35bdd Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1 Introduction

35bdd is committed to handling your personal data with transparency, integrity, and care. This Privacy Policy sets out the full scope of our data practices — what we collect, how we collect it, why we use it, who we share it with, how long we keep it, and what rights you have over it. We encourage you to read this Policy carefully before registering an account or using any 35bdd service.

35bdd operates as a safe and reliable online gaming platform primarily serving players in Bangladesh. All personal data processing described in this Policy is conducted in accordance with applicable data protection principles, including purpose limitation, data minimisation, storage limitation, and integrity and confidentiality standards.

If you have any questions about this Policy or about how 35bdd handles your personal data, contact us at [email protected] at any time. Our data team responds to privacy-related enquiries within 5 business days.

2 Data We Collect

35bdd collects personal data in two main categories: data you provide directly, and data we collect automatically through your use of the platform. The table below summarises the specific types of data collected in each category.

35bdd does not collect or store sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health records (other than responsible gaming self-disclosures made directly by you), or biometric data beyond that required for KYC liveness checks conducted by our certified verification partner.

3 How We Collect Your Data

35bdd collects personal data through the following channels:

Direct Collection

• Registration form: You provide name, mobile number, and date of birth when creating your 35bdd account.
• KYC submission: You upload identity documents when identity verification is required or requested.
• Cashier interactions: Payment details are entered by you when initiating deposits or requesting withdrawals through the MFS-connected cashier.
• Support channels: You provide information when contacting 35bdd via email at [email protected] or through the in-platform live chat feature.

Automatic Collection

• Server logs: Our servers automatically record your IP address, browser type, referring URL, and timestamps of each platform request.
• Cookies and local storage: Essential session cookies are set when you log in to maintain your authenticated session. Functional cookies store platform preferences such as language and display settings. No third-party advertising cookies are used on 35bdd.
• Game engine telemetry: Game providers (Pragmatic Play, Evolution Gaming, Spribe, Ezugi, Microgaming, NetEnt, and others) log bet and result data as part of their certified RNG audit trail. This data is accessible to 35bdd for dispute resolution and responsible gaming monitoring purposes.

Third-Party Sources

• KYC verification partners: Our identity verification service may cross-reference submitted documents against third-party databases to confirm authenticity and age eligibility.
• MFS providers: bKash, Nagad, Rocket, and Upay confirm transaction status and may provide transaction metadata as part of the payment processing workflow.
• Fraud prevention services: 35bdd uses automated fraud detection systems that may process device fingerprint data and behavioural analytics to identify suspicious account activity.

4 Why We Use Your Data

Every category of data 35bdd collects is used for one or more specific, documented purposes. We do not use personal data for purposes that are incompatible with those stated at the time of collection. Our processing purposes and the corresponding legal basis for each are as follows:

• Account creation and management — to register your account, authenticate your identity, maintain your player profile, and provide access to platform features. Legal basis: contractual necessity.
• Payment processing — to process deposits and withdrawals via your chosen MFS channel, reconcile transactions, and maintain financial records. Legal basis: contractual necessity and legal obligation.
• Age and identity verification (KYC) — to confirm that you meet the 21+ age requirement and to satisfy anti-money laundering obligations. Legal basis: legal obligation.
• Responsible gaming monitoring — to track gameplay patterns, enforce deposit and loss limits, detect signs of problem gambling behaviour, and action self-exclusion requests. Legal basis: contractual necessity and legitimate interest in player welfare.
• Fraud and security monitoring — to detect and prevent unauthorised account access, bonus abuse, collusion, money laundering, and other prohibited conduct. Legal basis: legitimate interest and legal obligation.
• Customer support — to respond to your enquiries, investigate disputes, and maintain records of communications for quality assurance. Legal basis: contractual necessity.
• Platform improvement — to analyse aggregated, anonymised usage patterns to improve platform performance, game selection, and user experience. Legal basis: legitimate interest.
• Promotional communications — to send you details of bonuses, promotions, and platform updates where you have opted in to receive such communications. Legal basis: consent (which you may withdraw at any time).

