Privacy Policy
At suna104, your privacy is a core commitment — not an afterthought. This Privacy Policy explains exactly what personal data we collect, how we use it, who we share it with, and what rights you hold over your own information. We handle all player data in accordance with applicable data protection principles and maintain strict security standards to keep your details safe.
Overview
Privacy at a Glance
The cards below summarise the six pillars of our approach to data protection on suna104. Each topic is covered in full detail in the sections that follow.
Minimal Collection
We collect only the personal data that is strictly necessary to operate your suna104 account, process your transactions, and comply with our legal obligations. We do not collect data for its own sake.
Secure Storage
All personal data stored by suna104 is protected by industry-standard encryption (TLS 1.3 in transit, AES-256 at rest). Access is restricted to authorised personnel on a strict need-to-know basis.
No Data Sales
suna104 does not sell, rent, or trade your personal data to third parties for marketing purposes. Data is shared only with service partners essential to platform operation, under strict confidentiality obligations.
Your Rights
You have the right to access, correct, delete, and port your personal data at any time. You may also object to certain processing activities. suna104 will respond to all valid data requests within 30 days.
Clear Retention Limits
We retain your data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Account data is securely deleted or anonymised after the applicable retention period expires.
Transparent Communication
When this Privacy Policy changes in a material way, we will notify you via email or a prominent on-platform notice before the changes take effect. You will never be surprised by a silent policy update.
Section 1
Data We Collect
When you interact with suna104 — whether by registering an account, making a deposit, placing a bet, contacting support, or simply browsing the platform — we may collect a range of personal data. The specific categories of data collected depend on how you use the platform. Below is a comprehensive breakdown of what we collect and why.
| Data Category | Examples | Collection Trigger |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, National Identity Card (NID) number | Account registration, KYC verification |
| Contact Data | Email address, Bangladesh mobile number, residential address (Dhaka, Chittagong, Sylhet, etc.) | Account registration, support contact |
| Financial Data | bKash account number, Nagad account number, Rocket (DBBL) account number, transaction history, deposit and withdrawal amounts in BDT | Deposit, withdrawal, transaction verification |
| Technical Data | IP address, device type, browser type and version, operating system, screen resolution, session duration | Automatic collection on platform access |
| Usage Data | Pages visited, games played, bets placed (sports markets, slots, casino), session timestamps, search queries on the platform | Automatic collection during platform use |
| Communications Data | Live chat transcripts, support emails, complaint records | When you contact suna104 support |
| Verification Data | Copies of NID, passport, driving licence, utility bill, bank statement scans submitted for KYC | KYC verification request |
Data We Do Not Collect
suna104 does not collect biometric data (fingerprints, facial recognition), does not store full payment card numbers (we do not accept card payments), and does not collect data from minors. Any data submitted by a person under 18 years of age will be deleted upon discovery and the associated account permanently closed.
suna104 collects and processes personal data on the following legal bases: (a) contractual necessity — to register your account and deliver the services you have requested; (b) legal obligation — to comply with applicable anti-money laundering (AML) and know-your-customer (KYC) requirements; (c) legitimate interests — to prevent fraud, maintain platform security, and improve our services; and (d) consent — for optional marketing communications, which you may withdraw at any time.
Section 2
How We Use Your Data
suna104 uses the personal data it collects for clearly defined, lawful purposes. We do not use your data in ways that are incompatible with the original reason it was collected. The following explains each use case in plain terms.
Account Management & Service Delivery
Your identity and contact data is used to create and maintain your suna104 account, verify your eligibility to use the platform (including age verification to confirm you are 18 or older), process your deposits and withdrawals via bKash, Nagad, and Rocket, and send you essential account-related communications such as transaction confirmations, security alerts, and password reset instructions.
Fraud Prevention & Platform Security
Technical data (IP address, device fingerprint, session data) and usage data are analysed by our security systems to detect and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting, and other forms of prohibited conduct described in our Terms & Conditions. This processing is carried out on the basis of our legitimate interest in maintaining a safe and fair platform for all suna104 players.
Responsible Gaming Compliance
Usage data — including bet frequency, session duration, deposit patterns, and game history — may be reviewed by our responsible gaming team to identify players who may be exhibiting signs of problem gambling. Where such patterns are identified, suna104 may reach out proactively to offer responsible gaming tools, including deposit limits, time-out periods, and self-exclusion options.
Legal & Regulatory Compliance
Where required by applicable law, suna104 may be obligated to process and retain certain personal data — including identity, financial transaction, and communications data — for the purpose of AML compliance, regulatory reporting, or responding to lawful requests from competent authorities. Such processing overrides any user request for data deletion during the applicable mandatory retention period.
