33bd9 Privacy Policy —
How We Protect Your Personal Data

1 Introduction

This Privacy Policy applies to the 33bd9 online betting and gaming platform, accessible at 33bd9.io and through its associated mobile interfaces. It governs the collection, processing, storage, and sharing of personal data belonging to all registered players and platform visitors located in Bangladesh.

33bd9 acts as the data controller in respect of all personal data collected through its platform. As data controller, 33bd9 is responsible for determining the purposes and means by which your personal data is processed, and for ensuring that such processing complies with applicable data protection principles.

This Privacy Policy should be read alongside the 33bd9 Terms & Conditions and Responsible Gaming Policy. Together, these documents constitute the full agreement governing your relationship with the 33bd9 platform. Where this Privacy Policy conflicts with any other document, the Privacy Policy shall take precedence on matters relating to personal data.

By using the 33bd9 platform, you confirm that you are at least 21 years of age and that you consent to the data practices described in this Privacy Policy. If you do not agree with any aspect of this Policy, you should cease using the platform and may request account closure by contacting our support team.

2 Personal Data We Collect

33bd9 collects personal data across several categories, depending on how you interact with the platform. The following table summarises the primary categories of data we collect and why each category is collected.

33bd9 does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data, except where identity documents provided during KYC verification incidentally contain such information. In those cases, the document is used solely for identity verification and is not processed for any other purpose.

3 How We Collect Your Data

33bd9 collects personal data through several channels and mechanisms:

• Direct submission during registration: When you create your 33bd9 account, you voluntarily provide identity and contact information through the registration form.
• Account activity: As you use the platform — placing bets, playing games, depositing and withdrawing funds — your activity data is automatically recorded in our systems.
• KYC and verification submissions: When you submit identity documents (national ID card, passport, utility bills) as part of the verification process, those documents and their contents are collected and stored securely.
• Payment processing: When you initiate a deposit or withdrawal via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, transaction data is received from the respective payment gateway.
• Technical systems: Our servers, cookies, and analytics tools automatically collect technical data including your IP address, device identifiers, and session behaviour as you navigate the platform.
• Customer support interactions: When you contact 33bd9 via live chat or email, the content of those communications is recorded and stored as part of your support history.
• Third-party sources: In limited circumstances — for example, where a fraud risk flag is raised — 33bd9 may receive data about you from third-party verification or fraud-prevention services. Such data is used only for the specific purpose for which it was obtained.

4 How We Use Your Personal Data

33bd9 uses the personal data it collects for the following specific purposes. Data is never used for purposes that are incompatible with those listed here without your prior knowledge and, where required, your explicit consent.

• Account creation and management: To set up and maintain your 33bd9 player account, including processing your registration details and maintaining your BDT wallet.
• Identity and age verification: To confirm that you are 21 years of age or older and are who you claim to be, in accordance with our KYC obligations.
• Transaction processing: To facilitate deposits, withdrawals, and bonus credits accurately and securely via your chosen payment method.
• Platform security and fraud prevention: To detect, investigate, and prevent fraudulent activity, money laundering, account sharing, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible gaming compliance: To monitor betting patterns and flag potential indicators of problem gambling behaviour, in line with our Responsible Gaming obligations.
• Customer support: To respond to your queries, resolve disputes, and maintain records of support interactions for quality and accountability purposes.
• Legal and regulatory compliance: To meet our obligations under applicable laws, including responding to lawful requests from governmental or regulatory authorities.
• Platform improvement: To analyse aggregate, anonymised usage patterns that help us improve the performance, design, and game selection of the 33bd9 platform.
• Marketing communications: To send you promotional offers, bonus notifications, and event updates — only where you have opted in to receive such communications and have not subsequently withdrawn consent.

