38bd Privacy Policy — Your Data, Your Rights

38bd collects personal data through several channels during the course of operating the Platform. The specific information collected depends on how you interact with the Platform and which services you use. We collect data in the following ways:

• Registration data: when you create a 38bd account, you provide your mobile number, chosen username, and certain basic personal details required to set up the account.
• KYC verification data: when you complete identity verification prior to processing a withdrawal, you provide government-issued identification documents and, where required, proof of address and source of funds documentation.
• Transaction data: every deposit and withdrawal processed through your 38bd account generates a transaction record, including the amount, timestamp, payment method used, and transaction status.
• Usage and gameplay data: the Platform automatically records your gameplay activity, including the games you play, session start and end times, bet amounts, win and loss outcomes, and how you navigate the Platform.
• Technical and device data: when you access the Platform from any device, we automatically collect certain technical information including your IP address, device model, operating system version, browser type, and session identifiers. This data is used for security monitoring, fraud detection, and to ensure the Platform functions correctly on your device.

38bd uses the personal data we collect for the following lawful purposes. We do not use your data for any purpose not listed below without first obtaining your explicit consent:

• Account management: to create, maintain, and administer your 38bd account, including processing your registration, verifying your identity through KYC, and managing your account settings and security preferences.
• Payment processing: to process deposits and withdrawals through your chosen payment method (including bKash, Nagad, Rocket, and Upay), to verify payment details, and to maintain an accurate transaction history for your account.
• Regulatory compliance and fraud prevention: to fulfil our obligations under applicable anti-money laundering, Know Your Customer, and responsible gaming regulations, including monitoring account activity for signs of problem gambling, fraudulent transactions, or prohibited conduct.
• Customer support: to respond to your enquiries, resolve disputes, investigate complaints, and provide technical assistance in connection with your use of the Platform.
• Platform improvement: to analyse aggregated, anonymised usage data to understand how players interact with the Platform, identify areas for improvement, and develop new features and game offerings that better serve our Bangladeshi player base.

38bd processes your personal data on the following legal bases:

• Contractual necessity: the majority of data processing is necessary for us to provide the services you have requested by creating an account and using the Platform. Without this processing, we would be unable to operate your account, process payments, or provide customer support.
• Legal obligation: certain processing activities — including KYC verification, transaction monitoring, and record-keeping for regulatory purposes — are required by applicable law, and 38bd is obligated to perform them regardless of consent.
• Legitimate interests: some processing activities — such as fraud prevention, platform security monitoring, and aggregated analytics for product improvement — are carried out on the basis of 38bd's legitimate interests in operating a safe, secure, and well-functioning platform, provided these interests are not overridden by your privacy rights.

38bd does not sell, rent, or trade your personal data to any third party for marketing purposes. We may share your data only in the limited circumstances described below:

• Service providers: we engage trusted third-party service providers to assist in operating the Platform, including payment processors (such as those facilitating bKash and Nagad transactions), game content providers (such as Pragmatic Play and Evolution Gaming), and technical infrastructure partners. These providers are contractually bound to handle your data only as instructed by 38bd and may not use it for their own independent purposes.
• Regulatory and legal authorities: we may be required to disclose your personal data to regulatory bodies, law enforcement agencies, or courts where required by applicable law, including in connection with anti-money laundering obligations, the investigation of fraudulent activity, or the enforcement of these Terms.
• Business transfers: in the event that 38bd undergoes a merger, acquisition, or asset sale, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.
• With your consent: in any other circumstance where we wish to share your data with a third party for a purpose not described above, we will first seek your explicit, informed consent and provide you with a clear description of the intended use.

Where your data is shared with service providers located outside of Bangladesh, 38bd takes appropriate steps to ensure that adequate data protection standards apply to that transfer, consistent with applicable international data protection principles.

38bd uses cookies and similar tracking technologies to operate the Platform, improve user experience, and maintain session security. The following types of cookies are used:

• Essential cookies: these are necessary for the Platform to function and cannot be disabled. They include session cookies that keep you logged in during an active session and security tokens that protect your account from unauthorised access.
• Analytics cookies: these help us understand how players use the Platform by collecting anonymised data on page views, session duration, and navigation paths. This data is used in aggregate and does not identify individual players.
• Functional cookies: these remember your preferences — such as your chosen language setting — so that the Platform behaves consistently across sessions without requiring you to re-enter your preferences each time you visit.

You may adjust your browser settings to refuse or delete cookies. However, disabling essential cookies will affect the functionality of the Platform and may prevent you from logging in or accessing certain features. 38bd does not use third-party advertising cookies or cross-site tracking cookies.

38bd retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy, and in accordance with any applicable legal, regulatory, or contractual obligations. The following general retention principles apply: account data and KYC documentation are retained for a minimum period of five years from the date of account closure to satisfy applicable anti-money laundering record-keeping requirements. Transaction records are retained for a minimum of five years from the date of the transaction. Usage and gameplay data is retained for up to three years for the purposes of analytics, dispute resolution, and responsible gaming monitoring. Technical and device data is retained for up to twelve months from the date of collection.

When your data is no longer required for the purpose for which it was collected and no legal obligation requires its continued retention, 38bd will securely delete or anonymise it in accordance with our internal data disposal procedures.

Subject to applicable law, you have the following rights in relation to your personal data held by 38bd. To exercise any of these rights, please contact our support team via live chat or email:

• Right of access: you have the right to request a copy of the personal data that 38bd holds about you, together with information about how it is being used and with whom it has been shared.
• 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 or completed. Requests to update account information may be subject to re-verification of your identity.
• Right to erasure: in certain circumstances, you may request that 38bd delete your personal data. This right is subject to exceptions where retention is required by law (for example, where KYC records must be retained to satisfy regulatory obligations) or where the data is required to resolve an outstanding dispute.
• Right to restriction: you may request that 38bd restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is being investigated.
• Right to object: where 38bd processes your personal data on the basis of its legitimate interests, you have the right to object to that processing. 38bd will cease processing unless it can demonstrate compelling legitimate grounds that override your interests or where processing is required for the establishment, exercise, or defence of legal claims.

38bd will respond to all verified rights requests within a reasonable timeframe, and no later than 30 days from receipt of the request. We may need to verify your identity before processing a request. There is no charge for exercising your privacy rights unless a request is manifestly unfounded or excessive.

38bd implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include SSL/TLS encryption for all data transmitted between your device and the Platform, secure server infrastructure with access controls restricted to authorised personnel only, regular security assessments and vulnerability testing of Platform systems, and multi-factor authentication requirements for administrative access to data systems.

While 38bd takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. If you have reason to believe that your account has been compromised or that your personal data has been involved in a security incident, please contact our support team immediately at [email protected] so that we can investigate and take appropriate action.

The 38bd Platform may reference or integrate with third-party services such as game providers (Pragmatic Play, Evolution Gaming, Spribe, Ezugi) and payment facilitators (bKash, Nagad). While 38bd carefully selects its third-party partners and requires them to maintain appropriate data protection standards under our data processing agreements, 38bd is not responsible for the privacy practices of those third parties in relation to data you provide directly to them or that they collect independently of the Platform. We encourage you to review the privacy policies of any third-party service you interact with.

38bd reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we provide. When material changes are made to this Policy, we will update the "Last Updated" date at the top of the page and, where practicable, provide notice to registered players via the Platform's notification system. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, please discontinue use of the Platform and contact our support team to request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 38bd handles your personal data, please contact our support team. We are committed to addressing your privacy enquiries promptly and transparently. Our support team is available 24 hours a day, seven days a week via live chat on the Platform.

Email us at: [email protected]