Privacy Policy — vlp2 Platform

1 Introduction

vlp2 ("we", "us", "our") is Bangladesh's trusted online cricket betting and casino platform, serving Members across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar, and all regions of Bangladesh. We are committed to protecting the privacy and personal data of every individual who interacts with the vlp2 platform, whether as a registered Member, a prospective user, or a visitor to our website.

This Privacy Policy ("Policy") sets out in formal, transparent terms: the categories of personal data we collect; the purposes for which that data is processed; the legal bases on which we rely to process it; the parties with whom data may be shared; the security measures we have in place to protect it; and the rights available to you as a data subject. We have drafted this Policy to ensure that our data practices are clear and understandable to all Members, regardless of their level of technical expertise.

vlp2 operates this Policy in good faith and in accordance with the principles of data minimisation, purpose limitation, accuracy, storage limitation, integrity, confidentiality, and accountability. We review and update this Policy periodically to reflect changes in our services, technology, and applicable regulatory expectations. The effective date of the current version is stated at the top of this document.

If you have any questions about this Policy or about how vlp2 handles your personal data, please contact our dedicated support team via live chat or email. Contact details are provided in Section 14 of this Policy.

2 Personal Data We Collect

vlp2 collects personal data through several channels: directly from you during registration, KYC, and your ongoing use of the platform; automatically through your device and browser when you access our website; and, in limited circumstances, from trusted third-party service providers such as identity verification agencies and payment processors.

2.1 Registration Data

When you create a vlp2 Account, we collect the following information:

• Full legal name (as it appears on your government-issued identity document);
• Date of birth (to verify that you meet the 21+ age requirement);
• Country of residence (Bangladesh);
• Registered Bangladesh mobile number;
• Chosen username and a hashed (non-reversible) version of your password;
• Email address (where provided).

2.2 KYC & Identity Verification Data

Before processing your first withdrawal, vlp2 requires completion of our Know Your Customer (KYC) process. This involves the collection of:

• A copy of a valid government-issued photo identity document — National Identity Card (NID), passport, or driving licence;
• A selfie or facial verification image (where applicable) to match against the submitted identity document;
• Proof of your registered Bangladesh mobile banking account (bKash, Nagad, Rocket, or Upay) — typically a screenshot or statement confirming account ownership;
• Source-of-funds documentation where requested by our compliance team for higher-value transactions.

2.3 Financial Transaction Data

In order to process deposits and withdrawals, we collect and retain records of all financial transactions conducted through your vlp2 Account. This includes:

• Deposit amounts, timestamps, and payment method identifiers (bKash wallet number, Nagad number, bank account reference);
• Withdrawal requests, amounts, processing status, and destination payment account references;
• Bonus credits, wagering records, and any adjustments made to your BDT Wallet balance;
• Win and loss records associated with your betting and gaming activity on the platform.

vlp2 does not collect or store full card numbers, CVV codes, or full bank account numbers. Payment identifiers are limited to the mobile wallet number or bank reference required to route a transaction to the correct recipient.

2.4 Technical & Device Data

When you access the vlp2 platform, our servers and analytics systems automatically collect certain technical data, including:

• IP address and approximate geolocation (country and city level);
• Device type, operating system, and browser version;
• Session start and end times, pages visited, and features interacted with;
• Referral source (the URL from which you navigated to vlp2, if applicable).

2.5 Communications Data

If you contact vlp2 via live chat, email, or any other support channel, we retain a record of the communication — including the content of messages, timestamps, and the support agent who handled the interaction. This data is used to resolve your query, improve our support quality, and maintain an accurate history of your interactions with the platform.

2.6 Responsible Gaming Data

Where you interact with our Responsible Gaming tools — including deposit limit settings, session time reminders, cool-off requests, and self-exclusion applications — we retain records of these interactions. This data is used to enforce the restrictions you have selected and to ensure that our responsible gaming obligations are upheld consistently.

3 How We Use Your Personal Data

vlp2 uses the personal data we collect for the following specific purposes. We do not use your data for any purpose that is incompatible with those listed below without obtaining your additional consent.