5 Sharing Your Data

35bdd does not sell, rent, or trade your personal data. We share data only in the following specific circumstances and only to the minimum extent necessary for the stated purpose:

• KYC and identity verification partners: We share your submitted identity documents and registration details with our certified KYC verification provider solely for the purpose of confirming your age and identity. The KYC provider processes data under contractual obligations that require it to maintain equivalent data protection standards.
• MFS payment processors: Transaction data (amount, timestamp, your registered MFS number) is shared with bKash, Nagad, Rocket, Upay, and other payment processors as required to initiate and complete deposit and withdrawal transactions. These providers operate under their own published privacy terms, which you are encouraged to review.
• Certified game providers: Bet and gameplay data is shared with game studios (Pragmatic Play, Evolution Gaming, Spribe, Ezugi, Microgaming, NetEnt, and others) as part of the technical integration required to deliver their games and maintain RNG audit trails. Game providers do not receive your financial or identity data beyond a pseudonymous player ID.
• Fraud prevention and security services: Device and behavioural data may be shared with fraud detection service providers for the purpose of identifying and preventing financial crime. These services process data under strict confidentiality agreements.
• Legal and regulatory authorities: 35bdd will disclose personal data to law enforcement agencies, financial intelligence units, or courts when required to do so by applicable law or a valid legal order. We will notify affected players of such disclosures where we are legally permitted to do so.
• Business transfers: In the event that 35bdd undergoes a merger, acquisition, or sale of substantially all its assets, your personal data may be transferred to the successor entity. You will be notified of any such transfer and of any material change to your data protection rights as a result.

6 Cookies and Tracking Technologies

35bdd uses a minimal set of cookies to operate the platform effectively. We do not use third-party tracking cookies, advertising pixels, or cross-site tracking technologies. The cookies we use fall into two categories:

Essential Cookies

These cookies are strictly necessary for the 35bdd platform to function. They cannot be disabled without breaking core functionality such as maintaining your logged-in session, remembering your cashier selections within a session, and enabling platform security features. Essential cookies are set by 35bdd's own servers and are not accessible to third parties.

Functional Cookies

These cookies remember your optional preferences to improve your experience on return visits. Examples include your preferred display language (English), notification settings, and responsible gaming reminder configurations. You can clear functional cookies through your browser settings at any time; this will reset your preferences to defaults but will not affect your account data or player balance.

Managing Cookies

You can manage, restrict, or delete cookies at any time using your browser's built-in cookie management tools. Instructions for the most common browsers are available through their respective help documentation. Note that disabling essential cookies will prevent you from logging in to your 35bdd account. 35bdd does not use browser fingerprinting as a substitute for standard session authentication.

7 Data Security

35bdd implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Our key security measures include:

• TLS encryption in transit: All data exchanged between your browser and the 35bdd platform is encrypted using TLS 1.2 or higher. Connections using older, insecure protocols are rejected.
• Encryption at rest: Personal data stored on 35bdd servers — including KYC documents and financial records — is encrypted at rest using AES-256 encryption.
• Access controls: Access to systems containing personal data is restricted to 35bdd staff with a documented business need. All access is authenticated via multi-factor authentication and is logged for audit purposes.
• Network security: 35bdd's infrastructure is protected by firewalls, intrusion detection systems, and regular vulnerability scanning. Critical systems are isolated from public-facing network segments.
• Third-party security audits: 35bdd engages independent security professionals to conduct periodic penetration testing and security reviews of platform infrastructure and application code.
• Staff training: All 35bdd staff with access to personal data receive regular data protection training and are bound by contractual confidentiality obligations.

Despite these measures, no internet-based system can be guaranteed to be 100% secure. 35bdd cannot guarantee the absolute security of data transmitted over the internet. You play an important role in keeping your account secure — use a strong, unique password for your 35bdd account, enable OTP authentication, and notify us immediately at [email protected] if you suspect unauthorised access to your account.

8 Data Retention

35bdd retains personal data for the minimum period necessary to fulfil each processing purpose, subject to legal retention obligations. Our standard retention periods are as follows:

After the applicable retention period expires, personal data is securely deleted or anonymised in a manner that prevents reconstruction of individual records. Where anonymisation is technically not feasible within the deletion timeframe, data is rendered inaccessible pending secure deletion.

