35bd Privacy Policy —
How We Handle Your Data

35bd is an online casino and sports betting platform serving adult players in the Bangladesh market. The 35bd platform enables players to participate in casino games, live dealer tables, slots, crash games, and sports betting markets including cricket fixtures involving the Bangladesh Tigers, the Bangladesh Premier League (BPL), the IPL, and international T20 tournaments.

In the course of providing these services, 35bd necessarily collects and processes personal information about its players. 35bd is committed to handling this information responsibly, transparently, and in a manner consistent with applicable data protection principles. This Policy sets out the full detail of that commitment.

This Policy applies to all personal data collected via the 35bd website at https://35bd.bar, via any mobile-optimised version of that website, and via any communications between you and the 35bd support team including email, live chat, and any other support channel operated by 35bd. It does not apply to third-party websites or services that may be accessible via links from the 35bd platform — those third parties operate their own privacy practices independently of 35bd.

35bd operates this platform as a safe and reliable service using SSL encryption and fair play certified game providers. 35bd does not claim regulatory approval from any specific Bangladeshi government body and does not fabricate licensing information of any kind. All data protection commitments in this Policy reflect 35bd's genuine operational practices.

35bd collects personal data through several channels: directly from you during registration and account management, automatically through your use of the platform, and from third-party verification and payment service providers. The categories of personal data 35bd may collect include:

35bd does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data (beyond standard ID verification photographs), or data concerning health conditions, except where health-related information is voluntarily disclosed in the context of a responsible gaming self-exclusion request, in which case it is used solely to act on that request.

35bd uses the personal data it collects for the following purposes, each of which is tied to a specific legitimate operational or legal need:

• Account Creation and Management: To register and maintain your 35bd player account, verify your identity in accordance with our KYC obligations, manage your account settings and preferences, and provide access to the full range of platform features.
• Payment Processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, and supported Bangladeshi banking channels. Financial data is shared with payment processors solely to the extent necessary to complete the requested transaction.
• Regulatory Compliance and Fraud Prevention: To fulfil our anti-money laundering (AML) and know your customer (KYC) obligations, detect and prevent fraudulent activity, identify and investigate multi-accounting, and comply with any lawful requests from competent authorities.
• Platform Delivery and Improvement: To operate the 35bd platform reliably, diagnose technical faults, analyse gameplay patterns in aggregate to improve the platform experience, and develop new features and services that serve the Bangladesh market.
• Responsible Gaming: To monitor gameplay behaviour for indicators of problem gambling, apply responsible gaming tools (deposit limits, session reminders, self-exclusion) at your request or proactively where warranted, and fulfil our duty of care to adult players.
• Marketing and Promotions: To send you relevant promotional communications — including bonus offers tied to cricket events such as BPL and IPL seasons, Eid promotions, and Pohela Boishakh offers — where you have opted in to receive such communications. You may opt out at any time by contacting support or updating your account communication preferences.
• Customer Support: To respond to your support queries, resolve disputes, process complaints, and maintain records of interactions for quality assurance and training purposes.
• Security: To protect the integrity of player accounts, detect unauthorised access, and maintain the overall security of the 35bd platform and its users' data.

35bd will not use your personal data for any purpose that is incompatible with the purposes described in this Policy without first obtaining your explicit consent or establishing a separate legal basis for the new processing activity.

35bd processes personal data on the basis of one or more of the following lawful grounds depending on the specific processing activity in question:

• Contractual Necessity: Processing is necessary to perform the contract between you and 35bd (i.e., operating your account, processing bets, handling payments). Without this processing, 35bd cannot provide its services to you.
• Legal Obligation: Processing is required in order to comply with applicable legal obligations, including anti-money laundering regulations, KYC requirements, and lawful requests from competent regulatory or law enforcement authorities.
• Legitimate Interests: Processing is carried out in pursuit of 35bd's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where these interests are not overridden by your rights and interests.
• Consent: Where processing is based on your consent (primarily in the context of direct marketing communications), you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Where 35bd relies on legitimate interests as its legal basis, it conducts a balancing assessment to ensure that those interests do not override your fundamental rights and freedoms. You may request information about these balancing assessments by contacting the 35bd support team.

