Your Privacy Matters
to 35db1 — Always

1 Introduction

35db1 ("we", "us", "our", or "the Platform") is committed to protecting the privacy and personal data of all players who access and use our online betting and casino services. This Privacy Policy sets out how we collect, use, store, share, and safeguard your personal information when you visit or interact with the 35db1 website or any of our associated services.

This Policy is drafted in plain English so that every player — regardless of their background — can understand exactly what data we hold about them and why. We operate in full compliance with applicable data protection principles, which include transparency, data minimisation, purpose limitation, accuracy, integrity, and confidentiality.

The 35db1 platform is operated for players located in Bangladesh, including those in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar. By accessing our services from any location in Bangladesh, you acknowledge that your personal data will be processed in accordance with this Policy.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Personal Data We Collect

35db1 collects a range of personal data categories depending on the nature of your interaction with the platform. The data we hold about you may include the following:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identity document
• Date of birth (required to verify you meet the 21+ age requirement)
• Residential address, city, and postal code (Bangladesh)
• Mobile phone number (used for account verification and support)
• Email address (used for account communications and optional marketing)
• National Identity Card (NID) number or passport number (for KYC verification)

2.2 Account & Transactional Data

• Username and encrypted password hash
• Account registration date and account status
• Deposit and withdrawal history, including amounts in Bangladeshi Taka (৳), timestamps, and payment method used (bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank, BRAC Bank)
• Bonus history, wagering activity, and promotion eligibility records
• Betting and gaming history, including markets, stake amounts, outcomes, and session durations
• Balance information and pending withdrawal requests

2.3 Identity Verification (KYC) Data

• Copies of government-issued photo identity documents (NID, passport, driving licence)
• Proof of address documents (utility bill, bank statement)
• Proof of payment method (screenshot or statement confirming ownership of bKash/Nagad account)
• Selfie or live photo for liveness verification where applicable

2.4 Technical & Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Session identifiers, login timestamps, and session duration
• Pages visited, click paths, and features used within the platform
• Referral source (if you arrived via a referring partner or affiliate link)

2.5 Communication Data

• Content of support tickets, live chat transcripts, and email correspondence submitted to or by our support team
• Feedback, survey responses, and complaints submitted through the platform
• Records of responsible gaming requests, self-exclusion requests, and deposit limit changes

3 How We Collect Your Data

35db1 collects personal data through several distinct channels:

3.1 Direct Collection

The majority of your personal data is provided directly by you when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or participate in a promotion. You choose what information to provide; however, certain fields are mandatory for account creation and regulatory compliance.

3.2 Automated Collection

When you use the 35db1 platform, we automatically collect technical data about your device, browser, and interaction patterns. This data is gathered using server logs, session cookies, and analytics tools. It helps us maintain platform security, diagnose technical issues, and improve the user experience for all players.

3.3 Third-Party Sources

In certain circumstances, we may receive personal data about you from third-party sources, including:

• Payment processors — transaction confirmations and fraud signals from bKash, Nagad, Rocket, Upay, and card payment networks
• KYC/identity verification providers — results of automated document checks and liveness verification
• Fraud prevention services — risk scores and flagged activity patterns
• Affiliate and referral partners — referral attribution data (no sensitive personal data is received from affiliates)

4 Legal Basis for Processing

35db1 processes your personal data on one or more of the following legal bases, depending on the specific processing activity involved:

5 How We Use Your Personal Data

The personal data collected by 35db1 is used exclusively for the purposes described below. We do not use your data for any purpose that is incompatible with these stated purposes without first obtaining your consent.

5.1 Account Operation

Your identity and contact data is used to create and maintain your 35db1 account, verify your identity, authenticate your login sessions, communicate important account updates, and enable you to access the full range of betting and casino features available on the platform.

5.2 Payment Processing

Transactional data is used to process your deposits and withdrawals accurately and securely in Bangladeshi Taka (৳), to maintain records of your financial activity on the platform, and to resolve any payment disputes that may arise.

5.3 Regulatory Compliance

35db1 is required by applicable law to conduct identity verification, age verification, and anti-money laundering checks. The data collected for these purposes is used to fulfil these obligations and may be retained for the periods mandated by law even after your account is closed.

5.4 Security and Fraud Prevention

Technical and behavioural data is analysed to detect suspicious activity, prevent account takeover, identify multi-accounting, and protect the integrity of the platform for all players. Where fraud is detected, relevant data may be shared with law enforcement authorities.

5.5 Responsible Gaming

Betting and gaming activity data is used by our responsible gaming team to identify patterns that may indicate problem gambling behaviour. Where such patterns are identified, we may proactively contact the player and apply responsible gaming interventions in accordance with our Responsible Gaming Policy.

5.6 Customer Support

Communication data is used to respond to your support enquiries, resolve complaints, and improve the quality of our customer service. Support interactions may be recorded for training and quality assurance purposes.

5.7 Platform Improvement

Anonymised and aggregated technical and behavioural data is used to analyse platform performance, identify bugs, test new features, and optimise the user experience across devices and browsers commonly used by players in Bangladesh.

6 Data Sharing & Disclosure

35db1 does not sell or rent your personal data to any third party. We share your data only in the limited circumstances described below, and always subject to appropriate data protection safeguards.

6.1 Service Providers

We engage trusted third-party service providers who process personal data on our behalf under strict contractual data processing agreements. These providers include:

• Payment processors: bKash, Nagad, Rocket, Upay, and card payment network operators who process your financial transactions
• KYC and identity verification providers: who verify the authenticity of your identity documents and confirm age eligibility
• Fraud prevention and security providers: who analyse transaction patterns and flag suspicious activity
• Cloud hosting and infrastructure providers: who securely host the 35db1 platform and its databases
• Customer support software providers: who operate the ticketing systems used by our support team

6.2 Legal and Regulatory Disclosures

35db1 may be required to disclose your personal data to law enforcement agencies, government authorities, or courts of competent jurisdiction where we are legally compelled to do so. We will only disclose the minimum data required to comply with the legal obligation.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or restructuring involving 35db1, your personal data may be transferred to the acquiring or merged entity. In such circumstances, we will notify you prior to your data being transferred and becoming subject to a different privacy policy.

