33pmw Privacy Policy — How We Collect, Use & Protect Your Data
At 33pmw, your privacy is a fundamental commitment, not an afterthought. This Privacy Policy explains in plain language exactly what personal information we collect when you use the platform, why we need it, how it is stored, who can access it, and what rights you hold over your own data.
Six Core Privacy Principles
The following cards summarise the key privacy principles that underpin how 33pmw handles your personal information. The full legal policy text appears in the sections below.
Minimal Data Collection
33pmw collects only the personal data that is strictly necessary to operate your account, verify your identity, process transactions, and comply with applicable legal obligations. We do not collect data beyond what is required for these defined purposes.
Secure Storage & Encryption
All data stored by 33pmw is protected with industry-standard SSL/TLS encryption in transit and AES-256 encryption at rest. Access to personal data is restricted to authorised personnel only, under strict role-based access controls and regular internal security audits.
Your Rights Are Respected
Members have the right to access a copy of their personal data, request corrections to inaccurate information, ask for data deletion where legally permissible, and object to certain types of data processing. All requests are handled within 30 days of receipt.
No Unauthorised Sharing
33pmw does not sell, rent, or trade your personal data to third parties for marketing purposes. Data is shared with carefully vetted service providers only where necessary to deliver platform services, and those providers are contractually bound to the same privacy standards we uphold.
Defined Retention Periods
Personal data is retained only for as long as it is needed to fulfil the purpose for which it was collected, or as required by applicable law. When data is no longer required, it is securely deleted or anonymised in accordance with our internal data retention schedule.
Transparent Cookie Use
33pmw uses cookies and similar tracking technologies solely to maintain session state, improve platform performance, and understand aggregate usage patterns. We do not use third-party advertising cookies. Cookie usage is explained fully in Section 8 of this policy.
1. Who We Are
33pmw is an online betting and gaming platform operating the website https://33pmw.io. The platform provides sports betting (with a particular focus on cricket, including BPL and international T20 matches), live casino games, and online slots to registered members in Bangladesh and other permitted jurisdictions. For the purposes of this Privacy Policy, "33pmw", "we", "us", and "our" refer to the platform operator responsible for the collection and processing of your personal data.
Our primary point of contact for all data-related enquiries is our support team, reachable at [email protected]. All data-related requests, including access requests, deletion requests, and complaints, must be submitted in writing to that address.
2. Data We Collect
33pmw collects personal data in several categories depending on the nature of your interaction with the platform. The table below summarises the categories of data we collect and the typical examples within each category:
| Category | Examples | When Collected |
|---|---|---|
| Identity Data | Full legal name, date of birth, gender, nationality, government-issued ID number | Registration and KYC verification |
| Contact Data | Email address, mobile phone number, residential address | Registration and account updates |
| Financial Data | bKash/Nagad/Rocket account identifiers, bank account details (where applicable), transaction history, deposit and withdrawal records | First deposit and each transaction |
| Account Data | Username, hashed password, account balance history, bonus claim history, VIP tier status, betting history | Ongoing platform use |
| Technical Data | IP address, browser type and version, device type, operating system, time zone (BST/UTC+6 noted where relevant), session duration, pages visited | Each platform visit |
| Communications Data | Support ticket content, email correspondence, live chat transcripts | When you contact support |
| KYC Documents | Scanned copies of national ID (NID), passport, utility bills, or other identity and address verification documents | KYC verification process |
3. How We Collect Data
We collect personal data through the following channels:
- Direct submission: Information you provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion.
- Automated technical collection: Data collected automatically when you visit the platform, including IP address, device identifiers, browser fingerprints, and session activity logs. This collection is performed through server logs and first-party cookies.
- Payment providers: When you initiate a transaction through bKash, Nagad, Rocket, Upay, or a banking partner, those providers may share transaction confirmation data with 33pmw to reconcile your deposit or withdrawal.
- Identity verification services: Where 33pmw uses a third-party identity verification provider to assist with KYC, that provider may share verification results and associated data points with us.