• Account creation and management: To create, maintain, and administer your vlp2 Account, including processing login sessions, updating account details, and providing access to platform features;
• Age and identity verification: To verify that you meet the minimum age requirement of 21 years and that your identity is genuine, in accordance with our responsible gaming and compliance obligations;
• Payment processing: To process deposits, credit winnings to your BDT Wallet, and execute withdrawal requests to your registered bKash, Nagad, Rocket, Upay, or bank account;
• Fraud detection and security: To identify, investigate, and prevent fraudulent activity, money laundering, multi-accounting, unauthorised access, and other security threats to the platform and its Members;
• Customer support: To respond to your enquiries, resolve disputes, process complaints, and deliver the support service you have requested;
• Platform improvement: To analyse aggregated, anonymised usage patterns and technical data in order to improve the performance, reliability, and user experience of the vlp2 platform;
• Responsible Gaming compliance: To enforce deposit limits, session time reminders, cool-off periods, and self-exclusion settings you have activated, and to monitor for indicators of problem gambling behaviour;
• Legal and regulatory compliance: To meet any legal, regulatory, or law enforcement obligations that apply to vlp2 as an online platform serving users in Bangladesh, including the retention of transaction records for audit purposes;
• Promotional communications: To send you information about bonuses, promotions, and platform updates — subject to your communication preferences as described in Section 12 of this Policy.

4 Legal Basis for Processing

vlp2 processes your personal data on one or more of the following legal bases, depending on the nature of the processing activity:

• Contractual necessity: Processing that is necessary to perform the contract between you and vlp2 — including account registration, payment processing, bet settlement, and customer support — is undertaken on the basis of contractual necessity;
• Legitimate interests: Processing undertaken for fraud prevention, security monitoring, platform analytics, and customer service quality improvement is based on vlp2's legitimate interest in operating a secure, fair, and well-functioning platform, provided that this interest is not overridden by your fundamental rights and interests;
• Legal obligation: Processing required by applicable law — including the retention of financial records, KYC documentation, and compliance with any lawful requests from competent authorities — is undertaken on the basis of legal obligation;
• Consent: Where vlp2 sends you direct marketing communications or uses non-essential cookies, this is done on the basis of your consent, which you may withdraw at any time as described in Sections 6 and 12 of this Policy.

5 Data Sharing & Disclosure

vlp2 does not sell, rent, or trade your personal data to any third party. We may share your personal data only in the limited circumstances described below, and only with parties who are contractually bound to handle it securely and in accordance with this Policy.

5.1 Service Providers

vlp2 engages trusted third-party service providers who process personal data on our behalf in order to deliver specific platform functions. These providers include:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, and BRAC Bank — to process deposits and withdrawals;
• Identity verification providers: Third-party KYC and age verification services that validate identity documents submitted during the verification process;
• Cloud hosting and infrastructure providers: Data centre and cloud infrastructure operators who provide the servers on which vlp2's platform and data are hosted;
• Game providers: Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi — who may receive a session token or anonymised player ID to facilitate game session delivery. Full personal data is not transmitted to game providers.

All service providers are required to process personal data only for the specific purpose for which it was shared and in accordance with vlp2's data protection standards.

5.2 Legal Disclosures

vlp2 may disclose your personal data to law enforcement agencies, regulatory bodies, or other competent authorities where we are required to do so by applicable law, court order, or other binding legal process. In such cases, vlp2 will disclose only the minimum data necessary to satisfy the legal requirement and will, where legally permissible, notify the affected Member of the disclosure.

5.3 Business Transfers

In the event that vlp2's business or a material part of it is acquired, merged, or transferred to a third party, your personal data may form part of the assets transferred. In such circumstances, vlp2 will take reasonable steps to ensure that your data continues to be handled in accordance with the terms of this Policy and will notify affected Members of any material change to data controller identity.

6 Cookies & Tracking Technologies

The vlp2 website uses cookies and similar tracking technologies to enhance your browsing experience, maintain your login session, and gather anonymised analytics data about how the platform is used. This section explains the categories of cookies we use and how you can manage your cookie preferences.