9 Your Data Rights

As a 35bdd player, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at [email protected] with your registered mobile number and a clear description of the right you wish to exercise. We will respond within 5 business days.

• Right of Access: You may request a copy of all personal data 35bdd holds about you. We will provide this in a structured, readable format within the response timeframe stated above.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Note that some corrections (e.g., changes to registered name or date of birth) may require re-submission of KYC documentation.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data. This right is subject to limitations — 35bdd cannot delete data that must be retained to comply with legal obligations (e.g., AML records, financial transaction logs) or to resolve outstanding disputes. We will explain any limitations clearly in our response.
• Right to Restrict Processing: In certain circumstances you may request that we limit the processing of your data to storage only, for example while a dispute about accuracy is being investigated.
• Right to Data Portability: You may request your registration and gameplay data in a machine-readable format (JSON or CSV) for transfer to another service provider where technically feasible.
• Right to Object: You may object to processing of your data based on legitimate interests (e.g., fraud analytics) at any time. We will consider your objection and cease processing unless we have compelling grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., promotional communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.
• Right to Manual Review: Where an automated decision has materially affected your account, you have the right to request that a human member of the 35bdd team reviews the decision.

10 Children and Minors

The 35bdd platform is strictly intended for adults aged 21 years and above. 35bdd does not knowingly collect, process, or retain personal data from any person under the age of 21. Age verification is enforced at the point of registration through OTP-linked mobile number verification, and 35bdd reserves the right to request documentary proof of age at any stage of the account lifecycle.

If 35bdd becomes aware that personal data has been collected from a person under the age of 21, all data associated with that account will be permanently deleted and the account will be closed immediately. Any deposits made to such an account will be returned through the original payment method where legally required.

11 International Data Transfers

35bdd's primary operations and data storage are oriented towards serving the Bangladesh market. In limited circumstances, personal data may be processed by service providers operating outside Bangladesh — for example, game engine telemetry processed by international game studios (Pragmatic Play, Evolution Gaming, Spribe, Ezugi, Microgaming, NetEnt) whose servers may be located in Europe, Malta, Gibraltar, or other jurisdictions.

Where data is transferred outside Bangladesh, 35bdd ensures that appropriate contractual safeguards are in place with the receiving party, including data processing agreements that require the recipient to maintain data protection standards at least equivalent to those described in this Policy. 35bdd does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without such contractual safeguards.

If you have concerns about the international transfer of your data, contact us at [email protected] and we will provide details of the specific safeguards applicable to your data.

12 Updates to This Privacy Policy

35bdd reviews and updates this Privacy Policy periodically to reflect changes in our data practices, platform features, applicable law, or the recommendations of data protection authorities. When material changes are made, we will notify registered players by displaying a prominent notice on the platform and, where practicable, by sending a message to your registered mobile number.

The updated Policy will be effective from the date stated in the notice — no less than 7 days after notification for material changes. Your continued use of the 35bdd platform after the effective date of an update constitutes acceptance of the revised Policy. If you do not accept the revised Policy, you must cease using the platform and request account closure in accordance with the Terms and Conditions.

The most current version of this Privacy Policy is always accessible at https://35bdd.io/privacy-policy. The effective date displayed at the top of the document indicates when this version became active. We recommend reviewing this Policy periodically. Historical versions are available on request by contacting [email protected].

13 Contact Us

For all enquiries, requests, or complaints relating to this Privacy Policy or to how 35bdd processes your personal data, please contact us using the details below:

• Email: [email protected] — responses within 5 business days for data rights requests, within 4 hours for general support enquiries
• Live Chat: Available directly inside your logged-in 35bdd account — for general account and platform queries
• Support Hours: 24 hours a day, 7 days a week, 365 days a year, Bangladesh Standard Time (BST, UTC+6)

Please include your registered mobile number and a clear description of your enquiry when contacting us. Do not send copies of identity documents or sensitive financial information via unsecured channels — document submissions for KYC purposes should be made through the secure upload facility within your 35bdd account dashboard only.