7 Cookies & Tracking Technologies

35db1 uses cookies and similar tracking technologies to operate and improve the platform. A cookie is a small text file stored on your device by your browser when you visit a website. The cookies we use fall into the following categories:

You may control cookie settings through your browser preferences. Please note that disabling strictly necessary cookies may prevent certain features of the 35db1 platform from functioning correctly, including the ability to log in to your account.

8 Data Security

35db1 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or alteration. Our security infrastructure includes:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the 35db1 servers
• Encrypted storage of sensitive data fields including passwords (stored as salted hashes), NID numbers, and financial account identifiers
• Role-based access controls ensuring that only authorised 35db1 staff can access personal data, and only to the extent necessary for their specific job function
• Regular security audits and penetration testing conducted by independent security specialists
• Intrusion detection systems that continuously monitor for abnormal access patterns and potential data breaches
• Secure data centres with physical access controls, environmental monitoring, and redundant systems to protect against hardware failure and data loss

Despite these measures, no online system can guarantee absolute security. In the event of a data breach that is likely to affect your rights and freedoms, 35db1 will notify you without undue delay in accordance with applicable data protection law.

9 Data Retention

35db1 retains your personal data for the period necessary to fulfil the purpose for which it was collected, or as required by applicable law, whichever is longer. The following retention guidelines apply:

• Active account data — retained for the duration of your account and for a period of 5 years following account closure, to comply with financial record-keeping and anti-money laundering obligations
• KYC and identity verification documents — retained for a minimum of 5 years following the completion of the verification process or account closure, in accordance with anti-money laundering legislation
• Transaction records — retained for a minimum of 5 years following the date of each transaction
• Customer support communications — retained for 3 years from the date of the most recent interaction
• Marketing preferences and consent records — retained for the duration of your consent, plus 3 years thereafter as evidence of consent
• Technical and device logs — retained for up to 12 months for security and analytics purposes

When personal data is no longer required and no legal retention obligation applies, 35db1 will securely delete or anonymise the data so that it can no longer be associated with you as an individual.

10 Your Data Rights

As a player of 35db1, you have the following rights with respect to your personal data. To exercise any of these rights, please contact our support team at support at 35db1.io with "Data Rights Request" in the subject line. We will respond within 30 days of receiving your request.

10.1 Right of Access

You have the right to request a copy of all personal data that 35db1 holds about you. This is sometimes called a "Subject Access Request" (SAR). We will provide this information in a structured, commonly used, machine-readable format where technically feasible.

10.2 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. You may also update certain account details directly from within your 35db1 account settings.

10.3 Right to Erasure

You may request that 35db1 delete your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn your consent, or where you object to the processing and there is no overriding legitimate interest. Please note that this right is subject to legal retention obligations — we cannot delete data we are legally required to retain.

10.4 Right to Restrict Processing

You have the right to request that 35db1 restrict the processing of your personal data in certain circumstances, such as while a dispute about the accuracy of your data is being resolved.

10.5 Right to Data Portability

Where processing is carried out by automated means and is based on your consent or a contract with you, you have the right to receive your personal data in a portable format and to request that it be transmitted directly to another data controller where technically feasible.

10.6 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, in which case we will assess whether our interests override your rights in the specific circumstances.

11 Marketing Communications

35db1 may send you promotional emails, SMS notifications, or in-platform messages about new games, seasonal promotions (such as Eid, Pohela Boishakh, and BPL season specials), reload bonuses, and platform updates — but only where you have given your consent or where we have a legitimate interest as an existing customer.

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

• Clicking the "Unsubscribe" link in any promotional email we send you
• Updating your communication preferences in your 35db1 account settings
• Contacting our support team at support at 35db1.io and requesting removal from our marketing list

Please note that even if you opt out of marketing communications, we will continue to send you essential account-related notifications such as deposit confirmations, withdrawal updates, security alerts, and policy change notices. These service communications are not subject to marketing opt-out.

12 Children & Minors

The 35db1 platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Our registration process includes an age declaration step, and we conduct KYC age verification checks on all players.

If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will immediately suspend the associated account, delete or anonymise all data collected, and void any transactions associated with the account.

If you are a parent or guardian and believe that a minor in your care has registered an account with 35db1, please contact our support team immediately at support at 35db1.io so that we can take prompt remedial action.

13 Third-Party Links

The 35db1 platform may contain references to third-party services such as payment providers (bKash, Nagad, Rocket), game studios (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi), and sports data providers. Where such services are accessed through third-party interfaces, their own privacy policies will govern the collection and use of your data on their platforms.

35db1 has no control over the privacy practices of third-party services and accepts no responsibility or liability for how those services handle your personal data. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of our platform.

14 Updates to This Privacy Policy

35db1 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes to this Policy, we will notify registered players by posting a prominent notice on the platform and, where reasonably practicable, by sending an email notification to your registered address.

The effective date of the current version is displayed at the top of this document. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the 35db1 platform following any update to this Policy constitutes your acceptance of the revised terms.

15 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which 35db1 processes your personal data, please contact our privacy team using the details below. We are committed to resolving all privacy-related enquiries in a fair and timely manner.

We hope to resolve any concerns you raise directly. If, however, you are not satisfied with the outcome of your complaint, you have the right to escalate the matter to the appropriate data protection authority or regulatory body in your jurisdiction.