Privacy Policy for 33pmw — How We Protect Your Personal Data

Data We Collect

When you interact with the 33pmw platform — whether by registering an account, making a deposit, placing a bet, or contacting our support team — we collect certain personal data about you. This section describes in full detail what categories of data we collect, how we collect them, and the lawful basis on which each category of collection rests.

1.1 Information You Provide Directly

When you register an account with 33pmw, you are required to provide the following personal information:

• Full legal name — as it appears on your government-issued identity document.
• Date of birth — used to verify that you meet the 18+ age requirement.
• Mobile phone number — used for account verification, two-factor authentication, and support communications.
• Email address — used for account notifications, password resets, and promotional communications (where consented).
• Residential address — including your district, city, and postal code within Bangladesh (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh).
• Payment method details — including your bKash, Nagad, or Rocket mobile banking number, or bank account details for Dutch-Bangla Bank, City Bank, BRAC Bank, or other supported institutions. We do not store full card numbers for Visa or Mastercard — only tokenised references provided by our payment processor.
• Identity verification documents — including scans or photographs of your National Identity Card (NID), passport, or other government-issued photo ID, submitted during KYC verification.

1.2 Information Collected Automatically

When you access the 33pmw platform, we automatically collect certain technical and behavioural data, including:

• IP address — used to detect your approximate geographic location, identify suspicious login attempts, and enforce geographic access controls.
• Device information — including device type, operating system version, browser type and version, screen resolution, and language settings.
• Session data — including login timestamps, session duration, pages viewed, games played, bets placed, and navigation paths through the platform.
• Transaction logs — a complete record of all deposits, withdrawals, bonus credits, wagers, and game outcomes associated with your account.
• Cookie data — see Section 4 (Cookies & Tracking) for full details.

1.3 Information from Third Parties

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

• Payment processors — bKash, Nagad, Rocket, Upay, and our card processing partners may share transaction confirmation data with us to verify your deposits and process your withdrawals.
• Identity verification providers — third-party KYC and age verification services may share the results of identity checks they conduct on our behalf.
• Fraud prevention agencies — we may receive alerts or flags from fraud detection services we work with to protect the integrity of the platform.
• Affiliates and referral partners — if you arrived at 33pmw via an affiliate link or referral programme, we may receive a referral identifier from that partner. We do not receive your personal data from affiliates; only a non-identifiable referral code is passed.

1.4 Data Collection Summary Table

How We Use Your Data

33pmw uses the personal data we collect for specific, defined purposes. We do not use your data in ways that are incompatible with the purposes described at the time of collection. The following is a comprehensive account of how we use your personal information.

2.1 Account Management and Service Delivery

The primary use of your personal data is to create, maintain, and operate your 33pmw account and to deliver the services you have requested. This includes processing your registrations, verifying your identity, managing your deposits and withdrawals in Bangladeshi Taka (৳), calculating and crediting your winnings, applying bonuses, and providing access to our full library of casino games, live tables, and sports betting markets.

2.2 Identity Verification and Regulatory Compliance

We are required to verify the identity and age of all players on our platform as part of our Know Your Customer (KYC) obligations. Your name, date of birth, and identity documents are used to confirm that you are aged 18 or above and that you are who you claim to be. We also use your personal data to comply with Anti-Money Laundering (AML) requirements, which may involve screening your details against sanctions lists and reporting suspicious transactions to relevant authorities.

2.3 Fraud Prevention and Platform Security

We use your IP address, device fingerprint, session data, and transaction history to detect and prevent fraudulent activity on the platform. This includes identifying duplicate accounts, detecting unauthorised access attempts, flagging unusual betting patterns, and preventing the misuse of bonus offers. Our fraud prevention systems operate on an automated basis with human review for flagged cases.

2.4 Customer Support

When you contact our support team via email at [email protected], we use the personal data you provide in your communication — together with your account history — to investigate and resolve your query. Support communications are retained for quality assurance and training purposes.

2.5 Responsible Gaming Monitoring

We use your session data, deposit history, and betting patterns to identify signs of potential problem gambling. If our systems detect behaviour consistent with compulsive gambling — such as unusually frequent deposits, extended uninterrupted gaming sessions, or rapid escalation of bet sizes — our responsible gaming team may reach out to you proactively. This use of your data is in your best interest and is part of our commitment to player welfare.

2.6 Marketing and Promotional Communications

With your explicit consent, we may use your email address and mobile phone number to send you information about 33pmw promotions, seasonal offers (such as Eid bonuses, Pohela Boishakh specials, BPL cricket promotions, and ICC T20 World Cup offers), and platform updates. You may withdraw your consent to marketing communications at any time by contacting [email protected] or by following the unsubscribe instructions in any marketing message. Withdrawal of marketing consent does not affect your ability to use the platform.

2.7 Platform Analytics and Improvement

We use aggregated and anonymised usage data to analyse how players interact with the 33pmw platform, identify technical issues, optimise the user interface for Bangladeshi mobile users, and improve the overall quality of our services. This analytics data does not identify you personally and is used solely for internal platform development purposes.

