tkjm Privacy Policy

This Privacy Policy ("Policy") is issued by tkjm ("tkjm", "we", "us", or "our") and governs the collection, use, storage, disclosure, and protection of personal data submitted to or collected by the tkjm platform, accessible at tkjm.io (the "Platform"). This Policy applies to all registered players, visitors, and prospective users of the Platform, including those accessing it from Bangladesh and any other jurisdiction.

By accessing or using the tkjm Platform, registering an account, making a deposit, or participating in any game or betting activity, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must discontinue use of the Platform immediately.

This Policy should be read in conjunction with the tkjm Terms & Conditions and the Responsible Gaming policy. Where any conflict arises between this Policy and the Terms & Conditions with respect to data handling, this Policy shall prevail.

This Policy was last reviewed and updated on 1 January 2026. The most current version of this Policy will always be available at tkjm.io/privacy-policy.

tkjm collects personal data through multiple touchpoints across the Platform lifecycle. The categories of data we collect are described below:

2.1 Registration Data

When you create a tkjm account, we collect the following mandatory information:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Residential address (including city, district, and postal code)
• Valid email address
• Mobile phone number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

In order to comply with our Know Your Customer obligations and to prevent fraud and money laundering, we may request one or more of the following documents:

• National Identity Card (NID) issued by the Bangladesh Election Commission
• Valid passport (biographical data page)
• Driving licence
• Recent utility bill or bank statement (for proof of address, dated within 90 days)
• A selfie or live photograph taken at the time of verification

2.3 Financial Data

When you make deposits or withdrawal requests, we collect transaction-related data including your payment method type (bKash, Nagad, Rocket, Upay, Visa, Mastercard), the masked account identifier or card number, transaction amounts in Bangladeshi Taka (BDT), and transaction timestamps. tkjm does not store full payment card numbers on its own servers; card data is processed by our certified payment service providers in compliance with applicable data security standards.

2.4 Technical and Usage Data

When you access the Platform, our servers automatically record certain technical information, including:

• IP address and approximate geolocation derived therefrom
• Device type, operating system, and browser type and version
• Pages visited, game sessions played, and duration of Platform sessions
• Referring URL (the website from which you navigated to tkjm)
• Clickstream data and interaction logs

2.5 Communications Data

When you contact the tkjm support team via live chat or email, we retain records of the correspondence, including your support request details, the responses provided, and any attachments you share. These records are used for quality assurance, dispute resolution, and training purposes.

2.6 Responsible Gaming Data

Where you utilise the responsible gaming tools on the Platform — including deposit limits, session reminders, cooling-off periods, and self-exclusion requests — we record and retain those preferences and requests as part of your account profile for the purpose of enforcing the restrictions you have chosen.

tkjm uses the personal data it collects exclusively for legitimate Platform-related purposes. The table below summarises the primary purposes for which each category of data is processed:

tkjm will not use your personal data for any purpose incompatible with the purposes set out above without first obtaining your explicit consent or as otherwise required by applicable law.

Where you have opted in to receive promotional communications from tkjm — including bonus offers, seasonal promotions tied to events such as BPL finals, Eid, or Pohela Boishakh, and platform updates — you may withdraw your consent at any time by contacting the support team or updating your communication preferences within your account settings. Withdrawal of consent for marketing communications will not affect the lawfulness of processing that occurred prior to withdrawal.

tkjm processes personal data on the basis of one or more of the following lawful grounds, depending on the nature of the processing activity:

• Contractual Necessity: Processing is necessary to perform the contract between you and tkjm — specifically, to operate your account, process your deposits and withdrawals, and provide access to the games and betting markets on the Platform.
• Legal Obligation: Processing is necessary to comply with applicable legal obligations, including Know Your Customer (KYC) requirements, anti-money laundering obligations, and obligations to maintain records of financial transactions.
• Legitimate Interests: Processing is necessary for the legitimate interests of tkjm, including fraud prevention, Platform security, responsible gaming monitoring, and the improvement of our services, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where no other lawful basis applies — particularly in respect of marketing communications and certain categories of cookie — tkjm will rely on your freely given, specific, informed, and unambiguous consent. You have the right to withdraw consent at any time.

