33db Privacy Policy — How We Handle Your Personal Data

1.1 Data Controller. For the purposes of this Privacy Policy, "33db", "we", "us", and "our" refers to the operating entity responsible for the 33db online betting and casino platform accessible at 33db.lat. 33db acts as the data controller in respect of all personal data collected from players and visitors to the platform.

1.2 Scope of This Policy. This Privacy Policy applies to all personal data collected by 33db through: (a) the 33db website and any mobile-optimised version thereof; (b) the account registration and login process; (c) deposit and withdrawal transactions; (d) use of live chat, email, and other support channels; (e) participation in promotions, tournaments, and loyalty programmes; and (f) any other interaction between you and 33db where personal data is provided or collected.

1.3 Contact. Questions relating to this Privacy Policy or to the processing of your personal data should be directed to the 33db support team. Contact details are provided in Section 13 of this policy.

33db collects the following categories of personal data:

We do not intentionally collect any special categories of sensitive personal data (such as health data, biometric data, racial or ethnic origin, religious beliefs, or political opinions) unless you voluntarily provide such information in the context of a support communication, in which case it will be handled with the highest level of care and used solely to address your query.

3.1 Directly From You. The majority of personal data 33db holds is provided directly by you in the course of: completing the account registration form; submitting identity verification documents; initiating deposits or withdrawal requests; contacting the support team via live chat or email; or updating your account preferences.

3.2 Automatically. When you visit the 33db website, certain Technical Data is collected automatically through server logs, cookies, and similar tracking technologies, regardless of whether you are logged in to an account. This automatic collection is described in detail in Section 6 (Cookies and Tracking Technologies).

3.3 From Payment Processors. When you initiate a deposit or withdrawal, 33db receives confirmation data from the relevant payment processor (such as bKash, Nagad, Rocket, or Upay). This confirmation data may include your registered mobile wallet number and the transaction reference, but 33db does not have access to your mobile banking PIN, password, or full bank account credentials.

3.4 From Identity Verification Services. 33db may use third-party identity verification services to assist with KYC compliance. These services compare the information and documents you submit against authoritative databases to confirm your identity. Any data shared with these services is subject to strict contractual confidentiality obligations.

3.5 From Game Content Providers. Game studios supplying content to the 33db platform (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) may log in-game technical data such as game session IDs and round results for audit and fair-play purposes. This data is shared with 33db in aggregated or pseudonymised form and is used solely for account management and dispute resolution.

33db processes your personal data for the following purposes, each grounded in a recognised legal basis:

• Account creation and management — Processing is necessary to perform the contract between you and 33db (i.e., to provide you with access to the platform and its services). Without your identity and contact data, we cannot open or maintain your account.
• Payment processing — Processing financial data is necessary to perform the contract (to receive deposits and pay out withdrawals) and to comply with anti-money laundering legal obligations that require us to verify the source and destination of funds.
• Identity verification (KYC) — Processing document and identity data is a legal obligation under applicable anti-money laundering and know-your-customer regulations. This processing cannot be declined without affecting your ability to use financial features of the platform.
• Fraud detection and platform security — Processing Technical Data and Account Activity Data for fraud prevention and security purposes is justified by 33db's legitimate interest in protecting the integrity of the platform and the interests of all players, as well as by legal obligations to prevent financial crime.
• Customer support — Processing Communication Data to respond to your support queries is necessary to perform the contract and to fulfil our legitimate interest in providing a high quality of service.
• Responsible gaming compliance — Processing account activity data to monitor for signs of problem gambling and to apply self-imposed limits or exclusions is necessary both to comply with responsible gaming obligations and to protect players' vital interests.
• Marketing communications — Sending promotional emails, SMS notifications, and in-platform offers is based solely on your freely given consent. You may withdraw this consent at any time from your account preferences or by contacting support.
• Platform analytics and improvement — Processing Technical Data and anonymised usage data to understand how the platform is used and to improve its features is justified by 33db's legitimate interest in developing and maintaining a high-quality service.
• Legal and regulatory compliance — Retaining certain categories of data beyond the life of your account is a legal obligation that overrides any individual request for deletion where statutory retention periods apply.

5.1 No Sale of Data. 33db does not sell, rent, or lease personal data to any third party. Data sharing takes place only in the circumstances described below and only to the minimum extent necessary.

5.2 Payment Service Providers. To process deposits and withdrawals, 33db shares relevant financial and identity data with the payment service provider handling each specific transaction (e.g., bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, Visa, Mastercard). Each payment provider operates under its own privacy policy and is independently responsible for data it receives in its capacity as payment processor.

5.3 Identity Verification and KYC Partners. Where 33db engages a third-party identity verification service to assist with KYC, the personal data and documents required for that verification are shared with that service under a strict data processing agreement. The service may not use your data for any purpose other than verifying your identity for 33db.

