35bd2 Privacy Policy
How We Handle Your Personal Data

35bd2 collects personal information from players in order to operate a safe, compliant, and enjoyable online gaming platform. We collect only the information that is necessary for the purposes described in this Privacy Policy, and we do not collect sensitive data beyond what is required for identity verification, payment processing, and responsible gaming compliance.

The categories of personal information we collect are set out in the table below:

We may also collect personal information indirectly — for example, where a player contacts us via a third-party channel, or where we receive information from a payment provider as part of a transaction dispute. In all such cases, the data received is handled in accordance with this Privacy Policy.

35bd2 processes personal data only for legitimate, clearly defined purposes. We do not use your data for any purpose that is incompatible with the reasons for which it was originally collected. The primary purposes for which 35bd2 uses personal data are as follows:

• Account creation and management: To register your player account, verify your identity, maintain your account settings, and enable you to access all platform features including deposits, withdrawals, and gaming activity.
• Transaction processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate records of all financial transactions associated with your account in BDT.
• Identity and age verification (KYC): To confirm that you are aged 18 or above and that the personal details you have provided are accurate and genuine, in compliance with our anti-money laundering (AML) obligations.
• Customer support: To respond to your enquiries, resolve disputes, investigate complaints, and provide assistance via live chat and email at [email protected].
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, money laundering, bonus abuse, and other violations of our Terms & Conditions. This includes device fingerprinting, IP analysis, and behavioural pattern monitoring.
• Responsible gaming compliance: To monitor player behaviour for signs of problem gambling, enforce self-imposed deposit limits and self-exclusion requests, and provide appropriate intervention where required under our Responsible Gaming Policy.
• Platform improvement: To analyse aggregated, anonymised usage data in order to improve the design, performance, and content of the 35bd2 platform, including game lobby curation, payment flow optimisation, and mobile user experience improvements for Bangladesh-based players.
• Marketing communications (with consent): To send promotional emails and SMS notifications about bonuses, cricket season offers, BPL promotions, and new game launches — but only where you have given explicit consent to receive such communications. You may withdraw consent at any time.
• Legal compliance: To comply with applicable legal obligations, respond to lawful requests from authorities, and enforce our Terms & Conditions.

35bd2 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only with carefully selected partners and service providers who assist in the operation of the 35bd2 platform, and only to the extent necessary for them to perform their specific function. All third-party partners who process personal data on our behalf are contractually required to handle that data securely and in accordance with applicable data protection standards.

The categories of third parties with whom 35bd2 may share personal data are as follows:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, and Mastercard payment infrastructure providers receive transaction reference data necessary to process deposits and withdrawals. These providers operate under their own published privacy policies and are independently certified for payment security.
• Game content providers: Third-party game studios including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised session identifiers to enable game functionality. These providers do not receive your name, contact details, or financial information.
• Identity verification services: Third-party KYC and AML compliance providers may process identity documents you submit for age and identity verification. These providers are contractually bound to use your documents solely for the verification purpose for which they were submitted.
• Customer support platform: Our live chat and email support infrastructure provider processes the content of your support interactions to enable 35bd2's customer service team to assist you. Support transcripts are retained for quality assurance and dispute resolution purposes.
• Analytics providers: Anonymised, aggregated technical and usage data may be processed by analytics platforms to help 35bd2 understand platform performance. No personally identifiable information is shared in this context.
• Legal and regulatory authorities: 35bd2 may be required to disclose personal data to law enforcement agencies, regulatory bodies, or courts in response to a lawful request, court order, or legal obligation. In such cases, we will disclose the minimum information required to satisfy the legal requirement.

35bd2 will never share your personal data with third parties for the purposes of direct marketing by those third parties, nor will we share your data with any political organisations, religious bodies, or commercial advertisers unrelated to the 35bd2 platform.

35bd2 uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your login session, detect fraud, and understand how players interact with the site. By continuing to use the 35bd2 platform, you consent to the use of cookies in accordance with this policy.

The types of cookies used by 35bd2 are described below:

You may manage or disable non-essential cookies through your browser settings. Please note that disabling functional or analytical cookies may affect certain features of the 35bd2 platform, such as saved preferences and session continuity. Disabling strictly necessary cookies will prevent you from logging in or using core platform features.

35bd2 implements a layered security architecture to protect personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures are reviewed and updated on a regular basis to address evolving threats and to reflect current best practices in online data protection.

