33ed Privacy Policy

This Privacy Policy ("Policy") describes how 33ed ("the Platform", "we", "us", "our"), accessible at 33ed.io, collects, processes, stores, and protects personal data belonging to registered players and website visitors in Bangladesh. This Policy applies to all interactions with the 33ed platform, including account registration, deposits and withdrawals, sports betting activity, casino and slot game play, promotional participation, and contact with our customer support team.

33ed is committed to handling personal data with integrity, transparency, and care. We recognise that the players who use our platform entrust us with sensitive information — including identity documents, financial transaction records, and contact details — and we take that responsibility seriously. This Policy explains precisely what we collect, why we collect it, how long we keep it, who we share it with, and what rights you have in relation to your own data.

This Policy should be read alongside the Terms and Conditions and the Responsible Gaming Policy, both of which are incorporated by reference. Where any conflict exists between this Policy and those documents in respect of data-handling matters, this Privacy Policy shall prevail.

For the purposes of applicable data protection law, 33ed is the data controller responsible for the personal data of players who use the 33ed.io platform. As data controller, 33ed determines the purposes and means by which personal data is processed and bears responsibility for ensuring that all processing activities comply with the applicable legal framework.

If you have any questions about how your personal data is handled, or if you wish to exercise any of the rights described in Section 10 of this Policy, please contact the 33ed Data Privacy team using the contact details set out in Section 14.

33ed collects personal data from players through several channels, including the account registration process, ongoing platform usage, customer support interactions, and KYC identity verification. The categories of personal data we may collect are summarised below.

We do not collect any special-category sensitive personal data such as biometric data, health records, political opinions, religious beliefs, or racial or ethnic origin. We do not require players to submit photographs beyond those already embedded in accepted identity documents.

33ed uses the personal data collected from players for the following specific purposes:

• Account creation and management: To register your account, verify your identity, maintain accurate records, and administer your player profile throughout the lifetime of your relationship with 33ed.
• Transaction processing: To facilitate deposits and withdrawals via bKash, Nagad, and Rocket; to reconcile financial records; and to investigate and resolve any transaction disputes that may arise.
• Platform delivery: To provide access to the sports betting markets, live casino games, slot titles, and multi-bet features available on the 33ed platform, and to personalise your experience where applicable.
• KYC and fraud prevention: To verify that you meet the minimum age requirement of 21 years, to detect and prevent fraudulent account activity, to identify and investigate suspected money laundering, and to enforce the one-account-per-player policy.
• Responsible gaming: To monitor betting behaviour for indicators of problem gambling, to apply voluntary or mandatory account limits where appropriate, and to action self-exclusion requests in line with our Responsible Gaming Policy.
• Customer support: To respond to your enquiries, complaints, and support requests; to maintain records of previous communications for continuity of service; and to improve the quality of our support provision.
• Legal and regulatory compliance: To fulfil any obligations imposed on 33ed by applicable law, including financial record-keeping, anti-money laundering (AML) requirements, and responses to lawful requests from regulatory or law-enforcement authorities.
• Platform improvement: To analyse aggregated, anonymised usage data in order to improve platform performance, game selection, user interface design, and overall player experience.
• Marketing communications: To send you promotional offers, seasonal campaigns, and platform updates where you have provided consent to receive such communications. You may withdraw marketing consent at any time by contacting the support team.

33ed will not use your personal data for any purpose other than those described above without first notifying you and, where required, obtaining your explicit consent.

33ed processes personal data only where a valid legal basis exists for doing so. The legal bases on which we rely are as follows:

• Contractual necessity: Processing that is required in order to provide the services described in the Terms and Conditions and to fulfil our obligations to you as a registered player — including account management, payment processing, and platform access.
• Legal obligation: Processing that is required to comply with applicable law — including anti-money laundering obligations, age verification requirements, and responses to lawful authority requests.
• Legitimate interests: Processing that is necessary for purposes related to the legitimate operation of the 33ed business — including fraud detection, platform security, responsible gaming monitoring, and anonymised analytics — provided that such processing does not override your fundamental rights and freedoms.
• Consent: Processing that is based on your freely given, specific, and informed consent — primarily marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

33ed does not sell, rent, or trade your personal data. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose.

• Payment service providers: Personal and financial data is shared with bKash, Nagad, and Rocket solely to process your deposit and withdrawal transactions. These providers operate under their own privacy policies and are bound by strict data processing agreements with 33ed.
• Game providers: Technical usage data (such as session identifiers and game play records) may be shared with certified third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi in order to deliver their games on the 33ed platform and to resolve any game-related disputes.
• Identity verification services: Where automated KYC tools are used to assist with document verification, identity data may be processed by a third-party verification provider operating under contract with 33ed and subject to equivalent data protection standards.
• Legal and regulatory authorities: 33ed may disclose personal data to law enforcement agencies, financial intelligence units, or other competent authorities where required to do so by applicable law, a court order, or a lawful regulatory request. We will notify you of any such disclosure where we are legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of the 33ed business, personal data held on the platform may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections being maintained.

33ed uses cookies and similar tracking technologies on the platform to deliver core functionality, improve user experience, and gather anonymised performance analytics. Cookies are small text files placed on your device when you visit the platform. They do not contain executable code and cannot access other files on your device.

The following categories of cookies may be used on 33ed:

• Strictly necessary cookies: These are essential for the platform to function. They enable you to log in, maintain your session, navigate between pages, and use core features such as the bet slip and account dashboard. These cookies cannot be disabled without rendering the platform unusable.
• Functional cookies: These remember your preferences — such as your preferred language setting, odds format, and display preferences — so that the platform behaves as you have configured it across sessions.
• Analytics cookies: These collect anonymised data about how players interact with the platform — including which pages are visited most frequently and where users encounter issues — to help us improve platform performance and user experience. No personally identifiable information is included in analytics data.
• Security cookies: These help protect your account by detecting suspicious login behaviour and preventing cross-site request forgery (CSRF) attacks.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect platform functionality. Most modern browsers allow you to view, manage, and delete cookies via the browser's privacy or settings menu.