5.4 Game Content Providers. Game studios supplying content to the platform receive the minimum technical data needed to initiate and record game sessions (typically a pseudonymised session identifier and stake/result data). Personal identifying information such as your name or address is not passed to game studios.

5.5 Technology and Infrastructure Providers. 33db uses third-party cloud hosting, analytics, and security service providers to operate the platform. These providers act as data processors under contracts that prohibit them from using your data for their own purposes and require them to maintain security standards equivalent to those applied by 33db.

5.6 Legal and Regulatory Disclosure. 33db may be required by law, court order, or regulatory directive to disclose personal data to law enforcement agencies, financial intelligence units, or other competent authorities without prior notice to the affected player. 33db will comply with all valid legal requests and will notify affected players of such disclosures only where permitted by law to do so.

5.7 Business Transfers. In the event of a merger, acquisition, restructuring, or sale of all or part of 33db's business, personal data held by 33db may be transferred to the acquiring or successor entity as part of that transaction. Players will be notified of any such transfer and of any material changes to data handling practices that result from it.

6.1 What Are Cookies. Cookies are small text files placed on your device by a website you visit. They serve a range of functions from keeping you logged in, to remembering your preferences, to helping 33db understand how the platform is being used so it can be improved.

6.2 Categories of Cookies Used by 33db.

• Strictly Necessary Cookies: These cookies are essential for the 33db platform to function. They manage your login session, maintain your basket of placed bets, and ensure that security features operate correctly. These cookies cannot be disabled without making the platform non-functional.
• Functional Cookies: These cookies remember choices you make on the platform — such as your preferred display language — so you do not have to reset your preferences each time you visit. Disabling these cookies may result in a degraded user experience.
• Analytics Cookies: These cookies collect anonymised or pseudonymised data about how visitors use the 33db website, including pages viewed, session duration, and navigation paths. This information helps 33db identify and fix usability problems and prioritise platform improvements. Analytics data is not used to identify individual users.
• Security and Fraud Prevention Cookies: These cookies help 33db detect and prevent suspicious activity, including automated bot access and multi-account fraud. They are a core component of the platform's anti-fraud infrastructure.

6.3 Managing Cookies. You can manage or disable cookies through your browser settings. Please be aware that disabling strictly necessary cookies will prevent you from logging in to your 33db account and will make the platform non-operational. Instructions for managing cookies in the most commonly used browsers are available via the respective browser's help documentation.

6.4 No Third-Party Advertising Cookies. 33db does not allow third-party advertising networks to place tracking or retargeting cookies on the 33db platform. We do not use your browsing behaviour to serve you targeted advertising on other websites.

7.1 General Principle. 33db retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or for as long as required by applicable law. Once the relevant retention period expires, data is securely deleted or irreversibly anonymised.

7.2 Retention Schedule.

7.3 Deletion Requests. Where a player requests deletion of their personal data and no statutory retention obligation applies to that data, 33db will process the deletion request within 30 days of receipt. Where statutory retention obligations prevent full deletion, 33db will notify the player of which specific data categories must be retained, the applicable retention period, and the legal basis for that retention.

8.1 Technical Measures. 33db implements the following technical security measures to protect personal data:

• SSL/TLS encryption on all data transmissions between users and the 33db platform
• Encryption of sensitive data at rest within 33db's database infrastructure
• Multi-factor authentication requirements for all internal staff accounts with access to player personal data
• Regular automated vulnerability scanning and penetration testing of platform infrastructure
• Firewall and intrusion detection systems monitoring all inbound and outbound network traffic
• Access controls implementing the principle of least privilege, ensuring staff can only access the personal data necessary for their specific role

8.2 Organisational Measures. In addition to technical controls, 33db applies the following organisational measures:

• All staff with access to personal data are bound by confidentiality obligations in their employment or service contracts
• Data protection training is provided to all relevant staff upon onboarding and updated annually
• Third-party service providers with access to personal data are subject to data processing agreements that require equivalent security standards
• A documented data breach response procedure is in place to ensure prompt identification, containment, and notification in the event of a security incident

8.3 Data Breach Notification. In the event of a personal data breach that is likely to result in a high risk to affected individuals, 33db will notify affected players without undue delay and will take all reasonable steps to mitigate the impact of the breach. Players will be notified via the email address registered to their 33db account.

8.4 Player Responsibility. While 33db applies robust security measures, players are also responsible for maintaining the security of their account credentials. You must keep your password confidential, not share your login details with any third party, and contact the 33db support team immediately if you suspect unauthorised access to your account.

