How tegem Collects, Uses, and Protects Your Personal Data

1 Introduction

tegem operates the online casino and sports betting platform accessible at https://tegem.onl. This Privacy Policy explains how tegem — acting as the data controller — collects, uses, discloses, and safeguards personal information belonging to players who register and use the platform from Bangladesh.

tegem is committed to handling personal data in a responsible, transparent, and secure manner. We adhere to internationally recognised data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability. This policy is written in English and applies to all players, regardless of the device or connection method used to access the platform.

This Privacy Policy should be read alongside tegem's Terms & Conditions and Responsible Gaming policy, both of which are available on this website. Where there is any conflict between this policy and the Terms & Conditions on a data-related matter, this Privacy Policy takes precedence.

2 Personal Data We Collect

tegem collects personal data through several channels. The categories of data collected and the circumstances under which they are gathered are described in the table below:

Data Category	Examples	When Collected
Identity Data	Full legal name, date of birth, gender, National ID number, passport number	Account registration and KYC verification
Contact Data	Email address, mobile number, residential address (city, district, division)	Account registration, support enquiries
Financial Data	bKash/Nagad/Rocket account numbers, bank account details, transaction history, deposit and withdrawal amounts in BDT	Payment processing, withdrawal verification
KYC Documents	Scanned ID documents, proof of address, selfie photographs	Identity verification process
Technical Data	IP address, device type, browser type and version, operating system, session timestamps	Automatically on site visit and login
Usage Data	Pages visited, games played, bet history, session duration, feature interactions	Automatically during platform use
Communications Data	Support ticket content, live chat transcripts, email correspondence with tegem	When you contact tegem support

tegem does not knowingly collect sensitive data categories such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where a player voluntarily discloses such information in the course of a support interaction, in which case it is handled with the utmost discretion.

3 How We Use Your Personal Data

tegem uses collected personal data for the following purposes:

• Account Management: To create, maintain, and administer your tegem player account, including processing login requests, managing account settings, and communicating account-related notifications.
• Transaction Processing: To process deposits and withdrawals in Bangladeshi Taka via bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, and BRAC Bank, and to maintain an accurate record of all financial activity on your account.
• Identity Verification (KYC): To verify the identity, age, and eligibility of players in compliance with our anti-money laundering and responsible gaming obligations. All players must be 21 years of age or older.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, and other prohibited conduct on the tegem platform.
• Customer Support: To respond to enquiries, resolve disputes, and provide assistance to players via email at [email protected].
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the design, performance, and content of the tegem platform for Bangladesh-based players.
• Responsible Gaming: To monitor gaming behaviour for signs of problem gambling and to facilitate responsible gaming tools such as deposit limits, self-exclusion, and cooling-off periods.
• Legal and Regulatory Compliance: To comply with applicable legal obligations, respond to lawful requests from regulatory and law enforcement authorities, and enforce tegem's Terms & Conditions.
• Communications: To send you material updates to these policies, notifications about your account status, and — where you have opted in — promotional communications about tegem offers and seasonal promotions.

4 Legal Basis for Processing

tegem processes personal data on the following legal bases:

• Contract Performance: Processing is necessary to perform the contract between tegem and the player (i.e., the Terms & Conditions). This covers account registration, transaction processing, and customer support.
• Legal Obligation: Processing is required to comply with applicable legal duties, including anti-money laundering obligations and age verification requirements.
• Legitimate Interests: tegem processes certain data (e.g., technical and usage data) on the basis of legitimate interests, namely maintaining the security of the platform, preventing fraud, and improving the player experience. These interests are balanced against your rights and freedoms.
• Consent: Where tegem relies on your consent — for example, for optional marketing communications — you may withdraw that consent at any time by contacting [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5 Data Sharing and Disclosure

tegem does not sell your personal data. We may share your data with third parties only in the following limited circumstances:

• Payment Processors: Information required to process financial transactions is shared with the relevant payment providers (bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, BRAC Bank). Only the minimum data necessary for the transaction is transmitted.
• Game Providers: Where games are provided by third-party studios (e.g., Pragmatic Play, Evolution Gaming, NetEnt, Spribe), limited session and account data may be shared with those providers solely to facilitate gameplay. Game providers are contractually prohibited from using this data for any other purpose.
• Identity Verification Services: KYC documents and identity data may be shared with trusted third-party verification services engaged to assist with document authentication.
• Fraud Prevention Organisations: In cases where tegem detects or suspects fraudulent activity, relevant data may be shared with third-party fraud prevention and anti-money laundering organisations.
• Legal and Regulatory Authorities: tegem will disclose personal data to law enforcement agencies, courts, or regulatory bodies where required by applicable law or in response to a valid legal order.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of tegem's business, personal data held by tegem may be transferred to the acquiring entity. Players will be notified of any such transfer via the email address registered on their account.

All third parties with whom tegem shares personal data are required to handle that data in accordance with applicable data protection law and are prohibited from using it for purposes beyond those for which it was shared.