33ed retains personal data for as long as is necessary to fulfil the purpose for which it was collected, subject to any overriding legal obligations that require longer retention periods. The following general retention guidelines apply:

• Active account data: Retained for the full duration of the player's registered account on the platform and for a period of five (5) years following account closure, in accordance with standard financial record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years following the most recent transaction on the account, consistent with applicable anti-money laundering record-keeping obligations.
• Transaction records: Full deposit, withdrawal, and betting transaction histories are retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for a period of three (3) years from the date of the interaction, to support continuity of service and facilitate the resolution of any future disputes referencing past communications.
• Marketing consent records: Retained for the duration of the consent and for one (1) year following withdrawal of consent, to demonstrate compliance with consent-based marketing obligations.
• Technical and usage data: Aggregated and anonymised analytics data may be retained indefinitely. Identifiable technical data such as IP address logs is retained for a maximum of twelve (12) months.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with any individual player.

33ed implements a comprehensive set of technical and organisational security measures designed to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include but are not limited to:

• SSL/TLS encryption for all data in transit between player devices and the 33ed platform servers.
• Encryption of sensitive data at rest, including identity document files and financial transaction records stored in our databases.
• Role-based access controls ensuring that personal data is accessible only to authorised 33ed personnel with a demonstrable operational need.
• Regular security assessments, penetration testing, and vulnerability scanning of platform infrastructure.
• Multi-factor authentication requirements for all 33ed administrative system access.
• Secure, access-controlled data storage environments with physical and logical security controls.
• Staff training on data protection responsibilities and secure data-handling procedures.

While 33ed takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. Players are encouraged to take their own precautions — including using strong, unique passwords and enabling two-factor authentication on their 33ed accounts — to protect their account credentials.

As a player on the 33ed platform, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact the 33ed support team at [email protected] with a clear description of your request. We will acknowledge all rights requests within 48 hours and aim to respond substantively within ten (10) business days.

• Right of access: You have the right to request a copy of the personal data 33ed holds about you, along with information about how it is being processed and the purposes for which it is used.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held in your 33ed account or associated records.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful. Erasure requests are subject to any overriding legal retention obligations.
• Right to restrict processing: You have the right to request that processing of your personal data be suspended — for example, while the accuracy of your data is under dispute or while an objection to processing is being assessed.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling. You also have an absolute right to object to processing for direct marketing purposes, which we will action immediately upon receipt of your objection.
• Right to data portability: You have the right to receive a structured, machine-readable copy of personal data that you have provided to 33ed, where processing is based on consent or contractual necessity and is carried out by automated means.
• Right to withdraw consent: Where processing is based on your consent (such as marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place before the withdrawal.

33ed will not charge a fee for handling rights requests unless the request is manifestly unfounded or excessive in nature, in which case a reasonable administrative fee may be applied or the request may be refused. We will explain any such decision in writing.

The 33ed platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from anyone below this age. The registration process requires players to confirm their date of birth, and KYC verification is used to validate this declaration.

If 33ed discovers or is informed that a minor has successfully registered an account and provided personal data, we will immediately close the account, delete all associated personal data (subject only to any mandatory legal retention obligations in respect of financial records), and return any deposits made to the originating payment method. No winnings generated during underage access will be released.

If you are a parent or guardian and believe that a minor in your care has registered an account on 33ed, please contact the support team immediately at [email protected]. We will treat all such reports with urgency and full discretion.

The 33ed platform integrates third-party services — including game providers, payment processors, and identity verification tools — that operate under their own independent privacy policies. When you interact with these services through the 33ed interface, your data may be processed by those third parties in accordance with their own terms.

33ed does not control the data practices of third-party providers and is not responsible for their privacy policies or their compliance with applicable data protection law. We encourage you to review the privacy policies of the following categories of third-party provider whose services are embedded within or connected to the 33ed platform:

• Payment providers: bKash, Nagad, Rocket — each operating under their own published privacy policy and regulated by the Bangladesh Bank.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi — all holding independent gaming certifications and operating data processing practices governed by their respective licensing jurisdictions.

Where third parties are engaged as data processors (acting on 33ed's instructions), they are bound by data processing agreements that require them to maintain security standards equivalent to those applied by 33ed and to process personal data only as directed.

33ed reserves the right to amend this Privacy Policy at any time. When a material change is made — one that significantly affects how your personal data is collected, used, shared, or retained — we will notify you via the email address registered to your account at least seven (7) days before the change takes effect.

Minor amendments, such as clarifications to existing language or corrections of typographical errors that do not alter the substantive meaning of any provision, may be published without advance notice. The date of the most recent update is displayed at the top of this page.

We encourage you to review this Policy periodically to remain informed about how 33ed is protecting your data. Continued use of the platform following the publication of an updated Policy constitutes your acknowledgment of the changes. If you do not accept the revised Policy, you should discontinue use of the platform and contact support to request account closure.

If you have any questions, concerns, or complaints about this Privacy Policy or about the way 33ed handles your personal data, please contact the support team using the details below. All privacy-related communications should be addressed in English.

When submitting a data rights request, please include your registered username, the specific right you wish to exercise, and sufficient detail to allow us to identify and locate your personal data records. We may request proof of identity before actioning your request to protect against unauthorised access to player data.

If you are not satisfied with our response to your privacy complaint, you have the right to escalate your concern to the relevant data protection authority or to seek independent legal advice. 33ed will cooperate fully with any properly constituted formal regulatory investigation into our data handling practices.