As a player whose personal data is processed by 33db, you have the following rights in relation to that data:

• Right of Access: You may request a copy of all personal data that 33db holds about you. 33db will provide this information in a structured, commonly used, and machine-readable format within 30 days of receiving a valid request.
• Right to Rectification: If any personal data held by 33db about you is inaccurate or incomplete, you have the right to request that it be corrected. Many items of account data (such as your contact email or phone number) can be updated directly from within your account settings.
• Right to Erasure: You may request that 33db delete personal data it holds about you. This right is subject to limitations where retention is required by law (see Section 7). Where erasure is possible, it will be completed within 30 days.
• Right to Restriction of Processing: You may request that 33db restrict its processing of your personal data in certain circumstances — for example, while a dispute about data accuracy is being resolved. During a restriction period, 33db will continue to store the data but will not actively process it beyond storage.
• Right to Data Portability: For data that you have provided directly to 33db and that is processed on the basis of your consent or contract performance, you may request that 33db provide you with that data in a portable, machine-readable format so that it can be transferred to another service provider if you wish.
• Right to Object: You may object to 33db's processing of your personal data where that processing is based on legitimate interests. You also have an unconditional right to object to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where processing is based on your consent (principally marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, please contact the 33db support team using the contact details in Section 13. 33db will verify your identity before processing any data rights request to ensure we do not inadvertently disclose or delete another person's data.

10.1 Strict 21+ Policy. The 33db platform is strictly for adults aged 21 years and over. We do not knowingly collect personal data from any individual under the age of 21. The account registration process includes an age declaration, and KYC verification is used to confirm that players meet the minimum age requirement.

10.2 Discovery of Underage Registration. If 33db discovers or is informed that personal data has been collected from an individual under the age of 21, we will immediately suspend the relevant account, refund any deposits made (net of any withdrawals already paid), and permanently delete all personal data associated with that account as soon as any legal obligations relating to the transaction records have been satisfied.

10.3 Parental Guidance. Parents and guardians who are concerned that a minor may have accessed the 33db platform are encouraged to contact the support team at [email protected] immediately. We will investigate and act without delay. We also encourage use of parental control software to restrict access to gambling websites on shared or family devices.

11.1 External Links. The 33db platform does not contain links to external third-party websites for commercial or affiliate purposes. Any navigation links present on the platform direct users to internal 33db pages only.

11.2 Third-Party Game Content. Games hosted on the 33db platform but developed by third-party studios (including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) are delivered via iframe or API integration. While 33db takes reasonable steps to ensure these integrations are secure, the game content itself is subject to the intellectual property and technical infrastructure of the respective studio. 33db is not responsible for the independent data practices of game studios in relation to game-level session data they process on their own systems.

11.3 Payment Provider Interfaces. When you initiate a deposit or withdrawal via a mobile wallet provider such as bKash or Nagad, you will interact with that provider's own authentication interface. Your interaction with that interface is governed by the respective payment provider's own privacy policy. 33db does not have visibility of the credentials or PIN you enter within those interfaces.

12.1 Right to Update. 33db reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, updates to the platform's features and services, or changes in applicable legal or regulatory requirements. All updates will be made in good faith and with the aim of maintaining or improving the level of protection afforded to your personal data.

12.2 Notification of Material Changes. Where a change to this Privacy Policy is material — meaning it meaningfully affects how your personal data is collected, used, or shared — 33db will notify registered players via the email address associated with their account at least 7 days before the updated policy takes effect. Non-material changes such as typographical corrections, clarifications that do not alter the substance of any provision, or updates to contact details may be made without advance notice.

12.3 Continued Use as Acceptance. Your continued use of the 33db platform after the effective date of any updated Privacy Policy constitutes your acceptance of the updated policy in its entirety. If you do not agree with the updated Privacy Policy, you must cease using the platform and may request account closure in accordance with the account closure provisions in the 33db Terms & Conditions.

12.4 Version Control. The current version of this Privacy Policy is always accessible on this page. The "Last updated" date displayed at the top of this document reflects the date on which the most recent version came into effect. Prior versions of this policy are available upon request by contacting the support team.

If you wish to exercise any of your data rights as described in Section 9, or if you have any questions, concerns, or complaints regarding this Privacy Policy or the way 33db handles your personal data, please contact the 33db data support team through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line for Data Requests: "Data Rights Request — [Your Account Username]"
• Live Chat: Available 24/7 via the chat widget on the 33db platform
• Response Time: Data rights requests acknowledged within 2 business days; substantive response within 30 days (Bangladesh Standard Time, UTC+6)

When submitting a data rights request, please provide your registered account username and the email address associated with your 33db account so that we can verify your identity efficiently. 33db will not process a data rights request where we are unable to confirm the identity of the requester to a reasonable standard.

For responsible gaming-related requests — including self-exclusion, deposit limit adjustments, or account closure on responsible gaming grounds — please clearly state the nature of your request in your initial message so that it can be escalated to the appropriate team without delay. Responsible gaming requests are treated as a priority and will receive an initial response within 24 hours.