cirkex Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how cirkex ("cirkex", "we", "our", "us") collects, uses, stores, shares, and protects the personal data of individuals ("you", "Player", "User") who access and use the cirkex platform available at https://cirkex.vip, including all associated services such as sports betting, live casino, slots, bingo, and crash games.

cirkex is committed to handling your personal data with transparency, care, and respect. We take our data protection responsibilities seriously and have implemented technical and organisational measures that reflect the sensitivity of the information entrusted to us by players across Bangladesh and beyond.

This Policy was last updated and became effective on 1 January 2026. It should be read alongside the cirkex Terms and Conditions and the Responsible Gaming Policy, which together form the full framework governing your relationship with cirkex.

2 Data Controller

cirkex acts as the data controller in respect of all personal data collected through the platform. As data controller, cirkex determines the purposes for which personal data is processed and the means by which that processing takes place. All data rights requests, privacy enquiries, and data protection concerns should be directed to the cirkex support team at the contact details provided in Section 15 of this Policy.

Where cirkex engages third-party service providers to process personal data on its behalf — for example, payment processors or identity verification providers — those parties act as data processors under instruction from cirkex and are bound by appropriate contractual data protection obligations.

3 Data We Collect

cirkex collects the following categories of personal data from players:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (used for age verification — players must be 18 or older)
• Residential address, city, and postal code
• Email address
• Mobile phone number registered in Bangladesh

3.2 Verification and Compliance Data

• Copies of government-issued photo identification (National ID card, passport, or driving licence)
• Proof of address documents (utility bills, bank statements, or official correspondence)
• Payment method verification screenshots (e.g., bKash or Nagad account details confirming ownership)
• Source of funds information where required by compliance procedures

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references
• Account balance history
• Bonus and promotion usage records
• Payment method identifiers (mobile wallet numbers, masked card numbers) — full card numbers are never stored by cirkex

3.4 Gaming and Betting Activity Data

• Bet placement records, including stake amounts, odds, game types, and outcomes
• Session duration, login timestamps, and active game logs
• Responsible gaming settings and any self-exclusion or limit requests made on your account

3.5 Technical and Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type
• Cookies and similar tracking technologies (see Section 11)
• Platform interaction logs, including pages visited and features used

3.6 Communications Data

• Records of correspondence between you and the cirkex support team, including live chat transcripts and email exchanges
• Feedback, complaints, and dispute records

4 How We Collect Your Data

cirkex collects personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing identity verification, making a deposit or withdrawal, or contacting support.
• Automated collection: Technical data collected automatically when you access the platform, including cookies, server logs, and analytics tools.
• Third-party providers: Identity verification agencies, payment processors (bKash, Nagad, Rocket, Visa), and fraud detection services may share data with cirkex as part of the services they provide to us.
• Publicly available sources: In limited circumstances, cirkex may verify information against publicly available records as part of its compliance and fraud prevention obligations.

5 How We Use Your Data

cirkex uses your personal data for the following purposes:

6 Legal Basis for Processing

cirkex relies on the following legal bases when processing your personal data:

• Contractual necessity: Processing required to perform the contract between you and cirkex — for example, account creation, payment processing, and bet settlement.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering requirements, age verification obligations, and responses to lawful authority requests.
• Legitimate interests: Processing carried out for cirkex's legitimate business interests where those interests are not overridden by your data protection rights — including fraud prevention, platform security, and service improvement.
• Consent: Processing based on your explicit, freely given consent — specifically in relation to optional marketing communications. You may withdraw consent at any time by contacting support or using the opt-out mechanism in any marketing email.

7 Data Sharing with Third Parties

cirkex does not sell or rent your personal data to third parties. We may share your data with the following categories of recipients only where necessary and subject to appropriate safeguards:

• Payment processors: bKash, Nagad, Rocket, Upay, and Visa — to process deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and comply with our obligations.
• Game content providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other providers whose games are hosted on the cirkex platform may receive limited technical session data required to run their games.
• Fraud prevention and security services: Third-party services that assist with detecting fraudulent activity and protecting the integrity of the platform.
• IT infrastructure and cloud providers: Hosting, storage, and platform infrastructure providers under strict data processing agreements.
• Legal and regulatory authorities: Where required by law, court order, or a lawful request from a competent authority, cirkex may disclose player data without prior notice.
• Professional advisors: Lawyers, auditors, and accountants where access to personal data is necessary in the course of the professional services they provide to cirkex, under obligations of confidentiality.

8 International Data Transfers

The cirkex platform serves players primarily in Bangladesh and processes the majority of data within the region. However, some of our third-party service providers — including game content providers and infrastructure partners — may be located outside Bangladesh. Where personal data is transferred internationally, cirkex ensures that appropriate safeguards are in place, such as contractual data protection clauses with the receiving party, to ensure your data is afforded a level of protection consistent with this Policy.

