35kbd Privacy
Policy

This Privacy Policy ("Policy") describes how 35kbd ("we", "us", "our", "the Platform") collects, processes, stores, and protects personal data relating to individuals ("you", "the User", "the Player") who access or use the 35kbd website, mobile interface, betting services, live casino, slot games, and all associated features. This Policy applies to all Users regardless of the device or connection method used to access 35kbd.

By registering a 35kbd account or by continuing to use the Platform after this Policy has been published, you acknowledge that you have read and understood its contents. If you do not agree with any aspect of this Policy, you should cease using the Platform and contact us to arrange account closure.

01 Introduction

35kbd is an offshore online betting and casino platform serving the Bangladesh market. We take the protection of your personal data seriously. This Policy has been written to give you a clear, honest account of our data practices — written in plain English rather than impenetrable legal jargon, while still being precise enough to constitute a formal privacy notice.

This Policy should be read alongside the 35kbd Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform. Together, these three documents govern the full relationship between you and 35kbd.

02 Data Controller

For the purposes of this Privacy Policy, 35kbd acts as the data controller in respect of the personal data you provide when registering for and using the Platform. As data controller, 35kbd determines the purposes and means by which your personal data is processed.

All data protection enquiries, subject access requests, and formal complaints should be directed to our designated data protection contact at: [email protected]. Please use the subject line "Data Protection — [Your Account Username]" so that your message is routed to the appropriate team without delay.

03 Data We Collect

The categories of personal data that 35kbd may collect and process are set out in the table below. The specific data points collected in any given instance depend on how you interact with the Platform and which features or services you use.

Data Category	Specific Data Points	When Collected
Identity Data	Full legal name, date of birth, gender, nationality, National ID / passport number	Registration and KYC verification
Contact Data	Email address, mobile phone number, residential address (city / district)	Registration
Financial Data	bKash / Nagad / Rocket mobile number, bank account details (where applicable), transaction history, deposit and withdrawal amounts	First deposit and ongoing transactions
Account Data	Username, encrypted password hash, account preferences, responsible gaming settings, session history	Registration and ongoing use
Betting & Gaming Data	Bet history, stake amounts, games played, win/loss records, bonus activations, wagering activity	Ongoing use of sportsbook and casino
Technical Data	IP address, device type, operating system, browser type and version, session timestamps, referral URL	Every Platform session
KYC Documents	Scanned or photographed copies of National ID card, passport, driving licence, utility bills (where requested)	Prior to first withdrawal
Communications Data	Live chat transcripts, email correspondence, support ticket content	When you contact support

35kbd does not knowingly collect sensitive categories of personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where specifically required by applicable compliance obligations and with your explicit consent.

04 How We Collect Data

35kbd collects personal data through the following channels:

• Directly from you: When you complete the registration form, submit KYC documents, make a deposit or withdrawal request, contact support, or update your account profile settings after 35kbd login.
• Automatically during Platform use: Via server logs, session tracking, and analytics tools that record Technical Data each time you access the Platform. This data is collected regardless of whether you are logged in.
• From payment service providers: When you initiate a deposit via bKash, Nagad, Rocket, Upay, or a supported bank, the payment provider confirms transaction status information to 35kbd. We do not receive your full mobile banking credentials — only transaction confirmation and reference data.
• From identity verification services: During KYC processing, 35kbd may use third-party document verification tools to authenticate the identity documents you submit. These tools process document images and return a verification result to 35kbd.
• From cookies and similar technologies: As described in the Cookies & Tracking section of this Policy.

05 Legal Basis for Processing

35kbd relies on the following legal bases to process your personal data, depending on the specific processing activity in question:

• Contractual necessity: Processing that is required to fulfil our obligations under the Terms & Conditions you accepted at registration — for example, processing deposits, settling bets, and managing your account balance.
• Compliance with legal obligations: Processing required to satisfy anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and fraud prevention duties — including identity document retention and transaction monitoring.
• Legitimate interests: Processing undertaken to protect the integrity of the Platform, detect and prevent cheating or bonus abuse, improve Platform performance, conduct internal analytics, and ensure responsible gaming obligations are met — where these interests are not overridden by your privacy rights.
• Consent: Where we rely on consent as a legal basis — primarily for optional marketing communications — you retain the right to withdraw that consent at any time without detriment to your account standing.

