33ko Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1 Introduction

33ko ("we", "us", "our") operates the online casino and sports betting platform accessible at https://33ko.io. This Privacy Policy describes how 33ko collects, uses, stores, and protects the personal information of individuals ("you", "your", "Player") who visit, register on, or use the 33ko platform in any capacity.

This policy applies to all data collected through the 33ko website, any associated mobile interfaces, customer support channels, and marketing communications. By creating a 33ko account or continuing to use the platform after this policy has been posted, you acknowledge that you have read and understood its contents.

33ko is committed to handling your personal data responsibly and in accordance with widely recognised data protection principles. We collect only what is necessary, retain it only for as long as required, and apply robust technical and organisational safeguards at every stage of data processing.

2 Data We Collect

33ko collects personal data in the following categories, depending on how you interact with the platform:

2.1 Registration Data

When you create a 33ko account, we collect the information you provide during the registration process, which may include:

• Full legal name
• Date of birth (required to verify the 21+ age requirement)
• Residential address (city, district, division within Bangladesh)
• Mobile phone number
• Email address (where provided)
• Username and hashed password

2.2 Identity Verification (KYC) Data

To comply with our Know Your Customer (KYC) obligations and to verify your age and identity before processing withdrawals, we may request and retain copies of:

• National Identity Card (NID)
• Passport (biographical data page)
• Driver's licence
• Proof of address documents (utility bill, bank statement)
• Selfie or live photograph for identity confirmation

2.3 Financial Transaction Data

We record details of all deposits, withdrawals, and bonus transactions conducted through your 33ko account. This includes transaction amounts, timestamps, payment method identifiers (e.g., the mobile number associated with your bKash or Nagad account, or the last four digits of your card), and transaction reference numbers. We do not store full card numbers, CVV codes, or mobile banking PINs.

2.4 Gameplay & Activity Data

We automatically record data about your activity on the platform, including games played, wagers placed, bet outcomes, session durations, and betting history. This data is used for account management, responsible gaming monitoring, fraud prevention, and improving the platform experience.

2.5 Technical & Device Data

When you access the 33ko platform, we automatically collect certain technical information about your device and connection, including:

• IP address
• Device type, operating system, and browser version
• Screen resolution and language settings
• Referring URL and pages visited within the platform
• Session start and end times

2.6 Communication Data

If you contact the 33ko support team — whether via email, live chat, or any other channel — we retain records of that correspondence, including the content of messages, timestamps, and any attachments provided. This enables us to resolve queries efficiently and maintain a service history for each account.

3 How We Use Your Data

33ko uses the personal data described in Section 2 for the following purposes:

• Account creation and management: To set up and maintain your 33ko player account, including processing your registration details and verifying your identity.
• Age verification: To confirm that you are at least 21 years of age before allowing real-money wagering, in line with our commitment to responsible gaming and our Terms & Conditions.
• Transaction processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, and to maintain accurate financial records of all account activity.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, money laundering, identity misrepresentation, multi-accounting, and other prohibited conduct as defined in our Terms & Conditions.
• Responsible gaming: To monitor gameplay patterns and identify players who may be displaying signs of problem gambling, in order to apply appropriate player protection measures such as deposit limits, cooling-off periods, or self-exclusion.
• Customer support: To respond to your queries, complaints, and requests in an accurate and timely manner, using our record of past communications to provide consistent service.
• Platform improvement: To analyse usage patterns, identify technical issues, and inform product development decisions that improve the overall 33ko platform experience.
• Marketing communications: Where you have given your consent, to send you information about promotions, bonus offers, new games, and platform news relevant to the Bangladesh market. You may opt out of marketing communications at any time.
• Legal and regulatory compliance: To fulfil obligations under applicable anti-money laundering (AML) requirements and to respond to lawful requests from relevant authorities.

