Privacy Policy — 35bdcom Data Commitment

Data You Provide Directly: When you create and operate a 35bdcom account, we collect the following categories of personal data:

Data Collected Automatically: When you visit and use the 35bdcom platform, we automatically collect certain technical data, including your IP address, device type and operating system, browser type and version, session start and end times, pages visited, games played, bets placed, and in-session behaviour patterns. This data is collected via server logs, session cookies, and analytics tools operated by or on behalf of 35bdcom.

Payment Transaction Data: For every deposit and withdrawal you initiate, 35bdcom logs the transaction amount in Bangladeshi Taka (৳), the payment method used, the transaction timestamp, the transaction reference number issued by the payment provider (bKash, Nagad, Rocket, Upay, Visa, or Mastercard), and the outcome status. Full payment card numbers are never stored by 35bdcom — payment processing is handled by certified payment gateways using tokenisation.

Gameplay and Betting Data: We maintain records of all bets placed, games launched, session durations, win and loss outcomes, bonus claims, and wagering activity on your account. This data is retained for operational integrity, dispute resolution, responsible gaming monitoring, and regulatory compliance purposes.

The primary purposes for which 35bdcom processes your personal data are as follows:

• Account Creation and Management: To register your account, authenticate your identity at login, manage your account settings, and communicate essential account-related notices to you.
• Payment Processing: To process deposit and withdrawal transactions through bKash, Nagad, Rocket, Upay, Visa, and Mastercard; to reconcile transaction records; and to investigate and resolve any payment disputes.
• Identity and Age Verification (KYC): To verify that you are at least 18 years of age and to confirm your identity in accordance with anti-money-laundering (AML) and know-your-customer (KYC) obligations. 18+
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, duplicate account creation, and any other conduct that violates our Terms & Conditions or applicable law.
• Platform Operations and Improvement: To monitor platform performance, diagnose technical faults, analyse user behaviour patterns to improve game selection and user interface design, and optimise the overall player experience for the Bangladesh market.
• Responsible Gaming Monitoring: To track betting patterns that may indicate problem gambling behaviour; to apply deposit limits, cool-off periods, and self-exclusion measures requested by the player; and to proactively reach out to players who exhibit high-risk patterns.
• Customer Support: To respond to your queries, process complaints, and maintain records of support interactions for quality assurance and dispute resolution purposes.
• Promotional Communications: Where you have opted in to receive marketing communications, to send you information about promotions, new games, and seasonal offers relevant to you. You may withdraw this consent at any time via your account notification settings or by contacting support.
• Legal and Regulatory Compliance: To comply with applicable legal obligations including tax reporting, financial crime reporting, and response to lawful requests from competent authorities.

35bdcom does not use automated decision-making processes (including profiling) that produce legal or similarly significant effects on players without human oversight. Where automated tools are used to flag potentially problematic gambling behaviour or suspicious transactions, a human compliance team member reviews flagged cases before any account action is taken.

• Contractual Necessity: Processing your identity data, contact data, and financial data is necessary to fulfil the contract between you and 35bdcom — specifically, to create and operate your account, process deposits and withdrawals, and provide access to the games and betting markets you have registered to use.
• Legal Obligation: Processing for KYC/AML identity verification, age verification, fraud reporting, and tax compliance is required by applicable financial crime prevention and consumer protection obligations. We cannot waive these obligations.
• Legitimate Interests: Processing for platform security, fraud detection, responsible gaming monitoring, customer support quality, and platform analytics is carried out on the basis of 35bdcom's legitimate interest in operating a safe, fair, and sustainable gambling platform. We have assessed that these interests are not overridden by your privacy interests in each case.
• Consent: Processing for marketing communications (promotional emails, bonus notifications) is based on your explicit opt-in consent obtained at registration or subsequently through your account settings. You may withdraw consent at any time with effect going forward.

Payment Service Providers: Transaction data is shared with bKash, Nagad, Rocket, Upay, and card network processors (Visa, Mastercard) solely to execute the payment instructions you initiate. These providers process your financial data under their own privacy policies and are independently responsible for their data handling practices.

Identity Verification Partners: Where 35bdcom uses a third-party KYC service provider to assist with age and identity verification, your submitted identity documents and personal details will be shared with that provider for the sole purpose of verification. KYC partners are contractually bound to process data only for verification and to apply appropriate security standards.