tkjm does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We may share your data with the following categories of recipients solely to the extent necessary to operate the Platform and fulfil our legal obligations:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, and our card processing partners receive the financial data necessary to process your deposit and withdrawal transactions. These providers are contractually obligated to process your data only for the purpose of completing the relevant transaction and in accordance with applicable data security standards.
• Identity Verification Providers: We engage certified third-party KYC verification services to assist with identity and age verification. These providers process the identity documents you submit solely for the purpose of completing the verification check and are prohibited from retaining or further processing your documents once the check is complete.
• Game Content Providers: Third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised or pseudonymised session data necessary to deliver their games and detect any game-level technical errors. These providers do not receive your full registration profile.
• Legal and Regulatory Authorities: tkjm may disclose your personal data to law enforcement agencies, courts, or regulatory bodies where required to do so by applicable law, court order, or where we believe disclosure is necessary to protect the rights, property, or safety of tkjm, our players, or the public.
• Professional Advisors: Our legal advisors, auditors, and accountants may access your data on a strictly need-to-know basis subject to binding confidentiality obligations.

tkjm 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 retention periods apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with tkjm's internal data destruction procedures. Where data has been anonymised such that it can no longer be attributed to any identifiable individual, it may be retained for statistical or analytical purposes without further restriction.

tkjm takes the security of your personal data seriously. We implement a comprehensive set of technical and organisational security measures designed to protect your data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the tkjm Platform is encrypted using industry-standard 256-bit SSL/TLS protocols. This ensures that your registration data, login credentials, and financial information cannot be intercepted in transit.
• Encrypted Data Storage: Sensitive data fields — including passwords, identity document references, and payment method identifiers — are stored in encrypted form using strong cryptographic hashing and encryption algorithms. Passwords are hashed using a one-way algorithm and are never stored in plain text.
• Access Controls: Access to personal data within tkjm's internal systems is strictly controlled on a role-based, need-to-know basis. All internal access is logged and audited. Staff with access to personal data are subject to binding confidentiality obligations and receive regular data protection training.
• Intrusion Detection and Prevention: tkjm operates real-time intrusion detection systems that monitor network traffic for anomalous patterns indicative of attempted unauthorised access. Automated alerts and response procedures are in place to address potential security incidents promptly.
• Regular Security Audits: The Platform undergoes periodic security assessments and penetration testing by independent security professionals to identify and remediate vulnerabilities proactively.
• Two-Factor Authentication: tkjm supports optional two-factor authentication (2FA) for account login. Players are strongly encouraged to enable 2FA to add an additional layer of protection to their accounts.

While tkjm takes every reasonable precaution to protect your personal data, no system of data transmission or storage can be guaranteed to be completely secure. In the event of a data security incident that is likely to result in a high risk to your rights, tkjm will notify affected players as soon as reasonably practicable in accordance with applicable notification obligations.

tkjm uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session state, and gather anonymised analytics data. The categories of cookies we use are as follows:

• Strictly Necessary Cookies: These cookies are essential to the operation of the Platform and cannot be disabled. They include session cookies that maintain your login state, security tokens that protect against cross-site request forgery, and cookies that remember your responsible gaming preferences during an active session.
• Performance and Analytics Cookies: These cookies collect anonymised information about how visitors use the Platform — including which pages are visited most frequently, how long sessions last, and whether any technical errors occurred. This data is used exclusively to improve Platform performance and user experience. No personally identifiable information is collected by these cookies.
• Functional Cookies: These cookies remember your preferences and settings — such as your preferred display language or notification settings — to provide a more personalised Platform experience across sessions.
• Targeting and Preference Cookies: Where you have consented, these cookies record your game preferences and Platform interaction patterns to allow tkjm to surface more relevant game recommendations and promotional content tailored to your interests. You may withdraw your consent for this category of cookies at any time.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the Platform and may prevent you from accessing certain features, including the ability to log in to your account.

tkjm does not use cookies or tracking technologies to build profiles of you for sale to third-party advertisers, and we do not permit third-party advertising networks to place tracking cookies on the Platform.

