Privacy Policy

Effective Date: October 26, 2025
Last Updated: October 26, 2025

TPG Minibank ("we," "our," "us") values your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application TPG Minibank ("the App"). By using the App, you agree to the terms of this Privacy Policy.

Information We Collect

Personal Information

• Phone Number: Collected during Firebase phone authentication for user registration, login, and account verification.

• Account Information: Username, profile data, and account preferences you provide.

Transaction and Financial Data

• Virtual Currency Transactions: Records of chip purchases, wallet deposits, withdrawals, and in-app currency transfers.

• Payment Information: Transaction IDs and payment confirmations (actual payment details are processed and stored by Google Pay, not on our servers).

Device and Usage Data

• Device Information: Device type, operating system, unique device identifiers.

• Network Information: IP address, network connection type.

• App Usage: Features used, time spent in app, interaction patterns, crash reports.

• Security Data: Login attempts, security verification data.

Communications Data

• Support Interactions: Records of communications through our helpline for customer service purposes.

• Notifications: Preferences and delivery status of promotional and transactional notifications.

Legal Basis for Processing (GDPR)

We process your personal information based on the following legal grounds:

• Contract Performance: To provide app services, process transactions, and maintain your account.

• Legitimate Interests: For security, fraud prevention, customer support, and app improvement.

• Consent: For marketing communications and optional features (you may withdraw consent anytime).

• Legal Compliance: To comply with applicable laws and regulations.

How We Use Your Information

Your information is used for the following purposes:

• Account Management: Register, authenticate, and maintain your account through Firebase.

• Identity Verification: Verify your identity and prevent fraud and unauthorized access.

• Transaction Processing: Process chip purchases, wallet storage, withdrawals, and payment transactions.

• Customer Support: Provide assistance through our helpline at +8801886288266

• Communications: Send notifications about offers, discounts, app updates, and important account information.

• Security and Compliance: Detect and prevent illegal activities, enforce Terms of Service, and ban users engaged in prohibited activities.

• App Improvement: Analyze usage patterns to enhance user experience and app functionality.

• Legal Compliance: Meet regulatory requirements and respond to legal requests.

Data Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers

• Firebase (Google): For authentication and app infrastructure.

• Google Pay: For payment processing (they handle payment data under their own privacy policy).

• Analytics Services: Anonymous, aggregated data for app performance analysis.

Legal Requirements

• Law Enforcement: When required by law, court order, or government regulation.

• Legal Protection: To protect our rights, safety, or property, or that of our users.

• Business Transfers: In case of merger, acquisition, or sale of business assets (users will be notified).

With Your Consent

• Any other sharing will only occur with your explicit consent.

International Data Transfers

Your information may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place for international transfers, including:

• Adequacy decisions by relevant authorities.

• Standard contractual clauses approved by data protection authorities.

• Other legally recognized transfer mechanisms.

6. Data Storage and Security

Security Measures

• Encryption: All communications use the HTTPS protocol and RSA encryption for user integrity and verification.

• Server Security: Phone numbers and account information are securely stored with industry-standard protection.

• Access Controls: Limited access to personal data on a need-to-know basis.

• Regular Monitoring: Continuous security monitoring and updates.

Security Limitations

While we implement robust security measures, no system is completely secure. You use the App at your own risk and should take appropriate precautions to protect your account.

Data Retention and Deletion

Retention Period

• Active Accounts: Information retained while your account remains active.

• Inactive Accounts: Data may be retained for up to 2 years after last activity for security purposes.

• Transaction Records: Financial transaction data retained for 7 years for legal and accounting purposes.

Account Deletion

• Upon your request, your account and associated personal information will be permanently deleted within 30 days.

• Once deletion is initiated, it cannot be undone, and accounts cannot be recovered.

• Some information may be retained longer where required by law or for legitimate business purposes (fraud prevention, legal compliance).

Your Rights

Depending on your location, you may have the following rights:

Universal Rights

• Access: Request a copy of your personal data.

• Deletion: Request deletion of your account and personal data.

• Correction: Update or correct inaccurate information.

• Opt-out: Unsubscribe from promotional notifications through device settings.

Additional Rights (EU/UK Users - GDPR)

• Data Portability: Receive your data in a portable format.

• Restriction: Limit how we process your data.

• Objection: Object to processing based on legitimate interests.

• Automated Decision-Making: Rights regarding automated profiling (if applicable).

Additional Rights (California Users - CCPA)

• Know: What personal information is collected and how it's used.

• Delete: Request deletion of personal information.

• Opt-out: Opt out of sale of personal information (we don't sell personal information).