35bd does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing or commercial purposes under any circumstances. Personal data is shared only in the following limited and controlled circumstances:

• Payment Service Providers: Transaction data is shared with bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, and other payment partners solely to process your deposit and withdrawal instructions. These providers operate under their own privacy policies and are contractually prohibited from using your data beyond the scope of transaction processing.
• Game Content Providers: Certain gameplay data (such as bet records and session identifiers) is shared with certified game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi to facilitate game delivery, resolve game disputes, and support RNG audit processes. Game providers do not receive personally identifiable information beyond what is necessary for these technical purposes.
• Identity Verification and KYC Services: Identity and verification documents may be processed by third-party KYC and AML compliance service providers engaged by 35bd to fulfil its due diligence obligations. These providers are bound by strict confidentiality agreements and may only process data for the specified KYC purpose.
• Fraud Detection and Security Services: Technical data including IP addresses and device fingerprints may be shared with cybersecurity and fraud detection service providers for the purpose of identifying and preventing fraudulent activity, multi-accounting, and unauthorised platform access.
• Legal and Regulatory Disclosure: 35bd may disclose personal data to law enforcement agencies, regulatory bodies, or courts where required to do so by applicable law or a valid legal process. 35bd will endeavour to notify you of such disclosures where permitted by law.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of 35bd's business, personal data held by 35bd may be transferred to the acquiring entity. You will be notified of any such transfer and any material change to the applicable privacy terms in advance.

35bd's primary player base is in Bangladesh, and the platform is designed to serve the Bangladesh market. However, certain technical and operational service providers engaged by 35bd may be located in countries outside Bangladesh, which means that some personal data may be transferred to and processed in countries other than Bangladesh in the course of delivering platform services.

Wherever personal data is transferred internationally, 35bd ensures that appropriate safeguards are in place to protect the data to a standard equivalent to the protections described in this Policy. These safeguards include contractual data processing agreements with all service providers that impose binding confidentiality, security, and data minimisation obligations consistent with recognised international data protection standards.

35bd does not transfer personal data to any third party located in a country where such a transfer would materially reduce the protections available to you as a data subject. If you have specific concerns about international data transfers in connection with your 35bd account, please contact the support team at [email protected].

35bd retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any applicable legal, accounting, or reporting obligations. The following retention principles apply:

• Active Account Data: Personal data associated with an active 35bd account is retained throughout the lifetime of the account and for a period of five (5) years following permanent account closure, to satisfy AML record-keeping requirements and to allow for the resolution of any post-closure disputes or legal proceedings.
• Transaction Records: Detailed records of all deposits, withdrawals, and betting transactions are retained for a minimum period of five (5) years following the date of the transaction, in accordance with applicable financial record-keeping obligations.
• KYC and Verification Documents: Identity verification documents submitted during the KYC process are retained for five (5) years following account closure or the date of last transaction, whichever is later, in accordance with anti-money laundering requirements.
• Support Communications: Records of customer support interactions are retained for three (3) years following the closure of the relevant support ticket or complaint, for quality assurance and dispute resolution purposes.
• Marketing Data: Email and SMS marketing preference records are retained until you withdraw consent or for three (3) years following your last engagement with a marketing communication from 35bd, whichever occurs first.
• Technical Logs: Server-side technical logs including IP access records are retained for twelve (12) months for security monitoring and fraud investigation purposes, after which they are permanently deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original personal data. Anonymised, aggregated data (from which individual players cannot be identified) may be retained indefinitely for statistical and analytical purposes.