Platform Improvement & Analytics
Anonymised and aggregated usage data may be used by suna104's internal analytics team to understand how players navigate the platform, which game categories (cricket betting, slots, treasure hunt, pirate fishing) are most popular, and where the platform's user experience can be improved. This analysis does not involve identifying individual players and is based on statistical patterns only.
Marketing Communications (Consent-Based)
If you have expressly opted in to receive promotional communications from suna104, we may use your email address and mobile number to send you information about bonuses, seasonal promotions (such as BPL cricket offers, Eid specials, and Pohela Boishakh events), new game launches, and platform updates. You may withdraw your marketing consent at any time by contacting or by using the unsubscribe mechanism in any promotional email.
suna104 does not use fully automated decision-making processes that produce legal or similarly significant effects on individual players without human review. Where automated systems flag an account for security or responsible gaming review, a member of our compliance team will assess the case before any account action is taken.
Section 3
Data Sharing & Third Parties
suna104 does not sell your personal data to third parties. However, to deliver our services effectively and meet our legal obligations, we may share certain personal data with the following categories of trusted partners and authorities. All third-party data sharing is governed by written data processing agreements that require recipients to apply security and confidentiality standards equivalent to our own.
Payment Service Providers
We share the minimum financial and identity data necessary with bKash, Nagad, and Rocket (DBBL) to process your deposits and withdrawals. These providers are subject to their own privacy policies and regulatory obligations under Bangladesh's financial regulations.
Game Software Providers
Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive a player session token and anonymised player ID to deliver their games within the suna104 platform. They do not receive your full identity or payment data.
Fraud & AML Prevention Services
We work with specialist fraud detection and anti-money laundering compliance partners. These services may receive technical identifiers (IP address, device fingerprint) and anonymised transaction patterns to help us maintain a safe platform environment.
Regulatory & Legal Authorities
Where required by applicable law or a lawful order from a competent authority, suna104 may disclose personal data to government bodies, law enforcement, or courts. We will notify affected players of such disclosures where we are legally permitted to do so.
International Data Transfers
Some of suna104's technology and game provider partners operate servers located outside Bangladesh. Where personal data is transferred internationally, suna104 takes reasonable steps to ensure that the recipient jurisdiction provides an adequate level of data protection, or that appropriate contractual safeguards (such as standard data protection clauses) are in place before any transfer occurs.
Section 4
Cookies & Tracking Technologies
suna104 uses cookies and similar tracking technologies (such as web beacons and local storage) to deliver a functional, personalised, and secure platform experience. A cookie is a small text file placed on your device by your browser when you visit a website. Cookies allow the platform to remember your preferences, maintain your login session, and analyse how the platform is being used.
| Cookie Type | Purpose | Duration | Can Be Disabled? |
|---|---|---|---|
| Strictly Necessary | Session management, login authentication, security tokens, CSRF protection | Session / 24 hours | No — required for platform to function |
| Functional | Remembering your language preference (English), display settings, last-visited game category | 30 days | Yes — via browser settings |
| Analytics | Anonymised page view tracking, session duration, game category popularity, navigation flow analysis | 90 days | Yes — via browser settings |
| Security | Device fingerprinting for fraud detection, bot detection, rate-limiting enforcement | Session / 7 days | No — required for security |
Managing Your Cookie Preferences
You can control and manage cookies through your browser settings. Most modern browsers allow you to block or delete cookies, or to be notified when a cookie is set. Please note that disabling strictly necessary or security cookies will impair your ability to use suna104 — you may be unable to log in, maintain a session, or access certain game categories including cricket betting, slots, treasure hunt, and pirate fishing.
To manage cookies in popular browsers, navigate to your browser's privacy or security settings. Instructions are typically found under headings such as "Privacy", "Security", "Content Settings", or "Site Settings". For mobile users accessing suna104 on Android or iOS devices in Bangladesh, you can manage cookies through your mobile browser's settings menu.
suna104 does not place third-party advertising or tracking cookies on your device. We do not participate in cross-site behavioural advertising networks. Any tracking technologies used on the platform are operated solely by suna104 or its direct service providers for the purposes described in this policy.
Section 5
Data Retention
suna104 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The retention schedule below reflects our standard data lifecycle management practices.
| Data Category | Retention Period | Reason |
|---|---|---|
| Account & Identity Data | Duration of account + 5 years after closure | AML compliance, dispute resolution |
| Financial Transaction Data | 7 years from transaction date | Legal and regulatory obligation |
| KYC Verification Documents | Duration of account + 5 years after closure | AML and identity fraud prevention |
| Support Communications | 3 years from last contact | Quality assurance, dispute reference |
| Technical & Usage Data | 13 months (rolling) | Security monitoring, platform analytics |
| Marketing Consent Records | Until consent is withdrawn + 1 year | Proof of consent for regulatory purposes |
When the applicable retention period expires, suna104 will securely delete or irreversibly anonymise the relevant personal data so that it can no longer be attributed to an identifiable individual. Anonymised statistical data (with no individual identifiers) may be retained indefinitely for aggregated business analytics.
