Your Privacy Matters
at 21vip

This Privacy Policy ("Policy") describes how 21vip ("we", "us", "our", "the Company") collects, processes, stores, and protects personal data provided by users ("you", "your") in connection with your use of the 21vip online casino and sports betting platform available at https://21vip.io ("Platform"). This Policy forms part of the 21vip Terms & Conditions and should be read together with that document.

By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and you consent to the collection and processing of your personal data as described herein. If you disagree with any part of this Policy, you must discontinue use of the Platform and contact us to close your account.

21vip is committed to handling all personal data with integrity, transparency, and in accordance with internationally recognised privacy principles. We process only the data that is strictly necessary for the purposes described below, and we never sell personal data to third parties for commercial marketing purposes.

1. Introduction

21vip operates as an internationally licensed offshore online gaming and sports betting platform serving players in Bangladesh and other eligible jurisdictions. As a platform that processes financial transactions, verifies identity documents, and monitors gameplay, we necessarily collect a range of personal data about our users. This Policy explains that data lifecycle in full — from the moment you first visit the Platform through to the deletion of your records following account closure.

We have appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and for handling data subject requests. Contact details for the DPO are provided in Section 15 of this Policy. Where any provision of this Policy conflicts with applicable data protection law, the applicable law takes precedence.

2. Data We Collect

The categories of personal data that 21vip may collect are set out in the table below. Not all data types apply to every user — the data collected depends on your activity on the Platform and the features you choose to use.

We do not collect any special category data (such as health data, racial or ethnic origin, political opinions, religious beliefs, or biometric data) unless this is strictly required for identity verification purposes and you have given explicit prior consent.

3. How We Collect Your Data

3.1 Data You Provide Directly

The majority of personal data 21vip holds about you is information you provide voluntarily when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions. You are responsible for ensuring the accuracy and completeness of all data you submit to us.

3.2 Automatically Collected Data

When you visit the 21vip Platform, our servers automatically record certain technical information about your device and session. This includes your IP address, browser fingerprint, device identifiers, referring URL, pages visited, and time stamps. This data is collected using server logs, cookies, and pixel tags as described in Section 9 of this Policy.

3.3 Data From Third Parties

21vip may receive personal data about you from third-party sources in the following circumstances: identity verification bureaux used to cross-check the documents you submit during KYC; payment processors including bKash, Nagad, Rocket, Upay, Visa, and Mastercard confirming the status of transactions; fraud prevention and anti-money laundering screening services; and game studio providers reporting game session activity relating to your account.

4. Why We Use Your Data

21vip uses personal data for clearly defined purposes. We do not use your data for any purpose that is incompatible with the reasons for which it was originally collected. The primary purposes for which we process personal data are as follows:

• Account Management: To create, maintain, and administer your 21vip account, including verifying your identity, processing your login credentials, and keeping your account secure.
• Transaction Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain complete and accurate financial records of all transactions.
• Regulatory Compliance: To comply with our obligations under applicable anti-money laundering (AML) regulations, know-your-customer (KYC) requirements, and international sanctions screening obligations.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, collusion, and other prohibited conduct as defined in the 21vip Terms & Conditions.
• Customer Support: To respond to your queries, resolve complaints, and provide technical assistance when you contact our support team.
• Platform Improvement: To analyse usage patterns and gameplay data in order to improve the Platform's performance, game offering, and user experience for all players.
• Responsible Gaming: To administer self-exclusion requests, deposit limits, cooling-off periods, and other responsible gaming tools, and to identify and contact players who may be showing signs of problem gambling behaviour.
• Marketing Communications: To send you promotional offers, bonus notifications, and seasonal campaign communications by email or SMS, where you have given your prior consent to receive such communications. You may withdraw this consent at any time.
• Legal Proceedings: To exercise or defend legal rights and claims, and to comply with court orders, regulatory instructions, or law enforcement requests.