By using the cirkex platform, you acknowledge that your personal data may be transferred to and processed in countries outside your country of residence. cirkex takes reasonable steps to ensure that any such transfers are conducted lawfully and securely.

9 Data Retention

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

• Active account data: Retained for the lifetime of your cirkex account and for a period of at least five years after account closure, to meet legal and compliance obligations.
• Transaction records: Financial records including deposit, withdrawal, and bet history are retained for a minimum of five years from the date of the transaction in line with anti-money laundering requirements.
• Identity verification documents: Retained for a minimum of five years after account closure or the date the document was submitted, whichever is later.
• Support communications: Correspondence and chat logs retained for a minimum of two years from the date of the last communication in a given case.
• Marketing consent records: Retained for as long as you remain opted in to marketing communications plus a reasonable period thereafter to evidence the consent given.

When personal data is no longer required, cirkex will securely delete or irreversibly anonymise it in a manner that prevents recovery or identification.

10 Security Measures

cirkex employs a range of technical and organisational security measures to protect your personal data against unauthorised access, loss, misuse, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the cirkex platform
• Encrypted storage of sensitive personal data and financial records at rest
• Multi-factor authentication options for player accounts
• Continuous automated monitoring for suspicious login attempts and anomalous account activity
• Strict internal access controls limiting data access to authorised personnel only
• Regular security assessments and vulnerability testing of platform infrastructure
• Incident response procedures to detect, contain, and report data security incidents

While cirkex takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You also play a role in keeping your account secure by maintaining a strong, unique password and not sharing your login credentials with any third party. If you believe your cirkex account has been compromised, contact support immediately at [email protected].

11 Cookies & Tracking Technologies

cirkex uses cookies and similar technologies on the platform. A cookie is a small text file placed on your device when you visit a website. cirkex uses the following categories of cookies:

• Strictly necessary cookies: Required for the platform to function correctly — for example, maintaining your login session, remembering your language preference, and securing your account. These cannot be disabled.
• Functional cookies: Used to remember your preferences and settings across visits, such as your display options and responsible gaming settings.
• Analytics cookies: Used to collect aggregated, anonymised information about how players use the platform, helping cirkex understand which features are most useful and where improvements can be made.
• Fraud and security cookies: Used by security and fraud detection systems to identify suspicious activity and protect the integrity of player accounts.

Most web browsers allow you to control cookie settings through the browser's preferences menu. Blocking strictly necessary cookies may impair the functionality of the cirkex platform. For all other cookie types, you may adjust your preferences without affecting core platform access.

12 Your Data Rights

As a cirkex player, you have the following rights in relation to your personal data. To exercise any of these rights, please contact the cirkex support team at [email protected]. cirkex will respond to all verified data rights requests within a reasonable period.

• Right of access: You have the right to request a copy of the personal data cirkex holds about you, along with information about how that data is being used.
• Right to rectification: If any of the personal data cirkex holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to erasure: In certain circumstances, you have the right to request that cirkex delete your personal data. This right is subject to limitations where cirkex is required to retain data to comply with legal obligations or to defend against legal claims.
• Right to restriction: You have the right to request that cirkex restricts its processing of your data in certain circumstances — for example, while a rectification request is being assessed.
• Right to data portability: Where processing is based on your consent or on a contract, you have the right to receive a copy of your personal data in a structured, machine-readable format.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling. You also have the right to withdraw consent for marketing communications at any time.

cirkex will not discriminate against players for exercising their data rights. Some requests may require identity verification before cirkex can fulfil them, to ensure that data is not disclosed to an unauthorised party.

13 Minors and Age Restriction

The cirkex platform is strictly for adults aged 18 years and above. cirkex does not knowingly collect personal data from any person under the age of 18. Age verification is a mandatory step in the registration and KYC process, and cirkex reserves the right to carry out age verification checks at any stage of the account lifecycle.

If cirkex becomes aware that personal data has been collected from a person under the age of 18, the relevant account will be closed immediately, all associated balances and bonuses will be voided, and the personal data will be securely deleted from our systems in line with applicable legal requirements.

If you are a parent or guardian and believe that a minor in your care has registered on the cirkex platform, please contact us immediately at [email protected] so that we can take appropriate action without delay.

14 Changes to This Policy

cirkex reserves the right to update or amend this Privacy Policy at any time. When material changes are made, cirkex will notify registered players via email to the address associated with their account and will post a prominent notice on the platform. The effective date at the top of this document will be updated to reflect the date of the most recent revision.

Your continued use of the cirkex platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should stop using the platform and contact support to request account closure and deletion of your personal data where applicable.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way cirkex handles your personal data, please contact our support team using the details below. All privacy-related enquiries are treated as confidential and handled by our dedicated data protection team.

For requests specifically relating to data access, rectification, erasure, or any other exercise of your data rights under Section 12, please include your registered email address and a description of your request. cirkex may ask you to verify your identity before processing any data rights request to ensure that information is not disclosed to an unauthorised party.