• Non-discrimination: Equal service regardless of privacy choices.

Exercising Your Rights

To exercise any of these rights, contact us at Minibank266@gmail.com or +8801886288266. We will respond within 30 days (or as required by applicable law).

Age Restrictions and Child Protection

• Age Requirement: The App is strictly prohibited for children under 18 years of age.

• No Child-Targeted Content: We do not create content intended for children.

• Immediate Deletion: Child accounts detected will be deleted immediately.

• Guardian Recovery: Remaining credits may be reclaimed by verified guardians within 7 days of account deletion with proper identification proof.

• Parental Responsibility: Parents/guardians should monitor their children's device usage.

Payments and Financial Data

Global Payments

• Google Pay: Processes payments globally in accordance with Google's regulations.

• Payment Security: Payment details (cards, bank accounts) are handled exclusively by Google Pay and never stored on our servers.

General Payment Policies

• Transaction Records: We maintain records of virtual currency transactions for account management and customer support

• Refund Policy: Credits may be blocked without refund for users banned due to illegal or fraudulent activities

• Payment Verification: Transaction verification may require temporary storage of payment confirmation data

Third-Party Services

Our App integrates with third-party services that may collect information under their own privacy policies:

Third-Party Services

Our App integrates with third-party services that may collect information under their own privacy policies:

Firebase Services

• Purpose: User authentication, app infrastructure, analytics

• Data Collected: Authentication data, usage analytics, crash reports

• Privacy Policy: Google Firebase Privacy Policy

Google Play Services

• Purpose: App functionality, payments, security

• Data Collected: Device information, app usage data

• Privacy Policy: Google Privacy Policy

Google Pay

• Purpose: Global payment processing

• Privacy Policy: Google Pay Privacy Notice

Data Collection by Third Parties

These services may collect device-related data such as IP addresses, advertising IDs, and analytics data, but do not access personal information you enter in our App beyond what's necessary for their specific functions. Local payment providers may collect additional data as outlined in their respective privacy policies.

Notifications and Communications

• Types: Promotional offers, discounts, app updates, security alerts, transaction confirmations.

• Consent: You can opt out of promotional notifications through your device settings.

• Time-Limited Offers: Expired offers cannot be claimed after their expiration date.

• Delivery: Notifications are sent through your device's notification system.

External Links and Content

• YouTube Content: The App contains links to YouTube videos owned and operated by us.

• Third-Party Links: Any external links (if present) lead to websites with their own privacy practices.

• Disclaimer: We are not responsible for the content or privacy practices of external websites.

Prohibited Activities and Enforcement

• Illegal Activities: Users engaging in illegal, fraudulent, or prohibited activities may be banned without prior notice.

• Credit Blocking: In cases of violations, account credits will be blocked, and no refunds will be issued.

• Investigation: We may investigate suspicious activities and cooperate with law enforcement.

• Appeal Process: Banned users may contact our support team to appeal decisions.

Cookies and Tracking Technologies

• Usage: We may use cookies, local storage, and similar technologies for app functionality and user experience

• Analytics: Anonymous data collection for app performance and user behavior analysis

• Control: You can manage these through your device settings, though some app functionality may be affected

Data Breach Notification

In the event of a data breach that may affect your personal information:

• User Notification: We will notify affected users within 72 hours of discovery.

• Authority Notification: Relevant data protection authorities will be notified as required by law.

• Mitigation: We will take immediate steps to secure the breach and minimize the impact.

Changes to This Privacy Policy

• Updates: We may update this Privacy Policy periodically to reflect changes in our practices or applicable laws.

• Notification: Material changes will be posted in the App with a revised "Last Updated" date.

• Acceptance: Continued use of the App after changes indicates your acceptance of the updated policy.

• Review: We encourage you to review this policy periodically.

Governing Law and Jurisdiction

• Governing Law: This Privacy Policy is governed by the laws of Bangladesh.

• Jurisdiction: Any disputes will be resolved in the courts of Dhaka, Bangladesh.

• International Users: Users outside Bangladesh acknowledge that their data may be processed under Bangladeshi law.

Contact Information

For questions, concerns, or to exercise your privacy rights, contact us:

Email:Minibank266@gmail.com
Helpline: +8801886288266  

Address:  77/2  Zero point, Khulna 9260, Bangladesh
Response Time: We will respond to privacy inquiries within 30 days

Effective Date and Acknowledgment

This Privacy Policy is effective as of the date listed above. By using BD Minibank Chips, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

For the most current version of this Privacy Policy, please check the App regularly.