06 How We Use Your Data

The personal data 35kbd collects is used for the following purposes:

• Creating and managing your 35kbd account, verifying your identity, and maintaining accurate account records.
• Processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard.
• Settling sports bets, resolving casino game outcomes, and crediting wins and bonuses to your account balance.
• Conducting KYC identity verification prior to releasing withdrawal funds.
• Monitoring transactions for suspicious activity in accordance with our AML compliance obligations.
• Providing customer support via live chat and email, and maintaining records of your support interactions.
• Enforcing the Terms & Conditions, investigating suspected breaches, and protecting against fraud, collusion, and account abuse.
• Operating responsible gaming tools including deposit limits, loss limits, cooling-off periods, and self-exclusion — and monitoring your account activity to identify indicators of problem gambling.
• Sending transactional notifications relating to your account, deposits, withdrawals, and bets — these are service communications and are not subject to marketing consent rules.
• Sending promotional communications about 35kbd offers, BPL and IPL betting specials, seasonal promotions (such as Eid and Pohela Boishakh), and casino game launches — where you have provided consent for marketing communications.
• Improving Platform performance, fixing bugs, and developing new features, using aggregated and anonymised analytics data.

07 Data Sharing

35kbd does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Your data is shared externally only in the following circumstances, and only to the minimum extent necessary:

• Payment processors: bKash, Nagad, Rocket, Upay, and supported banks receive the transaction data required to process your deposits and withdrawals. Each payment provider is subject to their own privacy policy and applicable financial data protection regulations.
• Identity verification providers: Third-party KYC and document authentication services receive copies of identity documents you submit. These providers are contractually prohibited from using your data for any purpose other than verifying your identity on 35kbd's behalf.
• Game content providers: Game studios such as Pragmatic Play, Evolution Gaming, Ezugi, NetEnt, and Microgaming receive the session data necessary to run their games on the Platform. Game providers do not receive your full identity or financial data.
• Analytics and platform infrastructure providers: Hosting, content delivery, and analytics service providers who process Technical Data to support Platform operation. All such providers are bound by data processing agreements that restrict their use of your data to services performed on 35kbd's behalf.
• Legal and regulatory disclosure: Where required by applicable law, court order, or a binding request from a competent authority, 35kbd may disclose personal data to law enforcement or regulatory bodies. We will notify you of such disclosure where we are legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 35kbd's business assets, personal data held by 35kbd may be transferred to the acquiring entity. Affected Users will be notified prior to any such transfer taking effect.

08 Cookies & Tracking

The 35kbd Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, to remember your session state after 35kbd login, to prevent fraud, and to understand how Users navigate the site so we can improve the experience.

The types of cookies used on the 35kbd Platform are as follows:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing identifiers. These cookies cannot be disabled without breaking core Platform functionality.
• Functional cookies: Remember your preferences such as language setting, responsible gaming limits display, and odds format. Disabling these cookies may result in a reduced user experience.
• Analytics cookies: Collect anonymised data about how Users interact with the Platform — which pages are visited most, how long sessions last, and which features are used. This data is aggregated and cannot be used to identify individual Users.
• Security and fraud prevention cookies: Assist in detecting unusual session behaviour, identifying automated access attempts, and flagging accounts that may be operating in violation of the Terms & Conditions.

You may manage cookie preferences through your browser settings. However, disabling strictly necessary cookies will prevent you from logging into your 35kbd account and using the Platform's core services.

09 Data Retention

35kbd retains personal data for the following periods, after which data is securely deleted or irreversibly anonymised:

• Active account data: Retained for the lifetime of your 35kbd account plus a post-closure period of 5 years, to meet AML record-keeping obligations and to allow resolution of any disputes that may arise after account closure.
• KYC identity documents: Retained for 5 years following account closure or the date of last transaction, whichever is later, in line with standard financial compliance record-keeping practice.
• Transaction records: Retained for 5 years from the date of each transaction, consistent with financial record-keeping requirements.
• Support communications: Live chat transcripts and email correspondence are retained for 2 years from the date of the interaction, to support quality assurance and dispute resolution.
• Technical and analytics data: Aggregated analytics data is retained indefinitely in anonymised form. Raw Technical Data (including IP logs) is retained for 12 months from the date of collection.
• Marketing consent records: Records of your marketing preferences and consent history are retained for the duration of your account plus 3 years, to demonstrate compliance with consent obligations.

10 Data Security

35kbd implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• TLS/SSL encryption on all data transmitted between your device and the 35kbd servers.
• Encryption at rest for sensitive data categories including financial details and KYC document stores.
• Access controls that restrict internal access to personal data on a role-based, need-to-know basis. Personnel without a legitimate operational need do not have access to Player personal data.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures that require notification of affected Users and, where applicable, relevant authorities, in the event of a confirmed data breach affecting personal data.
• Secure deletion protocols that ensure data removed from active systems cannot be reconstructed or recovered.

