Your Privacy Matters at 33det —
How We Protect Your Data

This Privacy Policy ("Policy") describes how 33det ("we", "us", "our", or "the Platform") collects, uses, stores, discloses, and protects the personal information of individuals ("you", "your", or "User") who access and use the 33det website at 33det.io and any associated services, features, or applications operated by 33det.

33det is committed to maintaining the trust of every player who uses our platform. We recognise that your personal data is sensitive and valuable, and we take our data protection obligations seriously. This Policy is designed to give you a clear, complete, and honest account of our data practices so that you can make informed decisions about your use of 33det.

This Policy forms an integral part of our Terms & Conditions. By registering an account on 33det, depositing funds, or otherwise using any part of the Platform, you acknowledge that you have read this Policy in full and that you consent to our processing of your personal data as described herein. If you do not accept this Policy, you must not use the Platform.

This Policy applies to all users of the 33det Platform, including registered players, visitors who browse the website without registering, and individuals who contact our customer support team. It covers personal data collected through all channels, including our website, live chat, email, and payment processing flows.

For the purposes of applicable data protection law, 33det is the data controller responsible for the personal data collected through the Platform. As data controller, 33det determines the purposes and means by which your personal data is processed.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection team using the following details:

• Platform name: 33det
• Website: 33det.io
• Data Protection contact email: [email protected] (plain text — not a clickable link)
• Support hours: 24 hours a day, 7 days a week, including Bangladesh public holidays
• Primary market: Bangladesh — serving players across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar

33det collects personal data across several categories depending on how you interact with the Platform. The following table summarises the categories of personal data we collect and typical examples within each category:

We do not collect any special categories of sensitive personal data (such as health information, racial or ethnic origin, political opinions, or religious beliefs) unless such data is volunteered by you in the course of a responsible gaming support interaction, in which case it is processed solely for the purpose of providing appropriate assistance and is not used for any other purpose.

33det collects personal data through the following channels and mechanisms:

• Direct provision: Data you actively provide when you create an account, complete a KYC verification request, make a deposit or withdrawal, contact our support team, or participate in a promotion or survey.
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you visit or interact with the Platform. See Section 6 for our full Cookie Policy.
• Payment processors: Financial data received from our integrated payment partners (including bKash, Nagad, Rocket, Upay, SureCash, Visa, Mastercard, and partner banks including BRAC Bank, Dutch-Bangla Bank, City Bank, Islami Bank, and Sonali Bank) when you initiate a deposit or withdrawal transaction.
• Identity verification providers: Identity and document data received from third-party KYC and identity verification service providers when you complete the account verification process. These providers compare your submitted documents against authoritative data sources to confirm your identity.
• Fraud prevention services: Technical and behavioural data received from third-party fraud detection and anti-money-laundering screening services that 33det uses to protect the integrity of the Platform.
• Public sources: In limited circumstances, 33det may verify information against publicly available sources (such as sanctions lists or politically exposed persons databases) as part of our compliance obligations.

33det processes your personal data only where we have a valid legal basis for doing so. The following table sets out each processing purpose, the categories of data involved, and the legal basis on which we rely:

Where we rely on consent as our legal basis (for example, for marketing communications and certain personalisation features), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before your withdrawal. To withdraw consent, contact us at [email protected] or update your preferences in your account settings.

Where we rely on legitimate interests, we have carried out a balancing test to confirm that our legitimate interests are not overridden by your rights and interests. We do not rely on legitimate interests where the impact on your privacy is disproportionate to the benefit we derive from the processing.

33det uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage objects) to operate and improve the Platform. Cookies are small text files placed on your device that allow our servers to recognise your browser across sessions.

We use the following categories of cookies on the 33det Platform:

• Strictly necessary cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session cookies that maintain your login state, security tokens that protect against cross-site request forgery, and load-balancing cookies that ensure stable server performance.
• Functional cookies: These cookies enable enhanced features such as remembering your preferred language, display settings, and responsible gaming preferences set during your session. Disabling these cookies may reduce Platform functionality.
• Analytics cookies: These cookies collect aggregated, anonymised data about how users interact with the Platform — which pages are visited most often, how long users spend on each section, and what technical errors occur. This information helps us improve Platform performance and user experience.
• Marketing and personalisation cookies: These cookies are used to deliver promotional content and game recommendations that are relevant to your interests based on your browsing and gaming behaviour on the Platform. They are only placed with your consent.