Data Sharing & Disclosure

33pmw does not sell your personal data. We do not share your information with third parties for their own marketing or commercial use. However, there are specific, limited circumstances in which we share your data with trusted partners and authorities, as described below.

3.1 Payment Processing Partners

To process your deposits and withdrawals, we share the minimum necessary payment information with our payment processing partners, including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, and our card processing provider for Visa and Mastercard transactions. These partners receive only the information required to execute the specific transaction and are contractually prohibited from using your data for any other purpose.

3.2 Identity Verification and KYC Providers

We work with third-party identity verification providers to conduct KYC checks on our behalf. These providers process your identity documents and return a verification result to 33pmw. They are bound by strict data processing agreements and are not permitted to retain your documents beyond the period necessary to complete the verification process.

3.3 Fraud Prevention and Security Services

We may share certain technical identifiers — such as anonymised device fingerprints and IP address ranges — with fraud prevention networks and security intelligence services to help identify and block known fraudulent actors. This sharing is limited to non-personally-identifiable technical data where possible.

3.4 Legal and Regulatory Authorities

33pmw may be legally required to disclose your personal data to law enforcement agencies, financial intelligence units, courts, or other governmental authorities in Bangladesh or internationally if we receive a lawful request, court order, or are otherwise required to do so by applicable law. We will only comply with requests that are lawful, proportionate, and properly authorised. Where permitted by law, we will notify you of any such disclosure request.

3.5 Business Transfers

In the event that 33pmw undergoes a merger, acquisition, or sale of all or substantially all of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. In such circumstances, we will notify affected players and ensure that the receiving entity agrees to honour the privacy commitments set out in this policy.

Cookies & Tracking Technologies

33pmw uses cookies and similar browser-based technologies to ensure the platform functions correctly, to remember your preferences, and to understand how players use the site so that we can continue to improve it. This section explains what cookies we use, why we use them, and how you can manage your cookie preferences.

4.1 What Are Cookies?

Cookies are small text files that are placed on your device (computer, smartphone, or tablet) by the websites you visit. They are widely used to make websites work more efficiently, to personalise your experience, and to provide information to the website operator. Cookies cannot execute programs or deliver viruses to your device; they are a passive data storage mechanism.

4.2 Types of Cookies We Use

4.3 What We Do NOT Use

33pmw does not use third-party advertising cookies, retargeting pixels, social media tracking scripts, or any cross-site tracking technology that follows you across other websites. Our cookie use is strictly limited to what is necessary to operate and improve the 33pmw platform itself.

4.4 Managing Your Cookie Preferences

You can control and manage cookies through your browser settings. Most modern browsers allow you to view, block, or delete cookies at any time. Please be aware that disabling strictly necessary cookies will prevent you from logging in to your 33pmw account and will impair core platform functionality. Instructions for managing cookies in common browsers used in Bangladesh:

• Google Chrome (Android): Settings → Privacy and security → Cookies and other site data.
• Mozilla Firefox: Settings → Privacy & Security → Cookies and Site Data.
• Samsung Internet (Galaxy devices): Settings → Privacy → Smart Anti-Tracking.
• Safari (iOS): Settings → Safari → Privacy & Security → Block All Cookies.

Data Retention

33pmw retains your personal data only for as long as it is necessary to fulfil the purposes for which it was collected, to maintain the integrity of the 33pmw platform, and to comply with our legal and regulatory obligations. This section explains our data retention practices in detail.

5.1 Active Account Data

While your 33pmw account is active, we retain all personal data associated with your account, including your registration information, identity documents, payment method records, transaction history, betting history, and support communications. This data is necessary for the ongoing delivery of our services to you.

5.2 Post-Account-Closure Retention

After you close your 33pmw account — whether voluntarily or through suspension — we retain your personal data for a minimum period of five (5) years following account closure. This retention period is necessary to comply with our Anti-Money Laundering (AML) obligations, to respond to any legal claims or regulatory investigations that may arise after closure, and to honour our responsible gaming commitments (for example, to enforce self-exclusion periods).

5.3 Self-Excluded Players

If you have self-excluded from 33pmw, we are required to retain sufficient identifying data — including your name, date of birth, email address, and mobile number — for the full duration of your exclusion period (and for five years thereafter) in order to prevent you from registering a new account in violation of your self-exclusion agreement. This retention is mandatory and cannot be waived upon request.

5.4 Anonymisation

After the applicable retention period has expired, 33pmw will either securely delete your personal data or anonymise it so that it can no longer be associated with you as an individual. Anonymised, aggregated data (such as statistical betting patterns or platform usage trends) may be retained indefinitely for analytical purposes, as it no longer constitutes personal data.

Data Security

The security of your personal data is of paramount importance to 33pmw. We implement a comprehensive set of technical and organisational security measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure.