Game Technology Providers: Game providers such as Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi may receive your account identifier and session data in order to launch and operate game sessions on your device. These providers do not receive your full name, payment details, or identity documents — only the minimum session data required for game functionality.

IT Infrastructure and Security Providers: 35bdcom uses cloud infrastructure and cybersecurity service providers to host the platform and protect it from technical threats. These providers act as data processors under contractual data processing agreements and may process data only as instructed by 35bdcom.

Legal and Regulatory Authorities: In response to a lawful court order, regulatory direction, or law enforcement request, 35bdcom may be required to disclose specific personal data to competent authorities. We will notify you of any such disclosure where we are legally permitted to do so.

Business Transfers: In the event of a merger, acquisition, or transfer of ownership of 35bdcom or any substantial part of its assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy. You will be notified of any such transfer in advance.

A cookie is a small text file placed on your device by a website you visit. Cookies are widely used to make websites work efficiently and to provide information to site operators. 35bdcom uses the following categories of cookies:

35bdcom does not deploy third-party advertising cookies, social media tracking pixels, or cross-site behavioural profiling technologies. The analytics data collected through cookies is used internally by 35bdcom and is not shared with advertising networks.

Managing Cookies: You can control cookie behaviour through your browser settings. Most browsers allow you to refuse all cookies, accept only certain types, or delete existing cookies. Please note that disabling strictly necessary cookies will prevent the 35bdcom platform from functioning correctly — you will not be able to log in or maintain a session without them. Disabling functional or analytics cookies will not prevent platform access but may affect your experience.

For detailed guidance on managing cookies in your specific browser, refer to your browser's help documentation. Bangladesh Standard Time (BST, UTC+6) timestamps are used in all session and cookie expiry records.

The following retention periods apply to the main categories of personal data processed by 35bdcom:

• Account and Identity Data: Retained for the duration of your active account plus 5 years following permanent account closure, to satisfy AML and financial crime record-keeping obligations.
• Financial Transaction Records: Retained for 5 years from the date of each transaction in accordance with standard financial record-keeping practice.
• KYC and Verification Documents: Retained for the duration of account activity plus 5 years post-closure. Physical document copies (scanned images) are securely deleted at the end of the retention period.
• Customer Support Correspondence: Retained for 2 years from the date of the last interaction in a given support thread, after which records are anonymised.
• Marketing Consent Records: Retained for as long as you remain subscribed plus 2 years following unsubscription, to demonstrate the history of consent in the event of a query.
• Analytical and Behavioural Data: Aggregated analytics data is anonymised after 13 months. Raw session log data is retained for up to 6 months for security and debugging purposes, then deleted.
• Responsible Gaming Records: Records of self-exclusion requests, deposit limits, and cool-off periods are retained for the full duration of the restriction plus 3 years, to prevent circumvention through re-registration.

At the end of the applicable retention period, personal data is either securely deleted from all live and backup systems or irreversibly anonymised such that it can no longer be associated with any identifiable individual. 35bdcom conducts periodic data retention reviews to ensure compliance with these schedules.

The technical and organisational security measures applied by 35bdcom include:

• TLS/SSL Encryption: All data in transit between your device and 35bdcom servers is encrypted using TLS 1.2 or higher. This applies to all account pages, the cashier, and the game lobby.
• Password Hashing: Account passwords are never stored in plain text. 35bdcom uses a strong, salted cryptographic hashing algorithm to store password credentials. Even 35bdcom staff cannot view your password.
• Access Controls: Access to personal data within 35bdcom's internal systems is restricted on a strict need-to-know basis. Staff access to player data is logged and audited. Administrative access requires multi-factor authentication.
• Payment Tokenisation: Full payment card numbers are never stored by 35bdcom. Card processing is handled by PCI-DSS-compliant payment gateways that return only tokenised references for subsequent transaction use.
• Intrusion Detection and Monitoring: 35bdcom operates continuous security monitoring across its server infrastructure to detect and respond to anomalous access patterns, attempted intrusions, and other security events.
• Data Backup and Recovery: Regular encrypted backups of all critical data are maintained with geographically separated redundancy. Backup access is subject to the same access control restrictions as live data.
• Vendor Security Due Diligence: All third-party service providers who process personal data on behalf of 35bdcom are subject to a security assessment before onboarding and are contractually required to maintain security standards at least equivalent to those applied by 35bdcom.