You can manage your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies at any time. Please note that blocking strictly necessary cookies will prevent you from logging in or using key Platform features. A full list of the specific cookies used on 33det is available on request by contacting our support team.

33det does not sell your personal data to third parties. We share your personal data with third parties only in the following circumstances, and only to the minimum extent necessary for the specified purpose:

• Payment service providers: We share your name and account number with payment processors (bKash, Nagad, Rocket, Upay, SureCash, and banking partners) to facilitate deposits and withdrawals. These providers act as independent data controllers in respect of the payment transaction data they process.
• Identity verification (KYC) providers: We share identity documents and personal details with regulated third-party KYC and anti-money-laundering service providers for the purpose of verifying your identity in compliance with our legal obligations.
• Game content providers: Certain game usage data (such as session identifiers and wager amounts) may be shared with our game studio partners (including Pragmatic Play, Evolution Gaming, PG Soft, NetEnt, Microgaming, Spribe, and Ezugi) to deliver their game content on the Platform. These providers are bound by data processing agreements and may not use your data for their own independent marketing purposes.
• IT and hosting service providers: We use third-party cloud hosting and infrastructure providers to store and process Platform data securely. These providers act as data processors under binding agreements and may not use your data for any purpose other than delivering the contracted infrastructure services.
• Fraud prevention and security services: We share technical and behavioural data with third-party fraud detection and cybersecurity providers to protect the Platform and its users from fraudulent activity, account takeover attacks, and financial crime.
• Legal and regulatory authorities: We may disclose personal data to government bodies, law enforcement agencies, or regulatory authorities where we are legally required to do so — for example, in response to a valid court order, subpoena, or official regulatory investigation.
• Business transfers: In the event that 33det or its business assets are acquired, merged with, or transferred to another entity, your personal data may form part of the transferred assets. You will be notified in advance of any such transfer and the new controller's privacy practices.

All third-party service providers with whom we share personal data are required to maintain appropriate technical and organisational security measures and to process your data only for the specific purposes set out in their contractual agreement with 33det.

33det's primary operations serve the Bangladesh market. However, some of our third-party service providers (including cloud hosting and game content providers) may process data on servers located outside Bangladesh. Where personal data is transferred to a country that does not provide an equivalent level of data protection, 33det takes steps to ensure that appropriate safeguards are in place, including:

• Entering into standard contractual clauses or equivalent data transfer agreements with the receiving party that impose binding data protection obligations.
• Conducting transfer impact assessments to evaluate the risks associated with transfers to specific jurisdictions and implementing supplementary technical safeguards (such as encryption at rest and in transit) where necessary.
• Limiting the scope of data transferred to the minimum necessary for the contracted service.

If you would like more information about the specific safeguards in place for any particular international transfer, please contact us at [email protected].

33det retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply to the main categories of personal data we hold:

At the end of each applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data (which can no longer be linked to any individual) may be retained for statistical, analytical, and product development purposes indefinitely.

33det implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS encryption: All data in transit between your browser or app and 33det's servers is encrypted using industry-standard TLS 1.2 or higher protocols.
• Encryption at rest: Sensitive personal data stored in our databases (including payment details and identity documents) is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within 33det is restricted to authorised staff on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and undergo regular data protection training.
• Multi-factor authentication: Internal systems holding personal data are protected by multi-factor authentication requirements for all staff accounts.
• Penetration testing and security audits: 33det conducts regular third-party security assessments, including penetration testing of our web application and infrastructure, to identify and remediate vulnerabilities before they can be exploited.
• Intrusion detection systems: Real-time monitoring systems alert our security team to unusual access patterns, potential data breaches, or suspicious activity affecting Platform data.
• Data breach response: In the event of a personal data breach that poses a risk to your rights and freedoms, 33det will notify affected users without undue delay and, where required by applicable law, will report the breach to relevant authorities.

While 33det takes all reasonable precautions to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your 33det account login credentials (username and password) confidential. If you suspect that your account has been compromised, please contact our support team immediately at [email protected].

As a user of the 33det Platform, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our support team at [email protected] with a clear description of your request. We will respond within 30 days.