While 35kbd takes all reasonable steps to protect your data, no online platform can guarantee absolute security against all possible threats. You also play a role in keeping your account secure: use a strong, unique password for your 35kbd account and do not share your credentials with anyone. See the Account Security section of the Terms & Conditions for full guidance.

11 International Transfers

35kbd is operated as an offshore platform. This means that the servers on which your personal data is stored and processed may be located outside of Bangladesh. When your data is transferred internationally, 35kbd takes steps to ensure that an adequate level of protection is maintained, including through the use of standard contractual clauses and data processing agreements with all third-party service providers who receive your data.

By using the 35kbd Platform, you acknowledge and consent to the transfer of your personal data to servers and service providers located in jurisdictions outside Bangladesh, subject to the protections described in this Policy.

12 Your Rights

Subject to applicable law and the limitations described in this Policy, you hold the following rights in relation to the personal data that 35kbd processes about you:

• Right of access: You may request a copy of the personal data 35kbd holds about you, along with information about how it is being processed. We will respond to verified access requests within 30 days.
• 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. You can update basic account details directly from your profile settings after 35kbd login; for more complex corrections, contact support.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent (in cases where processing was based on consent). Erasure requests may be declined where retention is required by law.
• Right to restriction of processing: You may request that 35kbd restrict processing of your data in certain circumstances — for example, while the accuracy of the data is contested, or while an objection to processing is being considered.
• Right to data portability: Where processing is based on consent or contract and is carried out by automated means, you may request a copy of your data in a structured, machine-readable format.
• Right to object: You may object to processing based on legitimate interests, including profiling. 35kbd will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (for example, marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of the above rights, contact us at [email protected] with the subject line "Data Rights Request — [Your Account Username]". We will acknowledge your request within 3 business days and provide a substantive response within 30 days. In complex cases, we may extend this period by a further 30 days, with notification to you.

13 Children & Minors

The 35kbd Platform is strictly for individuals aged 21 years or older. 35kbd does not knowingly collect personal data from anyone under the age of 21. If we become aware that a registered account belongs to a person under 21, the account will be immediately suspended, all personal data associated with the account will be deleted in accordance with our data protection procedures, and any funds in the account will be handled in accordance with our Terms & Conditions and applicable compliance requirements.

If you believe a minor has created a 35kbd account using false information, please notify us immediately at [email protected]. We take underage gambling with the utmost seriousness and will act promptly on all credible reports.

14 Marketing Communications

With your consent, 35kbd may send you promotional communications about new games, sportsbook offers (including BPL and IPL betting specials), seasonal campaigns (such as Eid and Pohela Boishakh promotions), and platform updates. These communications may be delivered via email or SMS to the contact details registered on your account.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email you receive from 35kbd.
• Updating your communication preferences in your account settings dashboard after 35kbd login.
• Contacting support at [email protected] with a request to be removed from all marketing lists.

Opting out of marketing communications will not affect the delivery of transactional service messages (such as deposit confirmations, withdrawal status updates, and account security alerts), which are sent regardless of marketing preferences as they are necessary for the operation of your account.

15 Third-Party Links

The 35kbd Platform does not contain links to external third-party websites as a general policy. However, in the event that any third-party content or links are accessible from the Platform, please be aware that those third-party sites operate under their own privacy policies, for which 35kbd bears no responsibility. We encourage you to review the privacy policy of any external site you visit before providing any personal data to that site.

16 Policy Amendments

35kbd reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to our Platform. The most current version of this Policy will always be accessible at the /privacy-policy page of the 35kbd Platform. The "Last Updated" date at the top of this document will be revised whenever a material change is made.

For material changes — those that significantly affect how we process your personal data or the rights available to you — 35kbd will notify registered Players via the on-site notification system or by email to the address on file for your account. Your continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the revised terms.

17 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or about how 35kbd handles your personal data, please contact our data protection team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject line for data enquiries: "Data Protection — [Your Account Username]"
• Response time: Acknowledgement within 3 business days; substantive response within 30 days
• Support hours: 24 hours a day, 7 days a week via on-site live chat after 35kbd login; email monitored during Bangladesh Standard Time (BST, UTC+6) business hours with overnight coverage

If you are not satisfied with our response to a data protection complaint, you have the right to escalate your complaint to the relevant data protection authority in the jurisdiction applicable to your circumstances. 35kbd will co-operate fully with any such authority in the resolution of a complaint.