5 Legal Basis for Processing

33bd9 processes personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing that is required to fulfil the agreement between you and 33bd9 — including operating your account, processing transactions, and providing customer support. Without this processing, 33bd9 cannot deliver its services to you.
• Legal obligation: Processing required to comply with applicable laws — including KYC/AML (Know Your Customer / Anti-Money Laundering) requirements and responses to lawful authority requests.
• Legitimate interests: Processing carried out in the legitimate interests of 33bd9 or its players, where those interests are not overridden by your privacy rights. This includes fraud prevention, platform security monitoring, and anonymised analytics.
• Consent: Processing that relies on your freely given, specific, and informed consent — primarily in the context of marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Third Parties

33bd9 does not sell, rent, or trade your personal data to any third party for commercial gain. However, to operate the platform effectively, 33bd9 shares personal data with a limited set of third-party service providers, each of whom is bound by strict data processing agreements:

• Payment processors: bKash, Nagad, Rocket, Upay, and Visa/Mastercard network processors receive the transaction data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and security certifications.
• KYC and identity verification services: Third-party verification providers receive identity document data for the purpose of confirming your identity and age. Verified status is reported back to 33bd9; document data is not retained by 33bd9 beyond the verification process.
• Game content providers: Studios such as Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, and Spribe may receive anonymised session identifiers to facilitate game delivery. They do not receive your full name, contact details, or financial information.
• Fraud and security services: Specialist fraud-detection providers may receive technical data (IP addresses, device fingerprints) to assess risk levels associated with specific transactions or login events.
• Regulatory and legal authorities: In the event of a lawful request from a competent authority — such as a court order or regulatory investigation — 33bd9 may be required to disclose personal data. Such disclosure is made only to the extent required by applicable law.

All third-party service providers are contractually required to process personal data only for the specific purposes for which it has been shared, to maintain appropriate security measures, and to delete or return data when the business relationship ends.

7 Cookies & Tracking Technologies

The 33bd9 platform uses cookies and similar tracking technologies to provide core functionality, improve performance, and gather anonymised usage statistics. A cookie is a small text file placed on your device by a web server. It does not execute code or deliver viruses. Cookies used by 33bd9 fall into the following categories:

• Essential cookies: Required for the platform to function correctly — including maintaining your login session, managing your BDT wallet state, and securing form submissions. These cookies cannot be disabled without breaking core platform functionality.
• Performance cookies: Used to collect anonymised data about how users navigate the platform — which pages are visited most, where users drop off, and how quickly pages load. This data helps 33bd9 improve platform performance. No personal identity is linked to this data.
• Functional cookies: Used to remember your preferences — such as your preferred game category or language setting — so that your experience is personalised across sessions.
• Security cookies: Used to detect and prevent fraudulent activity, including credential stuffing attacks and unusual login patterns.

33bd9 does not use third-party advertising cookies or behavioural tracking cookies that build profiles for external advertising networks. You may manage or disable non-essential cookies through your browser settings, though doing so may affect the functionality of certain platform features.

8 Data Retention

33bd9 retains personal data only for as long as it is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply as general guidelines:

• Active account data: Retained for the full duration of your account's active status plus a defined post-closure period to enable dispute resolution and fraud investigation.
• Financial transaction records: Retained for a minimum of five years from the date of each transaction, in compliance with anti-money laundering record-keeping requirements.
• KYC and identity verification documents: Retained for a minimum of five years following account closure, or longer if required by a specific regulatory instruction or legal proceeding.
• Customer support records: Retained for three years from the date of the last interaction, to support ongoing account management and dispute resolution.
• Technical and security logs: Typically retained for 12 months, after which they are deleted or anonymised. Logs tied to a specific fraud or security investigation may be retained for the duration of that investigation.
• Marketing consent records: Retained from the date of opt-in until you withdraw consent, plus a short period thereafter to document the fact that consent was obtained and subsequently withdrawn.

Once a retention period expires, data is securely deleted or irreversibly anonymised. Anonymised data — which cannot be linked back to any individual — may be retained indefinitely for statistical and platform improvement purposes.

9 Data Security

33bd9 implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 33bd9 platform.
• Encrypted storage of sensitive data fields, including financial identifiers and identity document references.
• Role-based access controls that limit internal access to personal data to authorised personnel with a documented business need.
• Regular internal security reviews and vulnerability assessments of platform infrastructure.
• Two-factor authentication options available to all registered players to protect account access.
• Monitoring systems that flag unusual login events, mass data access attempts, and other indicators of a potential security incident.