4 Legal Basis for Processing

33ko processes your personal data on the following legal bases:

• Contractual necessity: Processing your registration data, transaction data, and KYC data is necessary to perform the contract between you and 33ko (your player account agreement and these Terms & Conditions).
• Legitimate interests: Processing technical data, gameplay data, and communication data for fraud prevention, security, and platform improvement serves the legitimate interests of 33ko and its player community, provided those interests are not overridden by your rights.
• Legal obligation: Retaining financial records and KYC documentation enables 33ko to comply with applicable AML and financial record-keeping obligations.
• Consent: Where we send you marketing communications or use non-essential cookies, we rely on your explicit consent, which you may withdraw at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Data Sharing

5.1 Who We Share Data With

33ko does not sell, rent, or trade your personal data. We share your data only with the following categories of recipient, and only to the extent strictly necessary for the relevant purpose:

• Game providers: Certified game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive session tokens and player identifiers — but not full personal profiles — to deliver their games within the 33ko lobby.
• Payment processors: Domestic payment gateways facilitating bKash, Nagad, Rocket, and Upay transactions, as well as international card processors handling Visa and Mastercard payments, receive the transaction data required to execute and confirm transfers.
• KYC verification partners: Where identity verification is conducted with the assistance of a third-party KYC service, your submitted documents and photographs may be processed by that provider solely for the purpose of verification.
• Regulatory and law enforcement authorities: Where 33ko is subject to a lawful request, court order, or regulatory obligation requiring disclosure of player data, we will comply with that request. We will endeavour to notify you of any such disclosure where legally permitted to do so.
• Fraud prevention services: Aggregated or anonymised data may be shared with fraud detection networks to identify patterns associated with money laundering, bonus abuse, or identity fraud.

5.2 International Data Transfers

Some of the third parties described above — particularly game providers and card payment processors — may operate infrastructure located outside Bangladesh. Where your data is processed in a country that may not provide the same level of data protection as Bangladesh, 33ko takes steps to ensure that appropriate contractual safeguards are in place with the relevant third party before any transfer occurs.

6 Payment Data & Financial Security

33ko treats financial data with an elevated level of care given its sensitivity. The following specific measures apply to payment-related personal data:

• Full mobile banking account numbers (bKash, Nagad, Rocket, Upay) are stored in encrypted form and displayed to users in masked format (e.g., 01***7890).
• Credit and debit card numbers processed via Visa or Mastercard are handled exclusively by PCI-DSS Level 1 compliant payment processors. 33ko does not receive or store full card numbers on its own servers.
• CVV/CVC codes and mobile banking PINs are never requested by 33ko and are never stored or transmitted through our platform in any form.
• All financial transaction records are retained for a minimum of five years in line with standard financial record-keeping practice, even if your account is subsequently closed.
• Withdrawal requests above specified thresholds may require additional KYC verification before processing, as part of our AML compliance programme.

All deposits and withdrawals on the 33ko platform are denominated in Bangladeshi Taka (BDT / ৳). No foreign exchange conversion is applied to domestic BDT transactions. Currency conversion on international card payments is handled by the card issuer and is outside 33ko's control.

7 Cookies & Tracking Technologies

7.1 What Cookies We Use

The 33ko platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure experience. The categories of cookies we use are:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in during a visit and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings and display options so that you do not need to re-enter them on each visit.
• Analytics cookies: Collect anonymised data about how pages are used, which features are accessed most frequently, and where technical errors occur. This data is used exclusively for internal platform improvement.
• Marketing cookies: Used only where you have given explicit consent to receive personalised promotional content. These cookies track which promotions you have viewed so that you are not shown the same offer repeatedly.

7.2 Managing Cookies

You may control cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to use the 33ko platform. Disabling functional or analytics cookies will not prevent access to the platform but may reduce the quality of your experience. Withdrawing consent for marketing cookies will stop you from receiving personalised promotional content.

8 Data Retention

33ko retains your personal data for as long as is necessary for the purposes described in this policy or as required by applicable legal and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be linked to an identifiable individual. Anonymised or aggregated data may be retained indefinitely for statistical and analytical purposes.

9 Data Security

33ko implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and 33ko servers is encrypted using current SSL/TLS protocols. The padlock icon in your browser confirms this encryption is active on every 33ko page.
• Password hashing: Account passwords are never stored in plain text. They are processed using a strong one-way cryptographic hash function, meaning 33ko staff cannot retrieve your password even in the event of a data breach.
• Access controls: Access to personal data within the 33ko organisation is restricted to staff members who require that access to perform their specific role. Access logs are maintained and reviewed regularly.
• Infrastructure security: 33ko's server infrastructure is hosted in data centres with physical security controls, redundant power and network systems, and regular security audits.
• Incident response: In the event of a data security incident that may affect your personal data, 33ko will take prompt steps to contain the incident and will notify affected users within a reasonable timeframe where required.

10 Your Rights

As a 33ko account holder, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact [email protected] with the subject line "Data Rights Request" and include your registered username.