33pq Privacy Policy — How We Handle Your Personal Data

33pq ("we", "us", "our", "the Company") is committed to protecting the privacy and personal data of every individual who interacts with our Platform. This Privacy Policy sets out in clear, plain English the basis on which we collect, store, use, and disclose the personal data of our players, visitors, and prospective customers located in Bangladesh and elsewhere.

This policy has been written in accordance with internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, integrity and confidentiality, and accountability. While Bangladesh does not yet have a single comprehensive data protection statute equivalent to the EU's GDPR, 33pq voluntarily upholds these principles as a matter of best practice and player trust.

This Privacy Policy should be read alongside the 33pq Terms & Conditions and Responsible Gaming Policy, both of which are available on this website. Where there is any conflict between this policy and the Terms & Conditions on a privacy-related matter, this Privacy Policy shall take precedence.

We collect personal data through several channels: directly from you when you register an account or contact support, automatically through your use of the Platform, and from third-party service providers involved in payment processing and identity verification. The categories of data we collect include:

Category	Examples	Collection Method
Identity Data	Full legal name, date of birth, national ID number, passport number	Registration form, KYC upload
Contact Data	Mobile phone number, email address, residential address	Registration form, account settings
Financial Data	bKash/Nagad/Rocket account number, Visa/Mastercard last 4 digits, transaction history	Payment processor, deposit/withdrawal records
Technical Data	IP address, device type, browser type and version, operating system, session timestamps	Automatic collection via server logs and analytics
Usage Data	Pages visited, games played, bets placed, session duration, in-platform navigation paths	Platform analytics and game provider data feeds
Communications Data	Live chat transcripts, WhatsApp messages to support, email correspondence	Support platform logs
Marketing Preferences	Opt-in/opt-out status for promotional communications, preferred contact channel	Account settings, support requests

We do not collect or process special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless required by law or expressly consented to by you for a specific purpose.

33pq uses the personal data we collect only for the purposes described in this policy. We will never use your data in a way that is incompatible with the purpose for which it was originally collected without first seeking your consent. The primary purposes for which we process your data are:

• Account creation and management: To register your account, verify your identity, maintain your account profile, and communicate essential account-related information to you.
• Payment processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard; to reconcile transactions; and to investigate payment disputes.
• Identity verification (KYC): To verify that you meet the minimum age requirement of 21 years, confirm your identity and address, and comply with our anti-money laundering obligations.
• Platform personalisation: To tailor your experience on 33pq, including displaying relevant promotions, recommending games, and setting language and currency preferences.
• Customer support: To respond to your enquiries, resolve complaints, provide technical assistance, and maintain a record of your support history for quality and training purposes.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, bonus abuse, and other prohibited conduct on the Platform.
• Regulatory compliance: To fulfil our legal obligations, respond to lawful requests from government authorities, and cooperate with law enforcement investigations where required.
• Platform improvement: To analyse aggregate usage data, identify technical issues, improve game performance, and enhance the overall user experience on 33pq.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications.

Every instance of personal data processing at 33pq rests on at least one of the following legal bases:

• Contractual necessity: Processing that is required to fulfil the agreement between you and 33pq, including account management, payment processing, and KYC verification.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and responses to lawful authority requests.
• Legitimate interests: Processing necessary for the legitimate interests of 33pq, such as fraud prevention, platform security, and service improvement, provided those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, informed, and specific consent — most notably for marketing communications and optional analytics cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

33pq does not sell, rent, or trade your personal data. We share data only where strictly necessary and under binding contractual obligations that require the recipient to protect your data to at least the same standard as 33pq. The categories of third parties with whom we may share your personal data are:

• Payment service providers: bKash, Nagad, Rocket, Upay, and card processing partners receive the minimum financial data necessary to execute and verify your transactions. These providers are independently regulated and maintain their own privacy and security standards.
• Identity verification services: Third-party KYC and anti-money laundering service providers that process your identity documents and biographic data to confirm your eligibility to use the Platform.
• Game technology providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive pseudonymised session and game-play data necessary to deliver their games through the 33pq Platform.
• Analytics providers: Aggregated, anonymised usage data may be shared with platform analytics services to help us understand how players use 33pq and identify areas for improvement. No personally identifiable information is shared for analytics purposes.
• Law enforcement and regulatory authorities: We will disclose personal data to law enforcement agencies, courts, or regulatory bodies where we are legally required to do so or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of 33pq, our players, or the public.

We do not transfer personal data to countries outside Bangladesh unless equivalent data protection safeguards are in place. Where international transfers are necessary (for example, to cloud infrastructure providers or game studios operating outside Bangladesh), we ensure that appropriate contractual protections govern such transfers.

33pq uses cookies — small text files stored on your device — and similar tracking technologies to ensure the Platform functions correctly, to understand how it is used, and to improve your experience. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without preventing you from using the Platform. No consent is required for these cookies.
• Performance and analytics cookies: These cookies collect anonymised information about how players navigate the Platform — which pages are visited most, how long sessions last, and where errors occur. This data is used exclusively to improve Platform performance. These cookies are only placed with your consent.
• Functionality cookies: These remember your preferences — such as language settings and game display options — so you do not have to reconfigure them on each visit. These cookies are only placed with your consent.
• Marketing and personalisation cookies: Where you have consented, these cookies allow us to display promotions and content that are more relevant to your interests based on your platform activity. We do not use third-party advertising networks or share cookie data with advertisers.

