ludu Privacy Policy —
Your Data, Protected

Effective Date: January 1, 2026  |  Last Updated: January 1, 2026

This Privacy Policy ("Policy") describes how ludu ("the Company," "we," "us," or "our"), the operator of the online gaming and betting platform available at https://ludu.onl ("the Platform"), collects, uses, stores, shares, and protects personal information about registered players and visitors ("you" or "User") located in Bangladesh. By creating a ludu account or accessing the Platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you must immediately cease using the Platform and close your account.

1. Data Controller

ludu is the data controller responsible for your personal information collected via the Platform. For any privacy-related inquiries, requests, or complaints, you may contact our designated privacy team at [email protected]. We aim to acknowledge all privacy correspondence within 5 business days (Bangladesh Standard Time, UTC+6).

2. Information We Collect

2.1 Information You Provide Directly

When you register for a ludu account or interact with the Platform, you voluntarily provide certain personal information, including but not limited to:

• Identity information: Your full legal name, date of birth, gender, and national identity card or passport number for age verification and anti-fraud purposes.
• Contact information: Email address, mobile phone number registered in Bangladesh, and residential address.
• Account credentials: Username and password (stored in hashed form; ludu never stores your password in plain text).
• Payment information: Account numbers or mobile wallet identifiers for bKash, Nagad, Rocket, Upay, or bank account details for deposits and withdrawals. Note that credit/debit card information is processed directly by our licensed third-party payment gateways and is not stored on ludu's servers.
• Communications: Any messages, chat logs, emails, or support tickets you submit to ludu's customer service team.
• Verification documents: Copies of government-issued identification, proof of address (utility bills or bank statements), and selfie photographs holding ID documents as required for Know Your Customer (KYC) and anti-money laundering (AML) compliance.

2.2 Information Collected Automatically

When you access or use the ludu Platform, certain technical data is collected automatically through cookies, web beacons, server logs, and similar tracking technologies:

• Device and browser information: Your device type, operating system, browser type and version, screen resolution, IP address, and unique device identifiers.
• Location data: Your approximate geographic location derived from IP address to verify that you are accessing the Platform from within Bangladesh as required by our Terms and Conditions.
• Usage data: Pages viewed, features accessed, time spent on each page, games played, bets placed, deposits and withdrawals initiated, links clicked, and navigation paths through the Platform.
• Cookies and tracking identifiers: Small data files stored on your device to maintain session state, remember your preferences, and enable analytics. You may disable cookies through your browser settings, though this may limit certain Platform functionality.

2.3 Information From Third Parties

ludu may receive limited information about you from third-party sources, including:

• Payment providers: Transaction confirmation data from bKash, Nagad, Rocket, Upay, and banks to verify deposit and withdrawal requests.
• Identity verification services: Age and identity validation results from third-party KYC service providers used to comply with regulatory requirements.
• Fraud prevention services: Risk assessment scores and fraud indicators from specialized security vendors used to protect the Platform and its users from fraudulent activity.

3. How We Use Your Information

ludu uses the personal information collected from you for the following specific purposes:

• Account creation and management: To establish, maintain, and administer your ludu account, including authentication, password resets, and account recovery.
• Service delivery: To provide access to games, betting markets, live casino features, deposit and withdrawal processing, bonus eligibility determination, and customer support.
• Identity verification and compliance: To verify your age (21+ requirement), confirm your identity to prevent fraud and multiple account abuse, and comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
• Payment processing: To process deposits, withdrawals, and refunds through your chosen payment method; to verify that payment accounts are registered in your legal name; and to prevent payment fraud.
• Security and fraud prevention: To detect, prevent, and investigate fraudulent activity, collusion, bonus abuse, account takeovers, unauthorized access, and other violations of our Terms and Conditions.
• Communications: To send you transactional communications (account confirmations, deposit receipts, withdrawal notifications, security alerts) and, if you have opted in, promotional offers, bonuses, and marketing messages related to ludu services. You may opt out of promotional communications at any time via account settings or by clicking unsubscribe links in emails.
• Platform improvement and analytics: To analyze usage patterns, identify technical issues, optimize Platform performance, improve user experience, and develop new features and games tailored to Bangladeshi player preferences.
• Legal compliance: To respond to legal process (court orders, subpoenas, or government requests), enforce our Terms and Conditions, protect our legal rights, and comply with applicable laws and regulations in Bangladesh.

4. Legal Bases for Processing

We process your personal information on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and ludu (account creation, service delivery, payment processing).
• Legal obligation: Processing required to comply with applicable laws, including age verification, identity confirmation, AML/CTF regulations, and tax reporting requirements.
• Legitimate interests: Processing necessary for ludu's legitimate business interests, including fraud prevention, security monitoring, Platform optimization, and marketing (where not overridden by your privacy rights).
• Consent: Processing based on your explicit consent, such as receiving promotional communications or using optional Platform features that require additional data collection.

5. Information Sharing and Disclosure

5.1 Third-Party Service Providers

ludu shares your personal information with trusted third-party service providers who assist in operating the Platform, processing payments, verifying identities, preventing fraud, and delivering services to you. These providers include:

• Payment processors and mobile wallet operators (bKash, Nagad, Rocket, Upay, banks)
• Identity verification and KYC service providers
• Cloud hosting and data storage providers
• Customer support software vendors
• Marketing and email communication platforms
• Game content providers and live casino studios
• Security and fraud detection services

All third-party service providers are contractually required to protect your data, use it only for the specific purposes defined by ludu, and comply with applicable data protection laws. We do not permit these providers to use your data for their own marketing purposes.

