Privacy Policy – How 33ed Protects Your Data

33ed ("the Platform", "we", "us", "our") is committed to protecting the privacy and personal data of all individuals who access or use the 33ed online casino and sports betting platform at https://33ed.club ("the Platform"). This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data.

This Policy applies to all visitors, registered Players, and any other individuals who interact with the 33ed platform, whether via mobile browser, desktop browser, or any other access method. This Policy should be read in conjunction with 33ed's Terms & Conditions, which govern the Player's use of the platform as a whole. In the event of any conflict between this Policy and the Terms & Conditions on a privacy matter, this Policy shall prevail.

33ed does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic or biometric data, health data, or data concerning a person's sexual orientation. In the event that any such data is incidentally provided by a Player (for example, as part of a KYC document that contains health information), 33ed will not process it for any purpose and will delete it as soon as practicable.

Primary Purposes

33ed uses the personal data it collects for the following primary purposes, all of which are necessary for the delivery of the platform's services:

• To create, verify, and manage your 33ed account, including processing your registration details and verifying your identity and age in accordance with our KYC obligations.
• To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, Mastercard, and any other payment method offered on the platform, and to maintain accurate transaction records.
• To deliver the gaming services you request, including cricket betting, live casino, slots, crash games, and all other wagering products available on the platform.
• To provide customer support, respond to your queries and complaints, and communicate platform updates, maintenance notices, or security alerts relevant to your account.
• To fulfil our responsible gaming obligations, including monitoring your gaming activity for signs of problem gambling, enforcing deposit limits and self-exclusion requests, and verifying compliance with the 21+ age requirement.
• To detect, investigate, and prevent fraudulent transactions, account misuse, money laundering, bonus abuse, and any other activities that violate 33ed's Terms & Conditions or applicable law.

Secondary Purposes

With your explicit consent, 33ed may also use your contact details to send you promotional communications about new games, bonuses, seasonal offers (for example, Eid or Pohela Boishakh promotions), and other platform updates that we believe may be of interest to you. You may withdraw this consent at any time by contacting 33ed support. Withdrawal of consent for marketing communications does not affect the processing of your data for the primary purposes described above, and does not entitle you to close your account or receive a refund of any deposits.

33ed processes personal data only where it has a valid legal basis to do so. The legal bases on which 33ed relies are:

• Contractual necessity: processing that is necessary to perform the contract between 33ed and the Player — specifically, the Terms & Conditions agreed to at the time of registration. This covers account creation, payment processing, game delivery, and customer support.
• Legal obligation: processing that is necessary for 33ed to comply with its legal obligations, including KYC/AML (anti-money laundering) obligations, age verification requirements, and responsible gaming regulatory requirements.
• Legitimate interests: processing for fraud prevention, platform security, abuse detection, and the improvement of platform performance, where those interests are not overridden by the Player's data protection rights.
• Consent: processing for marketing communications and the use of non-essential cookies, where consent has been explicitly provided by the Player and may be withdrawn at any time without affecting other processing activities.

Service Providers

33ed shares personal data with carefully selected third-party service providers who assist in the delivery of the platform's services. These include payment processing partners (bKash, Nagad, Rocket, Upay, and card payment processors), game software providers (Pragmatic Play, Evolution Gaming, Spribe, Ezugi, and others), identity verification and KYC service providers, customer support platform providers, and cloud infrastructure and hosting providers. All third-party service providers engaged by 33ed are contractually required to process personal data only for the specific purpose for which it is shared, to implement appropriate security measures, and to comply with applicable data protection requirements.

Legal Disclosure

33ed may disclose personal data to law enforcement agencies, regulatory bodies, financial intelligence units, or other competent authorities where required to do so by applicable law, court order, or regulatory obligation. 33ed will, where permitted by law and practicable in the circumstances, notify the affected Player of any such mandatory disclosure. Where notification is not permitted (for example, where disclosure is part of an active anti-money laundering investigation), 33ed will comply with the disclosure obligation without providing prior notice to the Player.

Business Transfers

In the event that 33ed undergoes a merger, acquisition, restructuring, or sale of all or a material part of its assets, personal data held by 33ed may be transferred to the acquiring entity as part of that transaction. 33ed will take reasonable steps to ensure that any such transfer is subject to appropriate privacy protections and that affected Players are notified of the change in data controller in accordance with applicable law.