6.1 Essential Cookies

Essential cookies are strictly necessary for the vlp2 platform to function. They maintain your login session across page loads, remember your language and currency preferences, and enable core security features such as CSRF protection. Essential cookies cannot be disabled without significantly impairing your ability to use the platform.

6.2 Analytics Cookies

With your consent, vlp2 uses analytics cookies to collect anonymised data about how Members navigate and interact with the platform. This data helps us understand which features are most used, identify technical issues, and prioritise platform improvements. Analytics cookies do not collect personally identifiable information.

6.3 Managing Cookies

You may manage or withdraw consent for non-essential cookies at any time through your browser settings. Most modern browsers provide the option to block, delete, or restrict cookies on a per-site basis. Please note that disabling certain cookies may affect the functionality of the vlp2 platform. vlp2 does not use third-party advertising or retargeting cookies.

7 Data Retention

vlp2 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by our legal and regulatory obligations. The following retention periods apply to the principal categories of personal data we process:

Upon expiry of the applicable retention period, personal data is securely deleted from active systems and backups in accordance with our data disposal procedures. Data that has been fully anonymised — such that it can no longer be linked to an identifiable individual — may be retained indefinitely for statistical analysis purposes.

8 Data Security

vlp2 takes the security of your personal data seriously and has implemented a comprehensive set of technical and organisational measures to protect it against unauthorised access, accidental loss, disclosure, alteration, or destruction.

• SSL/TLS encryption: All data in transit between your device and vlp2's servers is encrypted using industry-standard SSL/TLS protocols. Our platform enforces HTTPS across all pages and API endpoints;
• Password hashing: Member passwords are stored as one-way cryptographic hashes. Even authorised vlp2 personnel cannot retrieve your original password from our systems;
• Two-factor authentication: Members may enable OTP-based two-factor authentication for their account, delivering a one-time verification code to their registered Bangladesh mobile number at each new login;
• Access controls: Access to personal data within vlp2's internal systems is restricted on a need-to-know basis. All staff with data access are subject to confidentiality agreements and regular security training;
• Infrastructure security: vlp2's platform is hosted on secured cloud infrastructure with firewall protection, intrusion detection, and regular security audits;
• Incident response: vlp2 maintains a data breach response procedure. In the event of a breach that poses a risk to Member data, affected Members will be notified without undue delay, and appropriate steps will be taken to contain and remediate the incident.

While vlp2 takes all reasonable measures to protect your data, no online platform can guarantee absolute security against all possible threats. We encourage Members to take personal responsibility for their account security by using a strong, unique password and enabling two-factor authentication.

9 Children & Minors

vlp2 takes the prevention of underage gambling extremely seriously. As part of our registration and KYC processes, we actively verify the age of all Members. Where we have reasonable grounds to believe that a Member is under the age of 21, their Account will be immediately suspended pending age verification, and any associated funds will be held while the matter is investigated in accordance with our Terms and Conditions.

Parents and guardians are encouraged to use parental control software and to educate minors about the risks associated with online gambling platforms. If you believe that a minor has registered an Account on vlp2, please contact our support team immediately at [email protected] so that we can investigate and take appropriate action without delay.

Any personal data collected from an individual who is later determined to have been under the age of 21 at the time of registration will be deleted from our systems as promptly as is operationally practicable, subject to any legal retention obligations that may require us to retain records of the incident for compliance purposes.

10 Third-Party Services & Links

The vlp2 platform integrates with a number of third-party services to deliver its full range of features. These include game providers (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Ezugi), payment processors (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank), and identity verification providers. While vlp2 takes care to work only with reputable and vetted partners, we are not responsible for the privacy practices of these third-party services once data is processed within their own systems.

Each third-party service provider operates under its own privacy policy and data protection practices. vlp2 enters into data processing agreements with all service providers who handle Member personal data on our behalf, requiring them to process that data only for the specified purpose and to maintain appropriate security standards. However, once you navigate away from the vlp2 platform to a third-party website or service, your interactions with that service are governed by its own privacy policy, not this one.

vlp2 does not embed third-party advertising networks, social media tracking pixels, or retargeting scripts on our platform. We do not share Member browsing behaviour with external advertising platforms.