You can manage your cookie preferences through your browser settings at any time. Blocking strictly necessary cookies will impair the functionality of the Platform. Blocking other categories of cookies will not prevent you from accessing the Platform but may reduce the quality of your experience.

33pq retains personal data only for as long as is necessary for the purposes for which it was collected, taking into account applicable legal retention requirements. Our standard retention periods are as follows:

• Account and identity data: Retained for the lifetime of your account and for a minimum of 5 years following account closure, in accordance with anti-money laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of 7 years following each transaction, in accordance with financial record-keeping requirements applicable in Bangladesh.
• KYC verification documents: Retained for a minimum of 5 years following the completion of verification or account closure, whichever is later.
• Customer support communications: Retained for 3 years from the date of the most recent interaction, to support quality assurance and dispute resolution.
• Technical and usage data: Retained in aggregated or anonymised form indefinitely for platform analytics purposes. Raw IP and session log data is retained for a maximum of 12 months.
• Marketing consent records: Retained for the duration of your consent and for 2 years following any withdrawal of consent, to demonstrate compliance with our marketing obligations.

At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where deletion is not technically feasible within a standard timeframe, we ensure the data is isolated from active processing until deletion can be completed.

As a player on the 33pq Platform, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team via live chat or at the email address shown in Section 13 of this policy.

• Right of access: You may request a copy of all personal data we hold about you, along with information about how it is used and with whom it is shared. We will respond within 30 days of receiving a valid request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
• Right to erasure: You may request that we delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where you object to processing based on legitimate interests and we have no overriding legitimate grounds. Note that legal retention obligations may prevent us from deleting certain categories of data immediately.
• Right to restriction of processing: You may request that we restrict the processing of your personal data in certain circumstances, such as while you contest the accuracy of data we hold or while an objection is being considered.
• Right to data portability: Where processing is based on your consent or on a contract, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling, at any time. You also have an absolute right to object to processing for direct marketing purposes at any time.
• 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 prior to withdrawal.

The 33pq Platform is strictly for adults aged 21 years and above. We do not knowingly collect, process, or store personal data relating to any person under the age of 21. If we become aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and permanently close the associated account.

If you believe that a minor may have registered an account on 33pq or that we may hold personal data relating to a person under 21, please contact our support team immediately via live chat or at the email address in Section 13. We treat all such reports as urgent and will investigate within 24 hours of receipt.

33pq may send you promotional emails, SMS messages, and in-platform notifications about bonuses, new games, seasonal offers (such as Eid promotions, Pohela Boishakh offers, and BPL cricket specials), and platform updates — but only where you have given your explicit, informed consent at registration or through your account settings.

You can opt out of receiving marketing communications at any time by:

• Clicking the "unsubscribe" link included in any marketing email we send you.
• Updating your communication preferences in your account settings.
• Contacting our support team directly via live chat or the email address in Section 13, and requesting removal from all marketing lists.

Opting out of marketing communications does not affect your ability to use the Platform, receive essential transactional communications (such as deposit confirmations, withdrawal notifications, or account security alerts), or access standard account bonuses. We will process all opt-out requests within 5 business days.

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

• Transport security: All data transmitted between your device and the 33pq Platform is encrypted using TLS 1.3 with 256-bit AES encryption. HTTP connections are automatically redirected to HTTPS.
• At-rest encryption: Personal data stored in our databases is encrypted at rest using AES-256 encryption. Encryption keys are managed through a dedicated key management service with strict access controls.
• Access controls: Access to personal data is restricted on a need-to-know basis. All staff with access to personal data undergo background checks and receive regular data protection training. Access is logged and audited.
• Two-factor authentication: All internal systems containing personal data require two-factor authentication for staff access. We also offer SMS-based 2FA to players for their own accounts.
• Vulnerability management: The 33pq Platform undergoes regular security assessments, penetration testing, and code reviews conducted by qualified security professionals.
• Incident response: We maintain a documented data breach response procedure. In the event of a confirmed data breach that poses a risk to your rights and interests, we will notify affected players as promptly as possible and take immediate steps to contain the breach and mitigate its impact.

While we take every reasonable precaution to protect your data, no platform is 100% immune to security threats. You are responsible for maintaining the security of your own account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

33pq reserves the right to update or revise this Privacy Policy at any time in response to changes in applicable law, our data processing practices, or the services we offer. When we make material changes to this policy, we will notify registered players by email to the address associated with their account and by posting a prominent notice on the Platform for a period of not less than 14 days before the changes take effect.

The "Effective Date" shown at the top of this policy reflects the date on which the current version came into force. We encourage you to review this policy periodically to stay informed about how 33pq protects your personal data. Your continued use of the Platform following notification of any changes constitutes your acceptance of the updated policy.

Previous versions of this Privacy Policy are available on request by contacting our support team via the details in Section 13.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a complaint about the way 33pq has handled your personal data, please contact us using any of the following methods:

• Email: [email protected] (plain text — not a clickable link)
• WhatsApp: +880 1700 000 033
• Live Chat: Available 24/7 directly on the Platform
• Support hours: Bangladesh Standard Time (UTC+6), 24 hours a day, 7 days a week

We aim to acknowledge all privacy-related requests within 2 business days and to resolve them fully within 30 calendar days. For complex requests, we may extend this period by up to a further 30 days, in which case we will notify you of the extension and the reasons for it before the initial 30-day period expires.

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority or to seek a remedy through the courts of Bangladesh.