5. Legal Basis for Processing

Every processing activity carried out by 21vip rests on one of the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 21vip — i.e., to operate your account, process bets and payments, and provide the services you have signed up for.
• Legal Obligation: Processing required to comply with applicable law, including AML regulations, KYC requirements, sanctions screening, and financial record-keeping obligations.
• Legitimate Interests: Processing carried out in pursuit of 21vip's legitimate business interests where those interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security, IT systems management, and internal analytics.
• Consent: Processing carried out with your explicit prior consent, including the sending of direct marketing communications and, where applicable, the collection of special category data for enhanced verification purposes. Consent may be withdrawn at any time by contacting us at [email protected].

6. Data Sharing & Disclosure

21vip does not sell, rent, or trade personal data with third parties for their own commercial purposes. We share personal data only in the circumstances described below, and only to the extent strictly necessary for the stated purpose:

6.1 Service Providers

We engage carefully selected third-party service providers who process personal data on our behalf under written data processing agreements that require them to maintain appropriate technical and organisational security measures. These providers include: identity verification and KYC platforms; payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard); fraud detection and AML screening services; IT infrastructure and cloud hosting providers; email and SMS communication platforms; and customer support software providers.

6.2 Game Studio Partners

Game content on the 21vip Platform is provided by third-party studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These studios may receive limited session data (such as a pseudonymous player token and game session identifiers) necessary to operate their games within the 21vip Platform environment. No directly identifiable personal data such as your name, email, or payment details is shared with game studios.

6.3 Legal and Regulatory Disclosure

21vip may disclose personal data to competent authorities, law enforcement agencies, courts, or regulators where required to do so by applicable law, court order, or a binding regulatory instruction. Where legally permissible, we will notify you of any such disclosure request before complying.

6.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of all or part of 21vip's business assets, personal data held by 21vip may be transferred to the acquiring entity as part of that transaction. Affected users will be notified by email in advance of any such transfer, and the acquiring entity will be required to honour the terms of this Privacy Policy.

7. International Data Transfers

21vip operates as an internationally based platform. As a result, your personal data may be stored on and processed by servers located outside Bangladesh, including in jurisdictions that may not have data protection laws equivalent to those in your home country. Where personal data is transferred internationally, 21vip ensures that appropriate safeguards are in place, such as contractual clauses that require the recipient to maintain standards of protection consistent with internationally recognised privacy frameworks.

By using the 21vip Platform, you acknowledge and consent to the transfer of your personal data to servers and processors located outside Bangladesh for the purposes described in this Policy.

8. Data Retention

21vip retains personal data for as long as necessary to fulfil the purposes for which it was collected, and in any event for the minimum periods required by applicable law. The general retention framework is as follows:

• Active account data: Retained for the lifetime of your account plus a minimum of five (5) years following account closure, to satisfy AML and financial record-keeping obligations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the customer relationship, in accordance with international AML standards.
• Transaction records: Retained for a minimum of seven (7) years from the date of each transaction.
• Customer support communications: Retained for a minimum of three (3) years from the date of each interaction, or longer if the communication relates to an unresolved dispute or legal proceeding.
• Marketing consent records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of the consent history.
• Technical / server log data: Retained for a maximum of twelve (12) months unless extended for fraud investigation or legal purposes.

Where personal data is no longer required for any lawful purpose, it is securely deleted or anonymised in accordance with 21vip's internal data lifecycle procedures.

9. Cookies & Tracking Technologies

The 21vip Platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain your login session, and collect analytical data about Platform usage. The main categories of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in, security tokens, and load-balancing cookies. These cannot be disabled without significantly impairing your use of the Platform.
• Performance & Analytics Cookies: Used to collect anonymous aggregated data about how users navigate the Platform, which pages are most visited, and where errors occur. This data helps us improve Platform performance and design.
• Functionality Cookies: Remember your preferences such as language settings, game display preferences, and responsible gaming tool configurations, so you do not have to re-enter them on each visit.
• Marketing Cookies: Used to deliver promotional content relevant to your interests, where you have given consent to receive marketing communications. These cookies track whether you have opened a promotional email or clicked on a banner within the Platform.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling certain categories of cookies may affect the functionality and security of your 21vip account session.