The key security controls in place at 35bd2 include:

• 256-bit SSL/TLS encryption on all data transmitted between player devices and 35bd2 servers, regardless of the network or device used.
• Encrypted data storage for sensitive personal data fields including identity document references and payment identifiers, using AES-256 encryption at rest.
• Role-based access control (RBAC) ensuring that only authorised 35bd2 personnel with a specific operational need can access personal data. Access logs are maintained and reviewed regularly.
• Two-factor authentication (2FA) available for all player accounts via SMS OTP, and mandatory for all 35bd2 administrative staff accounts.
• Automated intrusion detection systems that monitor server infrastructure for unusual access patterns and trigger immediate alerts to the security team.
• Regular penetration testing conducted by independent security professionals to identify and remediate vulnerabilities in the 35bd2 platform before they can be exploited.
• Incident response protocol: In the event of a data security incident that affects personal data, 35bd2 will notify affected players by email within 72 hours of becoming aware of the breach, providing details of the nature of the incident, the data affected, and the steps being taken to contain and remediate it.

As a player on the 35bd2 platform, you have a number of rights in relation to the personal data we hold about you. 35bd2 is committed to honouring these rights in a timely and transparent manner. To exercise any of the rights listed below, please contact us at [email protected] with the subject line "Privacy Rights Request" and include your registered account email address and the specific right you wish to exercise.

• Right of access: You have the right to request a copy of all personal data that 35bd2 holds about you. We will provide this information in a structured, commonly used, machine-readable format within a reasonable timeframe following identity verification.
• 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 update basic account details (such as your contact email or phone number) directly from within the 35bd2 account dashboard.
• Right to erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent (and no other legal basis for processing exists), or where you object to processing and there is no overriding legitimate interest. Please note that certain data must be retained by 35bd2 for legal and regulatory compliance purposes (see Section 7) and cannot be erased on request during the applicable retention period.
• Right to restrict processing: In certain circumstances, you have the right to request that 35bd2 restricts its processing of your personal data — for example, while a dispute about the accuracy of the data is being resolved.
• Right to data portability: You have the right to receive personal data you have provided to 35bd2 in a structured, commonly used format, and to transmit that data to another controller where technically feasible.
• Right to object to marketing: You have an absolute right to object to the processing of your personal data for direct marketing purposes at any time. Once you exercise this right, 35bd2 will cease all marketing communications immediately. You may do this via the account dashboard communication preferences or by emailing [email protected].
• Right to withdraw consent: Where 35bd2 processes your data on the basis of consent (principally for marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing that took place prior to the withdrawal.

35bd2 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Once personal data is no longer required for any of these purposes, it is securely deleted or anonymised so that it can no longer be linked to an individual player.

The following retention periods apply to the main categories of personal data held by 35bd2:

When an account is closed — whether at the player's request or by 35bd2 as a result of a terms violation — active access to the platform is terminated immediately. The retention periods above refer to the underlying data records maintained for compliance purposes only, to which the player no longer has active access but which 35bd2 is legally obligated to retain.

At the end of each applicable retention period, personal data is permanently deleted from 35bd2's live systems and backup archives through a secure data disposal process. Anonymised, aggregated statistical data derived from player activity may be retained indefinitely for platform analytics purposes, provided that it can no longer be linked to any identifiable individual.

35bd2 reserves the right to update, revise, or replace any part of this Privacy Policy at any time. Updates may be made in response to changes in applicable law, new data processing activities introduced as part of platform development, changes to third-party service providers, or improvements in our data protection practices.

When material changes are made to this Privacy Policy — meaning changes that significantly affect how your personal data is collected, used, or shared — 35bd2 will notify registered players by email to their registered address and by posting a prominent notice on the 35bd2 platform. The updated policy will take effect on the date stated in the revised document. Your continued use of the 35bd2 platform after the effective date constitutes acceptance of the updated Privacy Policy.

Minor or non-material updates (such as formatting corrections, clarification of existing practices, or removal of outdated references) may be made without notice. The "Last Reviewed" date at the top of this page will always reflect the date of the most recent update, whether material or non-material.

This Privacy Policy is governed by and construed in accordance with applicable data protection principles. The English language version of this policy is the sole authoritative text. In the event of any conflict between this English-language policy and any translation produced for informational purposes, the English text shall prevail.

35bd2 is committed to maintaining the highest standards of data privacy and player protection. We review this policy at minimum once per calendar year and update it whenever our practices change. We encourage all players to revisit this page periodically to stay informed about how their personal data is being used.