5.2 Legal and Regulatory Authorities

ludu may disclose your personal information to law enforcement agencies, government bodies, regulators, or courts when required by law or when we believe in good faith that disclosure is necessary to comply with legal obligations, protect our legal rights, enforce our Terms and Conditions, investigate fraud or security incidents, or protect the safety and rights of ludu, our users, or the public.

5.3 Business Transfers

In the event that ludu undergoes a merger, acquisition, sale of assets, bankruptcy, or other corporate restructuring, your personal information may be transferred to the acquiring or successor entity as part of the transaction. You will be notified via email and/or prominent Platform notice if such a transfer occurs.

5.4 No Data Sales

ludu does not sell, rent, or trade your personal information to third-party advertisers, data brokers, or marketing companies. Your data is used solely to provide and improve ludu's services and to fulfill the purposes described in this Policy.

6. Data Retention

ludu retains your personal information for as long as your account remains active and for a reasonable period thereafter as necessary to comply with legal obligations, resolve disputes, enforce our agreements, and maintain records required by anti-money laundering and gaming regulations. Specific retention periods include:

• Account information: Retained for the life of your account plus 7 years following account closure to comply with financial record-keeping requirements.
• Transaction records: Retained for 7 years following the transaction date as required by Bangladesh tax and financial regulations.
• Verification documents: Retained for 7 years following account closure to comply with AML/CTF obligations.
• Communications and support tickets: Retained for 3 years following resolution for quality assurance and dispute resolution purposes.
• Marketing preferences: Retained until you unsubscribe or request deletion.

Upon expiration of the applicable retention period, ludu will securely delete or anonymize your personal information. You may request early deletion of certain data by contacting [email protected], subject to our legal and regulatory retention obligations.

7. Data Security

ludu implements industry-standard technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ludu's servers
• Encryption at rest for sensitive data stored in our databases
• Secure password hashing using bcrypt or similar algorithms
• Multi-factor authentication options for account access
• Regular security audits, vulnerability assessments, and penetration testing
• Strict access controls limiting employee and contractor access to personal data on a need-to-know basis
• Secure data centers with physical access restrictions, fire suppression, and redundant power supplies
• Incident response procedures to detect and respond to security breaches

While we take data security seriously and employ robust safeguards, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying ludu immediately if you suspect unauthorized access to your account.

8. Your Privacy Rights

As a ludu user, you have the following rights regarding your personal information:

• Right of access: You may request a copy of the personal information ludu holds about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal information.
• Right to erasure: You may request deletion of your personal information, subject to legal and regulatory retention requirements.
• Right to restrict processing: You may request that ludu limit how we process your data in certain circumstances.
• Right to data portability: You may request a machine-readable copy of your data for transfer to another service provider.
• Right to object: You may object to processing of your data for direct marketing purposes or based on legitimate interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time.

To exercise any of these rights, contact [email protected] with your request and proof of identity. We will respond within 30 calendar days. Note that certain requests may be subject to legal restrictions or may require us to verify your identity before fulfilling the request.

9. Cookies and Tracking Technologies

ludu uses cookies, web beacons, and similar technologies to enhance your experience on the Platform, remember your preferences, and collect usage analytics. Cookies are small text files stored on your device that allow us to recognize you on return visits. Types of cookies we use include:

• Essential cookies: Required for basic Platform functionality, including authentication, security, and session management. These cannot be disabled without breaking core features.
• Functional cookies: Used to remember your preferences (language, layout settings, sound preferences) to provide a personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the Platform to help us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content and measure the effectiveness of marketing campaigns. These cookies may track you across websites.

You may control or delete cookies through your browser settings. However, disabling cookies may impair certain Platform functionality. For more information about cookies, visit www.allaboutcookies.org.

10. Children's Privacy

The ludu Platform is intended exclusively for individuals aged 21 years or older. We do not knowingly collect personal information from anyone under the age of 21. If we become aware that we have inadvertently collected data from a minor, we will immediately delete that information and permanently close the associated account. If you believe a minor has created an account on ludu, please contact [email protected] immediately.

11. International Data Transfers

Your personal information may be transferred to and stored on servers located outside Bangladesh, including in jurisdictions that may not provide the same level of data protection as Bangladesh law. When transferring data internationally, ludu implements appropriate safeguards (such as standard contractual clauses, encryption, and data processing agreements) to ensure your information remains protected in accordance with this Policy.

12. Changes to This Privacy Policy

ludu reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. When we make material changes, we will notify registered users via email or prominent notice on the Platform at least 14 days before the changes take effect. The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of the Platform following a policy update constitutes acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about our data practices.

13. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or ludu's data practices, or if you wish to exercise any of your privacy rights, please contact us at:

Email: [email protected]
Subject Line: Privacy Inquiry
Response Time: Within 5 business days for acknowledgment; within 30 calendar days for resolution

We are committed to resolving privacy concerns in a timely and transparent manner. If you are not satisfied with our response, you may have the right to lodge a complaint with the appropriate data protection authority in Bangladesh.