As a player on the tkjm Platform, you hold the following rights with respect to your personal data. tkjm is committed to facilitating the exercise of these rights promptly and without undue burden:

• Right of Access: You have the right to request a copy of the personal data that tkjm holds about you, together with information about how that data is being used. Requests will be responded to within 30 days of receipt.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain registration details directly from within your account settings, or contact the support team for assistance with data that cannot be self-corrected.
• Right to Erasure: You have the right to request the deletion of your personal data in certain circumstances — for example, where the data is no longer necessary for the purposes for which it was collected, or where you withdraw consent and no other lawful basis for processing applies. Please note that we may be required to retain certain data for legal compliance purposes (see Section 6) even following a valid erasure request.
• Right to Restriction: You have the right to request that tkjm restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of our legitimate interests.
• Right to Data Portability: Where processing is based on your consent or on a contract with you, and processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted directly to another controller where technically feasible.
• Right to Object: You have the right to object at any time to the processing of your personal data for direct marketing purposes. You also have the right to object to processing based on our legitimate interests, on grounds relating to your particular situation.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, please contact the tkjm data protection team by email at [email protected] with the subject line "Data Rights Request", including your full name, registered email address, and a description of the right you wish to exercise. tkjm will respond to all data rights requests within 30 calendar days. In complex cases this period may be extended by a further 60 days, in which case tkjm will notify you of the extension within the initial 30-day period.

The tkjm Platform is strictly intended for adults aged 21 years or older. tkjm does not knowingly collect, process, or retain personal data from any individual under the age of 21. If we become aware that a person under the age of 21 has registered an account or submitted personal data to the Platform, we will take immediate steps to close the account, delete the associated data, and reverse any financial transactions that may have occurred.

Parents and guardians who believe that a minor in their care may have registered an account on the tkjm Platform are urged to contact the support team at [email protected] without delay. tkjm will investigate and resolve such reports as a matter of priority.

The tkjm Platform may contain references to third-party services, including game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, as well as payment partners such as bKash, Nagad, Rocket, and Upay. When you interact with these third-party services — for example, when a game launches within a third-party game engine, or when you are redirected to a payment provider's interface to complete a transaction — you are subject to the privacy policy and terms of service of that third party.

tkjm is not responsible for the privacy practices, data handling procedures, or content of any third-party services. We encourage you to review the privacy policies of any third-party service with which you interact through the Platform. The inclusion of a third-party provider on the tkjm Platform does not constitute an endorsement of that provider's privacy practices.

tkjm reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing activities, applicable law, or best practice. Where any material change is made to this Policy — including changes to the categories of data we collect, the purposes for which we process it, or the third parties with whom we share it — tkjm will notify registered players via the email address associated with their account, or by means of a prominent notice on the Platform, with a minimum of 7 days' advance notice before the updated Policy takes effect.

Your continued use of the tkjm Platform after the effective date of any revised Policy constitutes your acceptance of the changes. If you do not agree with any changes, you must close your account and discontinue use of the Platform before the revised Policy takes effect.

The effective date at the top of this Policy will always reflect the date of the most recent update. We encourage you to review this Policy periodically so that you remain informed about how tkjm protects your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which tkjm processes your personal data, please contact us through any of the following channels:

• Live Chat: Available 24 hours a day, 7 days a week through the tkjm Platform. Our support team can handle general privacy enquiries and direct data rights requests to the appropriate team.
• Email: [email protected] — for all data rights requests, please use the subject line "Data Rights Request". For formal privacy complaints, please use the subject line "Privacy Complaint". We aim to acknowledge all emails within 24 hours (Bangladesh Standard Time, UTC+6) and to provide a substantive response within 5 business days.

For formal privacy complaints that cannot be resolved through the tkjm support team, you may escalate your complaint to the relevant data protection authority in your jurisdiction.