10. Security Measures

21vip employs a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures include:

• Industry-standard TLS 1.3 encryption for all data transmitted between your device and the 21vip Platform servers.
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial records.
• Account passwords stored using bcrypt one-way cryptographic hashing with per-account salt values — 21vip staff cannot retrieve your plaintext password.
• Multi-factor authentication (MFA) available for account login to provide an additional layer of identity verification beyond your password.
• Regular third-party security audits and penetration testing of Platform infrastructure and application code.
• Strict role-based access controls limiting employee access to personal data to those whose job functions require it.
• Intrusion detection and monitoring systems operating on a continuous basis across all Platform infrastructure.

While 21vip takes all reasonable precautions, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to affected users, 21vip will notify impacted users without undue delay and, where required, will report the breach to relevant regulatory authorities.

11. Your Data Rights

Subject to applicable law, you have the following rights in relation to the personal data 21vip holds about you. To exercise any of these rights, please contact our Data Protection Officer at the address provided in Section 15.

• Right of Access: You may request a copy of all personal data 21vip holds about you. We will provide this within 30 days of receiving a valid request, free of charge for one request per calendar year.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that it be corrected. We will update the data within 15 business days of a verified request.
• Right to Erasure: You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where you object to processing. Note that this right is subject to overriding legal obligations — for example, we are required by law to retain financial and KYC records for specified minimum periods even following account closure.
• Right to Restrict Processing: You may request that we suspend processing of your data in certain circumstances, such as while we investigate a rectification request or an objection to processing.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object at any time to processing carried out on the basis of legitimate interests, including profiling for direct marketing purposes. We will cease that processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

12. Children & Minors

The 21vip Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or store personal data relating to individuals under the age of 21. If we become aware that an account has been registered by a person under the age of 21, we will immediately suspend that account, freeze the associated balance, and securely delete all associated personal data, retaining only the records strictly required to fulfil our legal obligations.

If you are a parent or guardian and believe that a minor in your care has registered an account on the 21vip Platform, please contact us immediately at [email protected]. We will investigate the matter promptly and take all appropriate action.

We strongly encourage parents and guardians to use parental control software to prevent minors from accessing online gambling platforms. For further guidance, please refer to our Responsible Gaming Policy.

13. Third-Party Services & Links

The 21vip Platform may display or reference the names of third-party services, game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi), and payment providers (bKash, Nagad, Rocket, Upay, Visa, Mastercard) in the course of providing the Platform's features. While we integrate with these partners for service delivery purposes, each third-party service operates under its own independent privacy policy and data practices.

21vip is not responsible for the privacy practices of any third party, including game studios that serve game content within the Platform's interface, or payment processors that handle transaction data on their own infrastructure. We encourage you to review the privacy policies of any third-party services with which you interact in connection with your use of 21vip.

14. Changes to This Policy

21vip reserves the right to update or amend this Privacy Policy at any time. Where changes are material — that is, they significantly affect your privacy rights or how we handle your personal data — we will provide at least 14 days' prior notice by email to your registered address before the revised Policy takes effect. Minor changes, such as typographical corrections or clarifications that do not alter the substance of any provision, will take effect immediately upon publication on the Platform.

The current version of this Policy is always accessible at https://21vip.io/privacy-policy. The "Last Updated" date at the top of the table of contents indicates when the most recent revision was made. If you do not accept the terms of a revised Privacy Policy, you must close your account before the effective date of the change. Continued use of the Platform after that date constitutes acceptance of the revised Policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data 21vip holds about you, please contact our Data Protection Officer (DPO) using the details below. All data subject requests will be acknowledged within 2 business days and responded to within 30 calendar days of receipt.

Data Protection Officer — 21vip

Email: [email protected]

When submitting a data subject request, please include your registered username, the nature of the request, and any relevant account details to allow us to locate your records and verify your identity before processing the request. Identity verification is required for access, rectification, and erasure requests to protect against unauthorised disclosure of your data to third parties.

If you believe that 21vip has not handled your personal data in accordance with applicable data protection principles, and you are not satisfied with the outcome of your complaint through our internal process, you have the right to escalate the matter to the relevant data protection supervisory authority in your jurisdiction.