Data Deletion Requests
You may request the deletion of your personal data at any time by contacting . Please note that where suna104 is subject to a mandatory legal retention obligation (such as the 7-year financial records requirement), we will be unable to delete the relevant data until the mandatory period has elapsed, even if your account has been closed. We will notify you of any such limitation when responding to your deletion request.
Section 6
Your Privacy Rights
As a suna104 player, you hold the following rights in relation to your personal data. These rights may be exercised at any time by contacting our support team. suna104 commits to acknowledging all data rights requests within 5 business days and providing a full response within 30 calendar days of receiving a valid, verified request.
Right of Access
You have the right to request a copy of all personal data that suna104 holds about you, along with information about how it is being used and who it has been shared with.
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. Identity and contact data corrections may require supporting documentation.
Right to Erasure
You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any mandatory legal retention obligations that apply.
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to transmit it to another controller where technically feasible.
Right to Object
You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our overriding legal or operational needs.
Right to Restrict Processing
In certain circumstances, you may request that suna104 restricts the processing of your personal data — for example, while a rectification request is being assessed or an objection is being considered.
To exercise any of the rights listed above, contact suna104 in writing via email at . Please include your full registered name, your suna104 account username, and a clear description of the right you wish to exercise. We may ask for proof of identity before processing your request to protect your account against fraudulent data access requests from third parties.
Section 7
Data Security Measures
suna104 implements a layered security architecture designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. While no system can guarantee absolute security, we maintain the following technical and organisational measures as a matter of standard practice.
TLS 1.3 Encryption in Transit
All data transmitted between your device and suna104's servers is encrypted using TLS 1.3, the current industry standard for secure web communications. This protects your login credentials, financial data, and personal information from interception.
AES-256 Encryption at Rest
Sensitive personal data stored in suna104's databases — including identity, KYC documents, and financial records — is encrypted at rest using AES-256, ensuring that data remains unreadable even in the event of physical media compromise.
Access Controls & Staff Training
Access to personal data is restricted to suna104 staff who require it to perform their specific job functions, enforced through role-based access controls. All staff handling personal data undergo regular data protection and security training.
Incident Response
In the event of a personal data breach that poses a risk to affected individuals, suna104 will notify the relevant players without undue delay and take immediate remediation steps. A detailed incident response plan is maintained and tested regularly.
Your Role in Data Security
While suna104 takes every reasonable step to protect your data on our end, the security of your account also depends on the steps you take. We strongly recommend using a unique, strong password for your suna104 account that is not shared with any other service. Enable two-factor authentication where available, and never share your login credentials with another person. If you suspect your account has been compromised, contact immediately so we can secure your account.
Section 8
Contact & Complaints
If you have any questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how suna104 has handled your personal data, please contact us using the details below. All privacy-related enquiries will be handled by our compliance team and responded to within 5 business days (Bangladesh Standard Time, UTC+6).
Email: — Please use the subject line "Privacy Enquiry" or "Data Rights Request" for faster routing to our compliance team. Responses are provided in English within 5 business days (BST).
Complaints Process
If you are not satisfied with suna104's response to your privacy concern or data rights request, you have the right to escalate your complaint. Please follow the steps below:
- First, submit your concern in writing to with full details of your complaint. We will provide a full written response within 5 business days.
- If you remain unsatisfied after receiving our response, you may request that the matter be escalated to a senior member of our compliance team. Please state "Escalation Request" clearly in your email.
- If, after exhausting suna104's internal complaints process, you remain dissatisfied, you may seek independent resolution through applicable consumer protection or data protection channels available under the laws of Bangladesh.
Policy Updates
suna104 reviews this Privacy Policy periodically and will update it when our data practices change or when required by applicable law. When material changes are made, we will notify you via the email address registered to your account and post a prominent notice on the platform no less than 14 days before the changes take effect. The "Last Updated" date at the top of this document reflects the date of the most recent revision. Your continued use of suna104 following a policy update constitutes your acknowledgement of the revised Privacy Policy.
This Privacy Policy is written and published in English. In the event of any dispute arising from interpretation of this document, the English-language version shall be the authoritative and controlling version. suna104 serves the Bangladesh market with all platform content and legal documentation in English.
Our support team is available 24/7 to help with any privacy questions, data rights requests, or account concerns. You can also explore our platform while knowing your data is in safe hands.