In the event of a personal data breach that poses a risk to the rights and freedoms of affected players, 33bd9 will take immediate containment action and notify affected players as promptly as reasonably practicable, including a description of what data was involved, what steps are being taken, and what actions we recommend you take to protect yourself.

10 Your Privacy Rights

As a 33bd9 player in Bangladesh, you hold the following rights in respect of your personal data. To exercise any of these rights, contact the 33bd9 support team at [email protected] with the subject line "Privacy Rights Request":

• Right of access: You may request a copy of the personal data that 33bd9 holds about you, along with information about how it is being used.
• Right to rectification: If any personal data held by 33bd9 is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to any overriding legal retention obligations.
• Right to restriction: In certain circumstances, you may request that 33bd9 restrict the processing of your data — for example, while a rectification request is being reviewed.
• Right to data portability: You may request that certain personal data held by 33bd9 be provided to you in a structured, machine-readable format, where technically feasible.
• Right to object: You may object to the processing of your personal data where that processing is based on legitimate interests. 33bd9 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent — including marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

33bd9 will respond to privacy rights requests within 30 days of receipt. In cases of complexity or high volume, this period may be extended by a further 30 days, in which case you will be informed of the extension and the reason for it.

11 Children & Minors

The 33bd9 platform is strictly intended for adults aged 21 and above. 33bd9 does not knowingly collect personal data from any person under the age of 21. If we discover that a registered account belongs to a person under 21, that account will be immediately and permanently closed, all balances will be forfeited, and any associated personal data will be deleted from our systems as promptly as the applicable legal obligations allow.

If you are a parent or guardian and you believe that a minor in your care has registered on the 33bd9 platform, please contact [email protected] immediately. We will investigate and act without delay.

12 Marketing Communications

33bd9 may send you promotional communications — including bonus offers, cricket match-day promotions, BPL and IPL season specials, and new game launch notifications — provided that you have given explicit opt-in consent to receive such communications during registration or subsequently through your account settings.

Marketing messages may be sent via email or SMS to the mobile number registered on your 33bd9 account. The frequency and content of marketing communications will vary based on platform promotions and your account activity level.

You may opt out of marketing communications at any time by:

• Clicking the unsubscribe link included at the bottom of any marketing email from 33bd9.
• Updating your communication preferences in the 33bd9 account settings section.
• Contacting support at [email protected] with a request to be removed from marketing lists.

Opting out of marketing communications does not affect the delivery of transactional messages — such as deposit confirmations, withdrawal processing notices, and security alerts — which are sent regardless of marketing preferences because they are necessary for the operation of your account.

13 Updates to This Privacy Policy

33bd9 reviews and updates this Privacy Policy periodically to reflect changes in platform operations, applicable laws, or industry best practices. The effective date displayed at the top of this document indicates when the current version came into force.

When material changes are made — that is, changes that meaningfully alter how your personal data is collected, used, or shared — 33bd9 will notify registered players through a prominent in-platform notification upon login and, where applicable, by email to the registered account address. Such notifications will be issued at least 14 days before the updated policy takes effect, giving you time to review the changes before they apply to your account.

Continued use of the 33bd9 platform after the effective date of a Privacy Policy update constitutes your acceptance of the revised policy. If you do not accept the updated terms, you must cease using the platform and contact support to request account closure. The most current version of this Privacy Policy is always accessible at 33bd9.io/privacy-policy.

14 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 33bd9 handles your personal data, please contact the 33bd9 privacy team using the details below:

• Email: [email protected] — please use the subject line "Privacy Enquiry" or "Privacy Rights Request" for the fastest response.
• Live Chat: Available 24 hours a day, 7 days a week through the 33bd9 platform interface after login.
• Response Time: Privacy enquiries are typically acknowledged within 48 hours and resolved within 30 days. Complex requests may take up to 60 days, with prior notification provided.
• Support Hours: Bangladesh Standard Time (BST, UTC+6), 24/7 including all public holidays.

33bd9 is committed to resolving all privacy-related concerns fairly and transparently. If you are not satisfied with the outcome of a complaint, you retain the right to escalate the matter through appropriate channels in your jurisdiction.