35bp Privacy Policy — How We Handle Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how 35bp ("we", "us", "the Platform") collects, uses, stores, shares, and protects personal data provided by users ("you", "User", "Player") of the 35bp website and all associated gaming and betting services. This Policy applies to all users of the platform regardless of the device or connection method used to access it.

By registering an account on 35bp or continuing to use the platform after this Policy has been published or updated, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must not use the platform.

This Policy should be read alongside the 35bp Terms and Conditions, which together form the complete agreement between you and 35bp governing your use of the platform. Capitalised terms not defined in this Policy have the meanings given to them in the Terms and Conditions.

2. Data We Collect

35bp collects personal data in the following categories. We collect only what is necessary for the purposes described in this Policy:

3. How We Use Your Data

35bp processes personal data for the following purposes. Each purpose is supported by a lawful basis as described in Section 4:

• Account creation and management: registering your account, verifying your identity (KYC), maintaining your account record, and processing account closure requests.
• Transaction processing: receiving and processing deposits via bKash, Nagad, Rocket, and Upay; settling winnings; and processing withdrawal requests to your registered payment wallet.
• Fraud prevention and platform security: screening transactions for fraudulent activity, detecting and investigating duplicate accounts, identifying unusual betting patterns, and protecting the integrity of sports betting markets.
• Responsible gaming compliance: monitoring account activity to identify behavioural patterns associated with problem gambling; delivering responsible gaming tools including deposit limit prompts and self-exclusion facilities; and responding to requests from users seeking to restrict their gaming activity.
• Customer support: responding to account queries, complaints, and disputes; providing information about platform services; and communicating the outcome of any investigation or review of your account.
• Platform improvement: using aggregated and anonymised usage data to understand how users navigate the platform, identify performance issues, and prioritise feature development. No individual user is identifiable from data used for this purpose.

35bp does not use personal data for automated decision-making that produces significant legal effects, with the exception of automated fraud screening systems that may flag an account for manual review where suspicious activity is detected. In such cases, a human review is always conducted before any account action is taken.

4. Legal Basis for Processing

35bp processes personal data on the following legal grounds:

• Contractual necessity: processing required to perform our obligations under the Terms and Conditions, including account management, transaction processing, and delivery of gaming services.
• Legal obligation: processing required to comply with applicable anti-money laundering obligations, Know Your Customer (KYC) requirements, fraud reporting duties, and any other legal or regulatory requirements applicable to 35bp's operations.
• Legitimate interests: processing for fraud prevention, platform security, and responsible gaming monitoring, where our interest in maintaining a safe and fair platform is not overridden by your privacy interests.
• Consent: where you have given explicit consent for a specific processing activity (for example, receiving promotional communications). You may withdraw consent at any time by contacting 35bp support, without affecting the lawfulness of processing carried out before withdrawal.

5. Data Sharing and Third Parties

35bp does not sell, rent, or trade personal data to third parties for marketing purposes. We share personal data only in the limited circumstances described below:

Service Providers and Data Processors

35bp engages trusted third-party service providers to support platform operations. These providers act as data processors under our instruction and are permitted to use your data only for the specific purpose for which they were engaged. Categories of processors include:

• Payment processing providers (including the technical infrastructure supporting bKash, Nagad, Rocket, and Upay integrations) — for the sole purpose of processing deposits and withdrawals on your account.
• Game content providers (Pragmatic Play, Evolution Gaming, Spribe, and other certified studios) — these providers operate their own game servers and necessarily receive session data required to run the game. Game providers have their own privacy policies governing their data practices.
• Identity verification and KYC service providers — who verify the authenticity of identity documents submitted during account verification. These providers process only the minimum data necessary to complete a verification check.
• Fraud prevention and platform security technology providers — who assist in detecting automated bot activity, identifying high-risk transactions, and monitoring for coordinated abuse patterns across accounts.

Disclosure Required by Law

35bp may disclose personal data to law enforcement authorities, regulatory bodies, or other competent authorities where required to do so by applicable law, court order, or valid legal process. Where legally permitted to do so, 35bp will attempt to notify the affected user of any such disclosure request before complying. In cases where disclosure is required urgently or where notification would prejudice an ongoing investigation, prior notification may not be possible.

6. Cookies and Tracking Technologies

35bp uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Essential cookies: strictly necessary for the platform to function. These cookies maintain your logged-in session, remember your language preference, and ensure security features operate correctly. They cannot be disabled without breaking core platform functionality.
• Analytics cookies: used to understand how users interact with the platform in aggregate. Data collected through analytics cookies is anonymised and used exclusively to improve platform performance and user experience. No individual user is identified through analytics data.
• Security cookies: used to detect and prevent fraudulent activity, bot interactions, and cross-site request forgery. These cookies are essential to platform integrity and cannot be disabled.

You can manage non-essential cookie preferences through your mobile browser settings. Please note that disabling certain cookies may affect your ability to use some platform features. 35bp does not use third-party advertising cookies or cross-site tracking for commercial advertising purposes.

7. Data Security

35bp implements technical and organisational measures designed to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. Security measures in place include SSL/TLS encryption for all data transmitted between your device and the 35bp platform, access controls limiting staff access to personal data on a strict need-to-know basis, secure storage of KYC documents with restricted access permissions, and regular security assessments of platform infrastructure.

No data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. While 35bp takes all reasonable steps to protect your personal data, we cannot warrant absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 35bp will notify affected users as required by applicable law.

8. Data Retention

35bp retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal and regulatory retention obligations. The following general retention periods apply: account data and transaction records are retained for a minimum of five years following account closure to meet anti-money laundering record-keeping requirements; KYC documentation is retained for the same period; gaming activity logs are retained for three years following the last recorded activity on an account; technical and usage data is retained for twelve months on a rolling basis.

When personal data is no longer required for any retention purpose, it is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Users may request early deletion of personal data that is not subject to a mandatory retention obligation by contacting 35bp support. Such requests will be reviewed and a response provided within a reasonable timeframe.

9. Your Privacy Rights

As a user of the 35bp platform you have the following rights with respect to your personal data. To exercise any of these rights, contact 35bp support with your account details and a description of your request:

35bp will respond to verified rights requests within a reasonable period. In some cases, exercising a right may not be possible where mandatory legal retention obligations apply, where the data is necessary to fulfil an ongoing contractual obligation, or where the request conflicts with fraud prevention or security requirements. Where a request cannot be fulfilled in full, 35bp will explain the reason in writing.

10. Children's Privacy

35bp is strictly an adult platform. Registration and use of the platform is prohibited for persons under 21 years of age. 35bp does not knowingly collect personal data from persons under 21. If we become aware that personal data has been collected from a person under 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe a person under 21 has registered a 35bp account, please contact [email protected] immediately.

11. Changes to This Privacy Policy

35bp reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable legal requirements. The effective date at the top of this page indicates when the current version was last revised. Material changes — those that significantly affect your rights or how we use your data — will be communicated via a notice on the platform prior to taking effect.

Your continued use of the 35bp platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. We recommend reviewing this page periodically to stay informed about how your personal data is being handled.

12. Contact Us About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 35bp handles your personal data, please contact the 35bp support team. The platform support email is [email protected] (plain text — not a clickable link). The 35bp support team operates on Bangladesh Standard Time (BST, UTC+6) and aims to respond to all privacy-related enquiries promptly and no later than within a reasonable period of receipt.