11 Exercising Your Data Rights

As described in the Member Rights section above, you hold a number of rights with respect to the personal data vlp2 processes on your behalf. This section sets out the practical process for exercising those rights.

11.1 How to Submit a Request

To exercise any of your data rights — including access, rectification, erasure, restriction, portability, or objection — please contact our support team through one of the following channels:

• Live Chat: Available 24/7 via the live chat feature on the vlp2 platform. Please state clearly that you are submitting a data subject rights request and specify the right you wish to exercise;
• Email: Send your request to [email protected] with the subject line "Data Rights Request". Include your registered username, the right you are invoking, and sufficient detail for us to identify and locate the relevant data.

11.2 Verification

To protect your privacy and prevent unauthorised disclosure of your personal data to a third party, vlp2 will require you to verify your identity before processing any data rights request. Verification may involve confirming your registered mobile number, providing the last four digits of a transaction reference, or completing a one-time authentication step. This verification step is a necessary safeguard and not an obstacle to exercising your rights.

11.3 Response Timeframes

vlp2 will acknowledge receipt of your data rights request within 2 business days. We aim to resolve all data rights requests within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it before the initial 30-day period expires.

11.4 Limitations on the Right to Erasure

While vlp2 respects and upholds the right to erasure, this right is not absolute. We may be unable to delete certain categories of personal data where retention is required by law — for example, financial transaction records that must be retained for audit and anti-money-laundering compliance, or self-exclusion records that must be retained permanently to prevent a previously self-excluded Member from re-registering. In such cases, we will inform you of the specific legal basis for retaining the data and will delete all other personal data that is not subject to a legal retention obligation.

12 Marketing Communications

vlp2 may, with your consent, send you promotional communications relating to bonuses, seasonal offers (such as Eid, Pohela Boishakh, or BPL/IPL season promotions), new game launches, and other platform updates. These communications may be delivered via SMS to your registered Bangladesh mobile number or via push notification where you have enabled this feature on a supported device.

Your consent to receive marketing communications is separate from your consent to this Privacy Policy and is collected at the point of registration or subsequently through your Account settings. You may withdraw your consent to receive marketing communications at any time by:

• Updating your notification preferences in your Account settings;
• Replying "STOP" to any SMS communication sent by vlp2;
• Contacting our support team via live chat or at [email protected] and requesting removal from our marketing list.

Withdrawal of consent for marketing communications will not affect the lawfulness of any processing that was carried out on the basis of your consent prior to its withdrawal. Transactional communications — such as deposit confirmations, withdrawal notifications, and account security alerts — are not marketing communications and will continue to be sent regardless of your marketing preferences, as they are necessary for the delivery of the service.

13 Amendments to This Privacy Policy

vlp2 reserves the right to amend, update, or replace this Privacy Policy at any time. Amendments may be made to reflect changes in our data processing practices, the introduction of new platform features, updates to applicable legal requirements, or the recommendations of our data protection advisors.

Where a material change is made to this Policy — one that alters the purposes for which we process your data, the categories of data we collect, or the parties with whom we share it — vlp2 will provide advance notice to registered Members via a notification on the platform login page and, where appropriate, via SMS to your registered mobile number. The notice will describe the nature of the change and the date on which the updated Policy takes effect.

For non-material changes — such as corrections of typographical errors, clarifications of existing language, or updates to contact details — vlp2 may update the Policy without individual notice. The "Last Updated" date at the top of this document will always reflect the date of the most recent version. We encourage Members to review this Policy periodically to stay informed of how we handle their personal data.

Your continued use of the vlp2 platform following the effective date of any updated Privacy Policy constitutes your acceptance of the amended terms. If you do not agree with any amendment to this Policy, you should discontinue use of the platform and contact our support team to discuss the closure of your Account.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to vlp2's data handling practices in general, please do not hesitate to contact our dedicated privacy support team through the channels listed below. We are committed to responding to all privacy-related enquiries promptly, professionally, and in English.

• Email: [email protected] — please use the subject line "Privacy Enquiry" for the fastest routing to the appropriate team;
• Live Chat: Available 24/7 on the vlp2 platform — our support agents are trained to handle data subject rights requests and privacy queries;
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6);
• Languages: English and Bengali support agents are available.