6 Cookies and Tracking Technologies

tegem uses cookies and similar technologies (including local storage and session tokens) to operate and improve the platform. Cookies are small text files stored on your device when you visit the tegem website. They are used for the following purposes:

• Strictly Necessary Cookies: These cookies are essential for the tegem platform to function. They maintain your login session, store your authentication token, and enable core functionality. These cookies cannot be disabled.
• Analytical Cookies: These cookies help tegem understand how players interact with the platform — for example, which pages are visited most frequently and where users encounter errors. This data is used in aggregate form to improve the platform.
• Preference Cookies: These cookies remember your platform preferences (for example, your preferred language or display settings) so they are applied consistently across sessions.
• Security Cookies: These cookies support tegem's fraud detection and account security systems by helping identify unusual login patterns or suspicious activity.

You may control or disable non-essential cookies via your browser settings. Note that disabling certain cookies may impact the functionality of the tegem platform. tegem does not use advertising cookies or retargeting cookies on its platform.

7 Data Retention

tegem retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention principles:

• Account data and transaction records are retained for a minimum of five (5) years from the date of account closure, in order to meet anti-money laundering record-keeping obligations.
• KYC documents are retained for the duration of the player's account and for a minimum of five (5) years thereafter.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Technical and usage data collected via cookies or server logs is retained for a maximum of thirteen (13) months.
• Marketing preferences and consent records are retained for as long as the player holds an account and for two (2) years following account closure.

When data reaches the end of its defined retention period and there is no legal basis for further retention, it is securely deleted or irreversibly anonymised so that it can no longer be associated with any individual player.

8 Data Security

tegem implements a layered set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between the player's device and tegem's servers.
• Encryption at rest for all sensitive data held on tegem's infrastructure, including KYC documents and financial records.
• Role-based access controls that restrict access to personal data on a strict need-to-know basis within the tegem organisation.
• Regular security assessments and penetration testing conducted by qualified security professionals.
• Automated intrusion detection systems that monitor network activity for anomalous behaviour in real time.
• Multi-factor authentication required for all administrative access to tegem's internal systems.

While tegem takes all reasonable steps to protect your personal data, no internet transmission or electronic storage system is completely secure. In the event of a data breach that poses a risk to your rights and freedoms, tegem will notify affected players as soon as reasonably practicable via the email address registered on their account.

9 Your Data Rights

As a player on the tegem platform, you hold the following rights with respect to your personal data. To exercise any of these rights, contact tegem at [email protected]:

• Right of Access: You have the right to request a copy of the personal data tegem holds about you, along with information about how it is being processed.
• Right to Rectification: If any personal data tegem holds about you is inaccurate or incomplete, you have the right to request that it be corrected or supplemented.
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right is subject to tegem's legal obligations to retain certain data for specified periods (see Section 7).
• Right to Restriction: You may request that tegem restrict the processing of your personal data in certain circumstances, for example where you contest its accuracy or where you have objected to processing.
• Right to Data Portability: Where processing is based on your consent or on contract performance, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to processing carried out on the basis of tegem's legitimate interests. tegem will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

tegem will respond to data rights requests within thirty (30) days of receipt. Where a request is complex or numerous, this period may be extended by a further two months, in which case tegem will notify you of the extension and the reason for it.

10 Children's Privacy

The tegem platform is strictly intended for adults aged 21 years and above. tegem does not knowingly collect personal data from any person under the age of 21. If tegem becomes aware that a registered account belongs to a person under the age of 21, that account will be immediately suspended, all associated personal data will be deleted in accordance with our retention policy, and any balance on the account will be returned via the original deposit method.

If you are a parent or guardian and believe that a person under the age of 21 in your care has registered an account on tegem, please contact [email protected] immediately so that the account can be closed and the relevant data removed.

11 Third-Party Links

The tegem platform does not contain links to third-party websites for commercial or advertising purposes. Where references are made to third-party payment partners (bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, BRAC Bank) or game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi), these references are for informational purposes only.

tegem accepts no responsibility for the privacy practices of any third-party organisation. If you interact with a third-party service in connection with your tegem account (e.g., initiating a bKash payment), you should review that organisation's own privacy policy independently.

12 Updates to This Privacy Policy

tegem reserves the right to update or amend this Privacy Policy at any time. When material changes are made, tegem will notify registered players by sending a communication to the email address on file at least seven (7) days before the changes take effect, except where immediate changes are required for urgent legal or security reasons.

The most current version of this Privacy Policy is always accessible at https://tegem.onl/privacy-policy. The "Last Updated" date at the top of this document reflects the date on which the most recent revision was made. Continued use of the tegem platform after any revision takes effect constitutes your acceptance of the updated Privacy Policy.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or tegem's data handling practices, please contact us using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Platform: https://tegem.onl
• Support Hours: 24 hours a day, 7 days a week — Bangladesh Standard Time (BST, UTC+6)
• Response Target: We aim to respond to all privacy-related enquiries within two (2) business days.