33hd Privacy Policy — How We Handle Your Data

1 Scope and Controller

This Privacy Policy applies to all personal data collected by 33hd in connection with the operation of the Platform, including data collected through the website, through payment processing systems, through customer support channels, and through any technical systems used to deliver the gaming services offered by 33hd.

33hd is the data controller for all personal data processed under this Privacy Policy. As data controller, 33hd determines the purposes and means of processing personal data and is responsible for ensuring that such processing is conducted lawfully, fairly, and transparently in accordance with applicable data protection principles.

2 Information We Collect

33hd collects personal information from players at the time of registration, during the course of account use, and through technical systems that support the Platform's operation. The categories of personal data we collect include:

• Identity information: full name, date of birth, national identity number or passport number where required for KYC verification.
• Contact information: Bangladeshi mobile phone number used for account registration and communication.
• Financial information: mobile wallet identifiers (bKash, Nagad, Rocket account numbers), transaction records, deposit and withdrawal histories.
• Technical information: IP address, device type, browser type and version, operating system, time zone, and session activity logs.
• Gaming activity: game history, bet records, win and loss records, session durations, and responsible gaming tool usage.
• Communications data: records of any messages, enquiries, or complaints submitted to 33hd through any support channel.

3 How We Use Your Information

33hd uses the personal data collected from players for the following purposes, each of which is necessary for the lawful and effective operation of the Platform:

• To create and manage your player account, including identity and age verification in compliance with applicable KYC requirements.
• To process deposits, withdrawals, and all financial transactions on the Platform through bKash, Nagad, Rocket, and other supported payment methods.
• To provide customer support, respond to enquiries, and resolve complaints submitted through any support channel.
• To detect and prevent fraud, money laundering, underage gambling, multi-accounting, and other prohibited activities on the Platform.
• To send service notifications, security alerts, and promotional communications to players who have opted in to receive such communications.

4 Legal Basis for Processing

33hd processes personal data on the following legal bases: (a) performance of a contract — processing necessary to fulfil the agreement between 33hd and the player, including account management, game delivery, and payment processing; (b) legal obligation — processing required to comply with applicable laws including anti-money laundering obligations and age verification requirements; (c) legitimate interests — processing necessary for fraud prevention, security monitoring, and platform integrity; and (d) consent — for optional marketing communications, where you have given explicit consent that may be withdrawn at any time.

Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent for optional marketing communications will not affect your ability to use the core Platform services.

5 Sharing of Personal Data

33hd does not sell, rent, or trade personal data to any third party for commercial or marketing purposes. Personal data may be shared with third parties only in the following limited circumstances:

• Payment processors: bKash, Nagad, Rocket, and other payment service providers receive the minimum data necessary to process your financial transactions on the Platform.
• Game providers: technology providers whose games are hosted on the Platform may receive technical data necessary for game delivery and fairness auditing, such as session tokens and anonymised bet data.
• Legal and regulatory authorities: 33hd may be required to disclose personal data to law enforcement or regulatory bodies where legally compelled to do so.
• Fraud prevention services: anonymised or aggregated data may be shared with fraud detection and responsible gaming service providers to protect the Platform and its players.

6 Cookies and Tracking Technologies

33hd uses cookies and similar tracking technologies to operate the Platform effectively. Cookies are small data files placed on your device that allow 33hd to recognise your device across sessions, maintain your login state, remember your preferences, and collect analytics data that helps us improve Platform performance and user experience. The types of cookies used include strictly necessary cookies (required for the Platform to function), functional cookies (which remember your settings and preferences), and analytics cookies (which provide aggregated data about how players navigate and use the Platform).

You may manage or disable non-essential cookies through your browser settings at any time. However, disabling strictly necessary cookies may impair your ability to use certain features of the Platform. 33hd does not use cookies to track your activity on third-party websites or to serve you personalised advertising on external platforms.

7 Your Data Rights

As a player whose personal data is processed by 33hd, you hold the following rights in relation to your data. To exercise any of these rights, contact 33hd support at [email protected]. We will respond to verified requests within a reasonable timeframe:

• Right of access: you may request a copy of the personal data 33hd holds about you, along with information about how it is used.
• Right of rectification: if any personal data held about you is inaccurate or incomplete, you may request that it be corrected or updated.
• Right to erasure: in certain circumstances, you may request that your personal data be deleted. This right is subject to 33hd's legal obligations to retain certain categories of data (for example, transaction records required for anti-money laundering compliance).
• Right to restrict processing: you may request that 33hd restricts the processing of your personal data in certain circumstances, for example while a rectification request is being assessed.
• Right to withdraw consent: where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

8 Data Retention

33hd retains personal data for as long as it is necessary to fulfil the purposes for which it was collected, including for the duration of the player's account and for any period required by applicable law thereafter. Specifically: account registration data and KYC documents are retained for the lifetime of the account plus a minimum of five years following account closure; transaction records are retained for a minimum of five years to satisfy anti-money laundering record-keeping requirements; gaming history and session logs are retained for a minimum of two years; and support communications are retained for a minimum of one year.

Once personal data is no longer required, 33hd will securely delete or anonymise it. Where full deletion is not immediately possible due to technical constraints or legal obligations, data will be isolated from active processing until deletion can be completed.

9 Security Measures

33hd implements a range of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL (Secure Socket Layer) encryption for all data transmitted between your device and the Platform.
• Encrypted storage for sensitive personal data, including payment identifiers and identity documents.
• Strict access controls limiting staff access to personal data on a need-to-know basis, with all access logged and auditable.
• Regular security reviews and vulnerability assessments of the Platform's technical infrastructure.

10 Changes to This Privacy Policy

33hd reserves the right to update or amend this Privacy Policy at any time. When material changes are made to this Policy, 33hd will notify registered players by displaying a prominent notice on the Platform or by sending a notification to the player's registered mobile number. The effective date shown at the top of the Policy will be updated to reflect the date on which the revised version takes effect.

Your continued use of the Platform following any amendment to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the revised Privacy Policy, you must cease using the Platform and may request account closure by contacting support at [email protected].

11 Contact and Data Requests

If you have any questions or concerns about this Privacy Policy, or if you wish to exercise any of your data rights described in this Policy, please contact the 33hd support team. All privacy-related enquiries should be directed to: [email protected] (plain text — not a clickable link). Please include your registered mobile number and a description of your request so that we can verify your identity and respond efficiently.

33hd aims to respond to all verified data subject requests within 30 calendar days. 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 within the initial 30-day window.

12 Governing Law

This Privacy Policy and any disputes arising in connection with it shall be governed by applicable law. 33hd is committed to handling all personal data in a manner consistent with recognised data protection principles, including purpose limitation, data minimisation, accuracy, storage limitation, integrity, confidentiality, and accountability.

13 Language of This Policy

This Privacy Policy is prepared and presented in the English language. In the event of any discrepancy between the English version of this Policy and any translated version, the English version shall prevail and be the authoritative text for all purposes.

Entire Policy