33md Privacy Policy – How We Handle Your Data

1. Introduction

33md ("we", "us", "our") operates the online gaming platform available at 33md.app. This Privacy Policy applies to all players who register an account, visit the platform, or otherwise interact with 33md's services. It governs the collection, use, storage, and disclosure of personal information in connection with the operation of the 33md platform.

By using the 33md platform, you consent to the data practices described in this policy. If you do not agree with how we handle personal data, you should not use the platform. We encourage you to read this policy in full before registering or making a deposit.

2. Information We Collect

33md collects personal information in three broad categories: information you provide to us directly during registration and ongoing account use, information generated automatically by your use of the platform, and information received from third-party payment providers in connection with your deposits and withdrawals.

Information You Provide Directly

• Registration details: your Bangladesh mobile number, which serves as your account identifier, and the password you create at the time of account setup.
• Verification documents: where identity verification is required (for example, prior to processing a large withdrawal), you may be asked to provide a copy of a government-issued identification document such as your NID card or passport.
• Communication records: any messages you send to the 33md support team via email, and the responses provided to you, are retained to maintain a record of your support history and to facilitate follow-up assistance.
• Responsible gaming tool settings: if you set deposit limits, session reminders, or request self-exclusion, these instructions and their timestamps are recorded as part of your account record.

Information Generated Automatically

• Device and technical data: your device type (mobile, tablet), operating system version, browser or app version, screen resolution, and device identifiers. This information is used to optimize the platform's display and performance for your specific device.
• Connection data: your IP address, connection type (WiFi, 4G, 5G), and general geographic location derived from your IP address (country and, in some cases, city level). This data is used for fraud detection, security monitoring, and platform access control.
• Session and gameplay data: records of your login sessions (times, durations), the games you play, bet amounts and outcomes, bonus activity, and deposit and withdrawal transaction history. This data is core to the operation of the gaming platform and is necessary for the accurate crediting and debiting of your account balance.
• Cookie and tracking data: small data files stored on your device that help us remember your session preferences, maintain your logged-in state, and, where applicable, analyze how players interact with different parts of the platform. See Section 9 for more detail on cookies.

Information from Payment Providers

• Transaction confirmation data from bKash, Nagad, Rocket, and Upay: when you make a deposit or withdrawal, the relevant payment provider transmits a transaction reference, the amount, the date and time, and — in the case of mobile money services — the mobile number associated with the sending or receiving wallet.
• Transaction status updates: payment providers may send status updates (pending, completed, failed, reversed) that are logged against your account's financial record.
• 33md does not receive your full payment account credentials (such as your bKash PIN or Nagad PIN) from these providers. That authentication happens entirely within the payment provider's own secure environment and is not visible to or stored by 33md.

3. How We Use Your Information

33md uses the personal information it collects for the following specific purposes. We do not use your data for purposes beyond those listed here without first seeking your consent or having a legal basis to do so.

• Account creation and management: to create your player account, verify your identity where required, maintain your account balance, and provide you with access to the platform's full game library and services.
• Payment processing: to process your deposits and withdrawals accurately and on time, to reconcile your account balance, and to maintain an auditable transaction history.
• Customer support: to respond to your queries, investigate complaints, and resolve disputes relating to your account or transactions. Support communication records are retained to provide continuity of service and to protect both you and 33md in the event of a dispute.
• Platform security and fraud prevention: to detect and prevent fraudulent activity, unauthorized access, money laundering, multi-accounting, bonus abuse, and other behaviors that violate our Terms and Conditions or applicable law.
• Responsible gaming compliance: to enforce age restrictions, to administer deposit limits and self-exclusion requests made by players, and to monitor for signs of problem gambling behavior in accordance with our Responsible Gaming policy.
• Platform improvement: to analyze aggregated, anonymized usage patterns for the purpose of improving the platform's performance, user interface, and game selection. This analysis is conducted at an aggregate level and does not involve profiling individual players.

4. Legal Basis for Processing

33md processes your personal data on the following legal bases, depending on the specific purpose of the processing:

• Contractual necessity: processing your registration data, maintaining your account, and handling deposits and withdrawals are all necessary to perform the contract we have with you as a player. Without this processing, we cannot provide the service.
• Legitimate interests: fraud detection, platform security, and responsible gaming monitoring are conducted on the basis of 33md's legitimate interest in operating a safe and compliant platform and protecting both its players and the integrity of the service.
• Legal obligation: certain data retention and reporting obligations may be imposed on 33md by applicable law, including anti-money laundering requirements and age verification obligations. Where we process data to comply with a legal obligation, we will retain that data for only as long as the law requires.
• Consent: where we rely on your consent as the legal basis for processing — for example, for sending you marketing messages — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

5. Sharing Your Information

33md does not sell, rent, or trade your personal information to any third party for their own commercial purposes. We share your information only in the following limited and specific circumstances:

• Payment providers (bKash, Nagad, Rocket, Upay): we share the minimum information necessary to process your deposits and withdrawals with the relevant payment provider. This typically includes the transaction amount, your registered mobile number, and a transaction reference. Payment providers are bound by their own privacy policies and are not permitted to use your data for purposes unrelated to processing your transaction.
• Game content providers (Pragmatic Play, Evolution Gaming, Spribe, and others): when you play a game hosted by a third-party provider, certain session data — such as your player ID, the game played, bet amounts, and round outcomes — is shared with that provider in real time to facilitate the game. This data is used by the provider solely to operate the game session and is not used for independent marketing or profiling.
• Legal and regulatory authorities: we may be required by applicable law, court order, or regulatory directive to disclose certain player data to government bodies, law enforcement agencies, or financial regulators. In such cases, we will disclose only the minimum information required and will notify you where we are legally permitted to do so.
• Technology and infrastructure service providers: 33md uses third-party providers for hosting, data storage, content delivery, and platform analytics. These providers process data on our behalf under strict contractual data processing agreements and are not permitted to use your data for any purpose other than providing the service to us.