6.1 Technical Security Measures

• TLS/SSL Encryption: All data transmitted between your device and 33pmw servers is encrypted using Transport Layer Security (TLS) with a minimum of 256-bit encryption.
• Password Hashing: Your account password is never stored in plain text. We use a strong, salted hashing algorithm (bcrypt) to store password data, meaning that even in the hypothetical event of a data breach, your actual password cannot be recovered from the stored hash.
• Two-Factor Authentication (2FA): We strongly recommend enabling 2FA on your 33pmw account. When enabled, logging in requires both your password and a one-time code sent to your registered mobile number.
• Access Controls: Internal access to player personal data is restricted on a strict need-to-know basis. All staff with data access undergo background checks and receive regular data security training.
• Intrusion Detection: Our platform is monitored continuously by automated intrusion detection and anomaly-detection systems. Any unusual activity triggers immediate alerts to our security team.

6.2 Organisational Security Measures

Beyond technical safeguards, 33pmw maintains a comprehensive internal security policy framework. All employees and contractors who handle personal data are bound by confidentiality obligations and receive regular training on data protection best practices. Our security posture is reviewed and tested on a scheduled basis through internal and external assessments.

6.3 Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, 33pmw will notify affected players without undue delay — and in any case within 72 hours of becoming aware of the breach — via the email address registered to their account. The notification will describe the nature of the breach, the categories of data affected, the likely consequences, and the measures taken or proposed to address it.

Your Privacy Rights

As a 33pmw player, you have a number of important rights with respect to the personal data we hold about you. We are committed to honouring these rights promptly and transparently. To exercise any of the rights described below, please contact our support team at [email protected] with the subject line "Privacy Rights Request".

7.1 Right of Access

You have the right to request a copy of all personal data that 33pmw holds about you. We will provide this information in a structured, commonly used, machine-readable format within 30 days of receiving your request. There is no fee for a standard access request.

7.2 Right to Rectification

If any personal data we hold about you is inaccurate, incomplete, or out of date, you have the right to request that we correct it. You can update certain account details (such as your email address, mobile number, and residential address) directly through your account settings. For changes to identity-verified information such as your legal name or date of birth, please contact support and provide supporting documentation.

7.3 Right to Erasure

You may request that we delete your personal data in certain circumstances — for example, if the data is no longer necessary for the purpose for which it was collected, or if you withdraw your consent (where consent was the lawful basis for processing). Please note that this right is subject to important exceptions: we are required to retain certain data by law (for AML and KYC compliance purposes), and we cannot erase data that we are legally obligated to keep during the applicable retention period.

7.4 Right to Data Portability

You have the right to receive a portable copy of the personal data you have provided to 33pmw in a structured, machine-readable format (such as CSV or JSON). This right applies to data processed on the basis of your consent or for the performance of a contract with you.

7.5 Right to Object and Restrict Processing

You have the right to object to the processing of your personal data where we rely on legitimate interests as our lawful basis, and to request that we restrict processing in certain circumstances (for example, while we investigate a rectification request or a challenge to the lawfulness of processing). Objections to marketing communications will always be honoured without exception.

7.6 How to Exercise Your Rights

To submit a privacy rights request, email us at [email protected] with the subject line "Privacy Rights Request". Please include your full name, the email address registered to your 33pmw account, and a clear description of the right you wish to exercise. We will acknowledge your request within 48 hours and aim to provide a full response within 30 days. In complex cases, we may extend this period by a further 30 days with notice.

Contact & Policy Updates

8.1 Data Controller Contact

33pmw is the data controller responsible for the personal data collected through the platform at https://33pmw.net. If you have any questions, concerns, or complaints about this Privacy Policy or about how we handle your personal data, please contact us at:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: "Privacy Policy Enquiry"
• Response Time: We aim to respond to all privacy-related enquiries within 2 business days (Bangladesh Standard Time, UTC+6).

8.2 Updates to This Privacy Policy

33pmw 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 functionality. When we make material changes to this policy, we will notify registered players via email to their registered address and post a prominent notice on the 33pmw platform for a minimum of 30 days following the change. The effective date at the top of this document will always reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically so that you remain informed about how we protect your personal data. Your continued use of the 33pmw platform after a policy update constitutes your acknowledgement of the revised terms. If you do not agree with any material change to this policy, you have the right to close your account and request deletion of your data (subject to our legal retention obligations described in Section 5).

8.3 Governing Principles

This Privacy Policy is guided by internationally recognised data protection principles, including purpose limitation, data minimisation, storage limitation, accuracy, integrity, confidentiality, and accountability. 33pmw is committed to processing your personal data lawfully, fairly, and transparently at all times. Our platform is designed and maintained with privacy considerations embedded at every layer — from our server infrastructure and database access controls to our internal staff training programmes and third-party vendor management processes.

We remain committed to earning and maintaining the trust of every player across Bangladesh — from Dhaka and Chittagong to Sylhet, Khulna, Rajshahi, Barisal, Rangpur, and beyond. Your privacy is not an afterthought at 33pmw; it is a foundational commitment that shapes everything we build.