35bd uses cookies and similar tracking technologies on the platform to deliver a functional, personalised, and secure user experience. A cookie is a small text file stored on your device by your browser when you visit the 35bd website. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the operation of the 35bd platform. They enable core functionality such as account login session management, security token validation, and load balancing across servers. The platform cannot function correctly without these cookies, and they cannot be disabled.
• Performance and Analytics Cookies: These cookies collect aggregated, anonymised information about how players use the platform — such as which pages are visited most frequently and how long sessions last. This data is used by 35bd to identify opportunities to improve the platform experience. No personally identifiable information is collected by performance cookies.
• Functionality Cookies: These cookies remember your platform preferences such as language settings, display preferences, and responsible gaming limit configurations, so that these settings persist across sessions without requiring you to re-enter them each time you visit.
• Fraud Prevention Cookies: These cookies support 35bd's fraud detection systems by helping to identify unusual access patterns, suspicious device behaviour, and potential multi-account scenarios. They form part of the platform's broader security infrastructure.

35bd does not use advertising cookies or behavioural tracking cookies that share your browsing behaviour with external advertising networks. No third-party advertising pixels or retargeting scripts are deployed on the 35bd platform.

You may control cookie behaviour through your browser settings. Note that disabling strictly necessary cookies will impair or prevent your ability to log in and use the 35bd platform. For other cookie categories, disabling cookies in your browser will not affect your ability to access the platform but may reduce the quality of the personalised experience.

As a player on the 35bd platform, you hold the following rights with respect to the personal data that 35bd holds about you. To exercise any of these rights, please contact the 35bd support team at [email protected] with the subject line "Data Rights Request — [Your Account Username]".

• Right of Access: You have the right to request a copy of the personal data that 35bd holds about you, along with information about the purposes for which it is processed, the categories of data involved, and any third parties to whom it has been disclosed.
• Right to Rectification: If any personal data held by 35bd is inaccurate or incomplete, you have the right to request that it be corrected or completed. 35bd will action verified correction requests promptly.
• Right to Erasure: You may request that 35bd delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (where consent was the basis for processing), or where the data has been unlawfully processed. Note that erasure requests may not be fulfilled where retention is required by applicable law (e.g., AML record-keeping obligations).
• Right to Restriction of Processing: You may request that 35bd restrict the processing of your data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing and that objection is pending assessment.
• Right to Data Portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider.
• Right to Object: You have the right to object to processing based on legitimate interests at any time. You also have an unconditional right to object to the processing of your personal data for direct marketing purposes, which 35bd will action immediately upon receipt of your objection.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without detriment. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.

35bd aims to respond to all verified data rights requests within thirty (30) days of receipt. Complex or multiple requests may require additional time, in which case 35bd will notify you of the extended timeline within the initial thirty-day window.

The 35bd platform is strictly intended for adults aged 21 years and above. 35bd does not knowingly collect, process, or store personal data relating to individuals under the age of 21. Online gambling by persons under the age of 21 is strictly prohibited on the 35bd platform without exception.

If 35bd becomes aware that personal data has been submitted by or on behalf of a person under the age of 21, that data will be deleted immediately and the associated account will be permanently closed. Any deposits made by an underage individual will be returned to the originating payment method, net of any amounts that cannot be recovered due to third-party payment constraints.

If you are a parent or guardian and believe that a minor in your care has registered with 35bd or has submitted personal data to the platform, please contact the 35bd support team at [email protected] immediately. Include the subject line "Minor Account — Urgent" and provide as much detail as possible to allow 35bd to locate and close the account promptly.

35bd encourages parents and guardians of young people to make use of parental control software to prevent access to online gambling platforms. 35bd supports all efforts to prevent underage gambling and co-operates fully with responsible gaming initiatives targeting the Bangladesh market.