• Right of access: You have the right to request a copy of the personal data we hold about you , together with information about how it is processed. We will provide this in a commonly used electronic format.
• 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. You may also update certain account details directly through your account settings page.
• Right to erasure: In certain circumstances, you have the right to request that we delete the personal data we hold about you. This right is subject to limitations where we are required to retain data to comply with a legal obligation or to establish, exercise, or defend legal claims.
• Right to restriction of processing: You have the right to request that we restrict the processing of your personal data in circumstances where you contest its accuracy, object to its processing, or require it for the establishment of legal claims.
• Right to data portability: Where processing is based on your consent or on contractual necessity, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller.
• Right to object: You have the right to object to processing carried out on the basis of legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease that processing immediately.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right not to be subject to automated decisions: You have the right not to be subject to a decision based solely on automated processing that produces significant legal or similarly significant effects on you, unless such processing is necessary for the performance of a contract or is authorised by applicable law.

We will not charge a fee for processing your rights requests in ordinary circumstances. However, where requests are manifestly unfounded, repetitive, or excessive, we reserve the right to charge a reasonable administrative fee or to refuse to act on the request, providing written reasons for our decision.

Please note that exercising certain rights — such as the right to erasure or restriction — may result in the closure of your 33det account where we are unable to provide our services without the relevant data. We will inform you of this before processing any such request.

The 33det Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. If you are under 21, you must not register an account on 33det or use any part of the Platform.

During the account registration process, all users are required to confirm that they are 21 or older. As part of our Know Your Customer (KYC) identity verification process, 33det verifies the age of users through government-issued identity documents. Any account found to belong to a person under the age of 21 will be immediately suspended and all funds held in that account will be frozen pending further investigation.

If you are a parent or guardian and believe that your child has registered an account on 33det or provided us with personal data without your knowledge or consent, please contact us immediately at [email protected]. We will investigate the matter promptly and, if confirmed, will delete the relevant data and close the account without delay.

With your explicit consent, 33det may send you promotional communications about new games, special offers, BPL and IPL betting promotions, seasonal bonuses (including Eid and Pohela Boishakh campaigns), and other Platform news via email and SMS. Marketing communications are sent only to users who have opted in during registration or through their account settings.

You may opt out of receiving marketing communications from 33det at any time by:

• Clicking the unsubscribe link included in any marketing email we send you.
• Updating your communication preferences in your 33det account settings.
• Contacting our support team at [email protected] and requesting removal from our marketing list.

Opting out of marketing communications will not affect transactional communications that are necessary for the operation of your account, such as deposit and withdrawal confirmations, account security alerts, KYC request notifications, and responsible gaming limit acknowledgements. These service communications are sent as part of our contractual obligations and cannot be disabled while your account is active.

33det does not share your contact details with third-party marketers for their own independent promotional purposes. All marketing communications you receive from us will originate from 33det directly.

33det reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The most current version of this Policy will always be available on the 33det website at the /privacy-policy page, along with the date on which it was last updated.

Where a proposed change is material — meaning it significantly affects the way in which we process your personal data or materially alters your privacy rights — we will notify you in advance by sending a notification to the email address registered to your account. We will provide at least 14 days' notice before any material change takes effect, giving you sufficient time to review the updated Policy and, if you do not agree to it, to close your account.

Your continued use of the 33det Platform after the effective date of an updated Privacy Policy constitutes your acceptance of that updated Policy. If you do not accept the updated terms, you should cease using the Platform and may contact our support team to request account closure and deletion of your personal data in accordance with Section 11 above.

If you have any questions, concerns, or requests relating to this Privacy Policy, the personal data we hold about you, or the manner in which we process that data, please contact the 33det Data Protection team using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: Please include "Privacy Request" in the subject line of any data-related enquiry to ensure prompt routing to our Data Protection team.
• Support hours: 24 hours a day, 7 days a week, including Bangladesh public holidays
• Response time: General privacy enquiries within 48 hours; formal rights requests within 30 days
• Languages: English and Bengali support available
• Platform: 33det.io — serving players across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar, and all regions of Bangladesh

We are committed to resolving all privacy-related concerns in a fair, transparent, and timely manner. If you are not satisfied with our response to your privacy enquiry or rights request, you may have the right to escalate the matter to an appropriate data protection authority or independent dispute resolution body in your jurisdiction.