6. Payment Data and Financial Privacy

33md takes the privacy of your financial information particularly seriously. When you make a deposit or withdrawal using bKash, Nagad, Rocket, or Upay, the authentication of the transaction — including the entry of your mobile wallet PIN — takes place entirely within that provider's own application or USSD flow. 33md never has access to your PIN or any other primary authentication credential for your mobile wallet.

The transaction data 33md receives from payment providers is limited to what is necessary to credit or debit your account: the transaction reference number, the amount, the mobile number of the sending or receiving wallet, and the transaction status. This financial transaction data is retained as part of your account record for as long as your account remains active and for a period following account closure as required for audit, anti-fraud, and legal compliance purposes.

7. Data Retention

33md retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following general retention principles apply:

• Active account data: while your account remains open and active, 33md retains all account data, transaction history, and gameplay records as part of your live account record. This data is necessary to operate your account, resolve disputes, and meet responsible gaming obligations.
• Post-closure retention: following account closure — whether voluntary or initiated by 33md — we retain your account record, identity verification documents, and transaction history for a period of up to 5 years. This retention period exists to satisfy anti-money laundering compliance requirements, to resolve any post-closure disputes, and to prevent circumvention of self-exclusion restrictions through re-registration.
• Support communication records: communications between you and the 33md support team are retained for 2 years from the date of the most recent message in a given support thread, to support follow-up assistance and dispute resolution.

When a retention period expires, 33md will securely delete or anonymize the relevant data. Anonymized aggregate data (from which no individual can be identified) may be retained indefinitely for analytical and platform improvement purposes.

8. Security Measures

33md implements a range of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, or disclosure. These measures include SSL/TLS encryption for all data transmitted between your device and our platform, secure password hashing, session authentication and automatic session expiry, access controls that limit which 33md personnel can view player data, and regular security reviews of platform infrastructure.

Despite these measures, no online platform can guarantee absolute security against all possible threats. 33md will notify affected players promptly in the event of a data breach that is reasonably likely to result in a risk to their rights or interests. If you believe your account has been compromised, please contact us immediately at [email protected].

9. Your Data Rights

As a player on the 33md platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact us at [email protected] with your registered mobile number and a description of your request. We will respond within a reasonable time.

• Right of access: you have the right to request a copy of the personal data 33md holds about you. We will provide this in a clear, readable format within a reasonable period of receiving your request.
• Right of rectification: if any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it. We will update inaccurate data promptly upon receiving a verified correction request.
• Right of erasure: you may request that 33md delete your personal data in certain circumstances — for example, where we no longer need the data for the purposes for which it was collected and there is no overriding legal obligation to retain it. Note that certain data (such as transaction records) may be subject to mandatory retention periods under applicable law, during which erasure cannot be completed.
• Right to object to marketing: you may opt out of marketing communications from 33md at any time without providing a reason. Your objection to marketing will be actioned immediately and will not affect your continued use of the platform.
• Right to complain: if you believe 33md has handled your personal data in a manner that breaches this Privacy Policy or applicable data protection law, you have the right to make a complaint. Please contact us first at [email protected] so that we have the opportunity to address your concern directly.

When submitting a data rights request, please include your registered mobile number so that we can verify your identity before processing your request. This verification step is necessary to protect your account from unauthorized data requests made by third parties.

10. Cookies and Tracking Technologies

33md uses cookies and similar tracking technologies to support the operation of the platform. The following types of cookies are used:

• Essential session cookies: these cookies are strictly necessary to keep you logged in during your gaming session, to maintain your account state (balance, active game, open bets), and to protect the security of your session. They expire when you close your browser or after a period of inactivity. These cookies cannot be disabled without disrupting the platform's core functionality.
• Functional preference cookies: these cookies remember your platform preferences, such as your language setting, and save you from needing to re-enter them on every visit. They are not used for tracking or advertising purposes.
• Analytics cookies: we use anonymized analytics tools to understand aggregate patterns in how players navigate the platform — for example, which pages are visited most, where players encounter navigation difficulty, and how the platform performs on different device types. No individual player is identified through analytics data.

You may disable non-essential cookies through your browser settings. Please note that disabling essential session cookies will prevent you from logging in to your 33md account. 33md does not use third-party advertising or retargeting cookies and does not share cookie data with advertising networks.

11. Children's Privacy and Age Restriction

The 33md platform is strictly intended for adults aged 21 and above. We do not knowingly collect, store, or process personal data from individuals who are under 21 years of age. If a player is found to be under 21 at any point, their account will be immediately closed and any personal data associated with their account will be deleted, subject to the minimum retention requirements imposed by applicable law.

12. Changes to This Privacy Policy

33md reserves the right to update or amend this Privacy Policy at any time. Where we make a material change to how we collect or use your personal data, we will endeavor to notify active players in advance via a notice on the platform or via communication to your registered mobile number. The updated policy will take effect from the date it is published on the platform.

Your continued use of the 33md platform following the publication of an updated Privacy Policy constitutes your acceptance of the changes. We recommend that you review this policy periodically. The "Last updated" date at the top of this page always reflects the date of the most recent revision.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to how 33md handles your personal data, please contact the 33md data support team. We are committed to responding to all privacy-related enquiries promptly and transparently.

Email us at [email protected]