has been registered by a person under 18, that account will be immediately closed, all associated personal data will be deleted except where retention is legally required, and any funds deposited will be returned to the originating payment method. Any winnings associated with an underage account will be voided.

If you believe that a minor has registered an account on the ace123 platform, please notify us immediately at [email protected] so that we can take swift action.

The ace123 platform may contain references to or integrations with third-party services, including game content provided by studios such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, and Spribe. Interactions with these embedded third-party services may result in data being collected by those providers under their own privacy policies.

ace123 is not responsible for the privacy practices of third-party game providers or any other external service. We recommend reviewing the privacy policies of any third-party services you interact with. ace123 does not include external outbound links to third-party websites within the main ace123.club platform interface.

ace123 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform features. The date shown at the top of this document reflects the date of the most recent revision.

Where a material change is made to this Policy — for example, a new category of data collection, a new purpose for which existing data is used, or a new category of third-party recipient — ace123 will provide advance notice to registered players via a platform notification or by email to the address registered on your account. For non-material changes, such as clarifications of existing language, the updated Policy will be published at ace123.club/privacy-policy without individual notification.

Your continued use of the ace123 platform following the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you should cease using the platform and request account closure by contacting our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ace123 handles your personal data, please contact our dedicated data support team:

• Email: [email protected]
• Subject Line: Include "Privacy Request" in the subject line to ensure your message is routed to the correct team
• Response Time: We aim to acknowledge all privacy-related enquiries within 48 hours and provide a substantive response within 30 days
• Support Hours: 24 hours a day, 7 days a week, including Bangladesh public holidays

When submitting a data access, rectification, or erasure request, please include your registered username or email address and a brief description of your request so that we can process it efficiently. We may require additional verification of your identity before fulfilling certain requests to protect against fraudulent access to another person's data.