Data Breach Response: In the event of a personal data breach that is likely to result in a risk to your rights, 35bdcom will notify affected players without undue delay and will describe the nature of the breach, the categories of data affected, the likely consequences, and the remedial measures being taken. 35bdcom will also report any qualifying breach to relevant authorities in accordance with applicable obligations.

• Right of Access: You have the right to request a copy of all personal data that 35bdcom holds about you. We will respond to verified access requests within 30 days, providing a structured summary of your data.
• 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. For most data fields, you can update information directly through your account profile settings.
• Right to Erasure: You may request that 35bdcom delete your personal data where it is no longer necessary for its original purpose, where you have withdrawn consent (and no other legal basis applies), or where you believe we are processing it unlawfully. This right is subject to retention obligations that may require us to retain certain records for a defined period.
• Right to Restriction: In certain circumstances — for example, while you are contesting the accuracy of data we hold, or while a complaint is under investigation — you may request that we restrict active processing of your data without deleting it.
• 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, machine-readable format so that you can transfer it to another service if you choose.
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming monitoring. 35bdcom will assess your objection and cease processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent — such as marketing communications — you may withdraw that consent at any time through your account notification settings or by emailing [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

To exercise any of the above rights, contact us at [email protected] with the subject line "Privacy Rights Request — [Your Account Reference]". We will verify your identity before processing any request and will respond within 30 days. Complex or high-volume requests may take up to 60 days; we will notify you if an extension is needed.

The 35bdcom platform does not contain links to external third-party websites for commercial or advertising purposes. However, certain game interfaces provided by third-party developers (Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Ezugi, and others) operate within their own technical environments. When you launch a game, your session data is passed to the game provider's system as described in the Data Sharing section above.

35bdcom is not responsible for the privacy practices of third-party game providers operating within their own platforms. Players are encouraged to review the privacy documentation of game technology providers where they wish to understand how those providers handle session data. 35bdcom does not control or oversee the internal data processing practices of independent game studios beyond the contractual obligations described in this policy.

35bdcom operates an 18+ only platform. 18+ We do not knowingly collect, store, or process personal data belonging to individuals under the age of 18. The registration process requires users to confirm that they are at least 18 years of age, and all accounts are subject to age verification before withdrawal processing.

If 35bdcom becomes aware that personal data has been collected from a person under the age of 18, we will immediately close the associated account, delete the personal data from our systems to the extent permitted by AML obligations, and return any real-money balance to the original deposit source where technically possible. Any winnings accrued on the account will be voided in accordance with our Terms & Conditions.

If you believe that a person under the age of 18 has created an account on 35bdcom, please notify us immediately at [email protected] with the relevant account information. We take all such reports seriously and will investigate and act without delay.

35bdcom may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable law, or improvements to our platform's privacy architecture. When material changes are made to this policy, we will notify registered players via the email address or mobile number associated with their account, or by displaying a prominent notice within the platform upon next login.

The effective date shown at the top of this page indicates when the current version of the policy came into force. Previous versions of this Privacy Policy are retained internally and are available on request by contacting our Data Protection contact. Your continued use of the 35bdcom platform after the stated effective date of any revision constitutes your acknowledgement that you have read and understood the updated policy.

Minor clarifications, typographical corrections, and non-substantive formatting changes may be made without individual player notification. Only changes that materially affect how your personal data is collected, used, shared, or retained will trigger the formal notification process described above.

General Privacy Enquiries:
Email: [email protected]
Subject line: "Privacy Enquiry — [Your Account Reference]"
Response time: Within 2–6 hours during Bangladesh Standard Time (BST, UTC +6) business hours.

Data Protection Contact:
For formal data subject rights requests (access, erasure, portability, rectification, objection), please email: [email protected]
Subject line: "Privacy Rights Request — [Your Account Reference]"
We will acknowledge your request within 2 business days and provide a full response within 30 days.

Postal Correspondence:
35bdcom operates as an online-only platform serving the Bangladesh market. All formal privacy correspondence should be directed to our support email address above. We do not maintain a publicly listed postal address for player correspondence.

35bdcom takes all privacy complaints seriously. If you raise a privacy concern with us and you are not satisfied with our response, you retain the right to escalate your complaint to the relevant data protection authority or consumer protection body in your jurisdiction. We encourage players to contact us first so that we have the opportunity to resolve any concern directly and efficiently.