33ed retains personal data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy. For active accounts, personal data is retained for the duration of the account relationship. Following account closure, 33ed is required by its legal and regulatory obligations to retain certain categories of data — including KYC documents, transaction records, and gaming activity logs — for a minimum period of five years from the date of account closure. This retention period reflects standard financial record-keeping and anti-money laundering requirements applicable to online gaming platforms operating in Bangladesh and internationally.

Personal data that is no longer required for any legitimate purpose is securely deleted or anonymised in accordance with 33ed's data deletion procedures. Where anonymisation is not technically practicable, 33ed applies appropriate pseudonymisation techniques to minimise the privacy impact of data held beyond the primary retention period.

33ed implements a multi-layered security architecture designed to protect personal data at rest and in transit. Access to personal data within the organisation is restricted on a strict need-to-know basis; only those personnel who require access to specific data categories to perform their job functions are granted access, and all such access is logged and auditable. Database access controls, data encryption at rest, network firewalls, intrusion detection systems, and regular security audits are all part of 33ed's data security framework.

In the event of a personal data breach that is likely to result in a high risk to the rights and freedoms of affected individuals, 33ed will notify affected Players without undue delay and will take all appropriate steps to contain and remedy the breach. 33ed will not be liable for any data security incidents arising from a Player's own failure to maintain the security of their account credentials — Players are responsible for keeping their passwords secure and for notifying 33ed immediately if they suspect their account has been accessed without authorisation.

Rights You Hold

Subject to applicable law and certain limited exceptions, you have the following rights in respect of the personal data that 33ed holds about you:

• Right of access: you may request a copy of the personal data that 33ed holds about you, together with information about how it is being used.
• Right of rectification: you may request that inaccurate or incomplete personal data held about you be corrected or completed without undue delay.
• Right of erasure: you may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to 33ed's legal retention obligations.
• Right to restrict processing: you may request that 33ed restricts the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or object to its processing.
• Right to object: you may object to the processing of your personal data where 33ed relies on legitimate interests as the legal basis for processing, and where your individual circumstances mean that the impact on you outweighs 33ed's legitimate interests.

Exercising Your Rights

To exercise any of the rights described above, please contact 33ed's support team using the email address provided in the Contact section of this Policy. 33ed will respond to all valid rights requests within a reasonable timeframe and in accordance with applicable data protection law. 33ed may need to verify your identity before processing a rights request; this is a necessary step to protect your personal data from being disclosed or altered by an unauthorised party. Where a rights request is refused, 33ed will provide a written explanation of the grounds for refusal and information about any available right of appeal.

33ed uses cookies and similar tracking technologies (collectively, "Cookies") to operate and improve the platform. Cookies are small text files placed on your device when you access the platform. 33ed uses the following categories of Cookies: (1) Strictly necessary Cookies, which are essential for the platform to function and cannot be disabled — these include session authentication tokens, security tokens, and load-balancing identifiers; (2) Functional Cookies, which remember your preferences (such as language settings) and improve your experience; (3) Analytics Cookies, which collect anonymised data about how Players use the platform, allowing 33ed to identify areas for improvement and optimise platform performance.

You may control non-essential Cookies through your device's browser settings. Please be aware that disabling certain Cookies may affect the functionality of the platform — in particular, disabling strictly necessary Cookies will prevent you from logging in or using core platform features. 33ed does not use third-party advertising Cookies or behavioural tracking Cookies that share your data with external advertising networks.

The 33ed platform is strictly intended for adults aged 21 and above. 33ed does not knowingly collect, process, or retain personal data from individuals under the age of 21. As part of its KYC process, 33ed requires all Players to verify their age before being permitted to deposit funds or place bets. If 33ed discovers that personal data has been collected from an individual under 21, it will immediately suspend the associated account, void all transactions, and permanently delete the personal data of the underage individual from its systems. Parents and guardians who believe that a minor may have created a 33ed account or accessed the platform should contact 33ed support immediately using the contact details provided in this Policy.

33ed reserves the right to update or amend this Privacy Policy at any time. When material changes are made, 33ed will update the "Last updated" date at the top of this page and, where practicable, will notify active Players via their registered mobile number or email address. Continued use of the 33ed platform following notification of a change to this Policy constitutes acceptance of the revised Policy. Players are encouraged to review this Policy periodically to stay informed about how their personal data is being protected. The most current version of this Policy is always available at https://33ed.club/privacy-policy.

If you have any questions about this Privacy Policy, wish to exercise any of your data protection rights, or have a concern about the way in which 33ed is handling your personal data, please contact our support team. We aim to respond to all privacy-related enquiries within 5 business days. All communications regarding this Policy should be directed to our official support email address.

Email: [email protected]