35bd implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in Transit: All data exchanged between your device and the 35bd platform is encrypted using 256-bit SSL/TLS protocols. This ensures that your login credentials, payment details, and personal information cannot be intercepted during transmission.
• Encryption at Rest: Sensitive personal data stored on 35bd servers — including financial records and identity documents — is encrypted at rest using AES-256 encryption standards.
• Access Controls: Access to personal data within 35bd's systems is restricted on a strict need-to-know basis. All staff with access to player data are subject to confidentiality obligations and receive regular data protection training.
• Two-Factor Authentication: 35bd strongly encourages all players to enable two-factor authentication (2FA) on their accounts. 2FA adds an additional layer of security by requiring a one-time verification code in addition to your password when logging in from a new device or location.
• Penetration Testing and Security Audits: 35bd conducts regular security assessments including penetration testing and vulnerability scanning to identify and remediate potential weaknesses in the platform's security infrastructure before they can be exploited.
• Intrusion Detection: 35bd operates continuous intrusion detection and monitoring systems that flag and respond to suspicious access patterns, unusual login behaviour, and potential data breach indicators in real time.
• Data Breach Response: In the event of a confirmed personal data breach that poses a risk to player rights and interests, 35bd will notify affected players without undue delay and will take all necessary steps to contain the breach, assess its scope, and prevent recurrence.

While 35bd applies robust security measures, no online platform can guarantee absolute security against all possible threats. Players are encouraged to use strong, unique passwords for their 35bd accounts, to enable 2FA, and to contact support immediately at [email protected] if they suspect any unauthorised access to their account.

The 35bd platform may from time to time contain references to or integrations with third-party services — including game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — whose game clients are delivered within the 35bd platform environment. Whilst 35bd takes care to engage only reputable, certified game providers, these providers operate their own independent privacy and data processing practices for data processed within their game engines.

35bd is not responsible for the privacy practices of any third-party game provider, payment processor, or any other external service whose functionality is integrated into or linked from the 35bd platform. Players are encouraged to review the privacy policies of third-party providers whose services they use via the 35bd platform.

This Policy applies exclusively to personal data processed directly by 35bd in connection with your use of the https://35bd.bar platform and the 35bd support channels. It does not extend to data processed independently by third-party providers within their own systems.

35bd reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, evolving data protection best practices, changes to the services offered by 35bd, or changes to the ways in which 35bd processes personal data. All updates will be effective from the date on which the revised Policy is published at https://35bd.bar/privacy-policy.

Where an update to this Policy involves a material change to the ways in which 35bd processes your personal data — particularly where that change affects processing activities based on your consent — 35bd will provide advance notice of the change via email to your registered address and/or via a prominent notice on the 35bd platform. In such cases, continued use of the platform following the effective date of the revised Policy will constitute acceptance of the updated terms.

For non-material updates — such as corrections of typographical errors, clarifications of existing language, or administrative changes that do not alter the substance of the Policy — 35bd may update the Policy without prior notice, though the "Last Updated" date at the top of the Policy will always reflect the date of the most recent revision.

Players are encouraged to review this Privacy Policy periodically to remain informed of how 35bd handles their personal data. If you disagree with any update to this Policy, you should discontinue use of the 35bd platform and contact support at [email protected] to discuss your options, including account closure.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way in which 35bd processes your personal data, please contact the 35bd support team using the details below. 35bd is committed to addressing all privacy-related enquiries promptly, professionally, and in accordance with the commitments set out in this Policy.

Email: [email protected]

When contacting 35bd regarding a data privacy matter, please include your registered username, the nature of your query or request, and any relevant reference numbers (such as a previous support ticket number) to allow the team to assist you as efficiently as possible. All privacy-related enquiries are handled in English, and our team operates across Bangladesh Standard Time (BST, UTC+6) hours, with responses targeted within 24 hours for standard queries and within one (1) hour for urgent matters such as suspected account compromise or data breach notifications.

If you are dissatisfied with 35bd's response to a privacy-related complaint, you may escalate the matter by submitting a formal written complaint to [email protected] with the subject line "Formal Privacy Complaint — [Your Account Username]". 35bd's data protection team will review all formal complaints within fourteen (14) days and provide a written resolution or interim update within that timeframe.