- Fraud prevention partners: 33pmw may receive data flags or risk signals from fraud prevention services that help us identify suspicious activity on your account or on the platform generally.
4. Why We Use Your Data
33pmw uses personal data collected from members for the following defined purposes. We do not use your data for any purpose outside this list without first obtaining your explicit consent:
- Account creation and management: To register your account, maintain your account profile, and provide you with access to the platform's services.
- Identity and age verification: To confirm that you meet the 21+ age requirement and that your identity matches the information you have provided, in compliance with our KYC obligations.
- Transaction processing: To process deposits, withdrawals, and bonus credits accurately and to maintain a complete transaction history for your account.
- Responsible gaming monitoring: To monitor betting patterns that may indicate problem gambling behaviour and to proactively apply responsible gaming tools where warranted.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, and other prohibited conduct as described in our Terms & Conditions.
- Customer support: To respond to your enquiries, process complaints, and resolve disputes in a timely and effective manner.
- Platform improvement: To analyse aggregate, anonymised usage data to improve platform performance, user experience, and the range of games and markets offered.
- Promotional communications: Where you have opted in, to send you information about promotions, bonuses, seasonal offers (such as BPL season promotions or Eid special offers), and VIP tier updates relevant to your account. You may opt out at any time by contacting support.
- Legal compliance: To comply with any applicable legal obligation, court order, regulatory request, or law enforcement direction.
5. Legal Basis for Processing
33pmw processes your personal data on one or more of the following legal bases, depending on the specific purpose of processing:
- Contractual necessity: Processing required to perform the contract between you and 33pmw — including account registration, transaction processing, and support — is carried out because it is necessary to deliver the service you have signed up for.
- Legal obligation: Certain processing activities, including identity verification and transaction monitoring, are required by applicable anti-money laundering obligations and other regulatory requirements.
- Legitimate interests: Processing carried out for fraud prevention, platform security, and aggregate analytics is conducted on the basis of 33pmw's legitimate interest in maintaining a safe and well-functioning platform, provided that interest is not overridden by your rights and interests.
- Consent: Processing for direct marketing and promotional communications is carried out only where you have provided explicit, freely given consent. You may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
6. Data Sharing & Third Parties
33pmw does not sell, rent, or trade personal data to third parties. We share data only in the following limited and controlled circumstances:
- Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Visa, and Mastercard receive the minimum data necessary to process your transactions. These providers operate under their own privacy policies and are responsible for their own data handling practices.
- Identity verification providers: Third-party KYC providers receive identity document data solely for the purpose of verifying your identity. They are contractually prohibited from using this data for any other purpose.
- Game content providers: Game studios and platform providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — may receive a pseudonymous session identifier for the purpose of delivering game content and maintaining fair play records. No directly identifiable personal data (such as your full name or payment details) is shared with game providers.
- Fraud prevention and security services: Aggregated risk signals and, where necessary, specific account data may be shared with fraud prevention partners to protect the integrity of the platform and our members.
- Legal and regulatory authorities: 33pmw will disclose personal data to law enforcement agencies, regulatory bodies, or courts where we are legally required to do so or where disclosure is necessary to protect the legal rights of 33pmw or our members.
7. International Data Transfers
The personal data of 33pmw members is primarily processed and stored on servers located in secure data centre facilities. Where data is transferred to or processed by service providers outside of Bangladesh — for example, game content providers or cloud infrastructure partners — 33pmw takes reasonable steps to ensure that an equivalent level of data protection is maintained.
Such steps may include contractual clauses binding the recipient to appropriate data protection standards, or limiting the scope of any transfer to pseudonymous or aggregated data that does not directly identify you as an individual.
8. Cookies & Tracking Technologies
33pmw uses cookies and similar technologies (such as local storage and session storage) on the platform. The following categories of cookies are in use:
| Cookie Type | Purpose | Duration |
|---|---|---|
| Strictly Necessary | Maintain your logged-in session, remember your account state between page loads, enable the shopping cart and deposit flow to function correctly | Session (deleted on browser close) |
| Functional | Remember your language or display preferences and personalise your experience on subsequent visits | Up to 12 months |
| Analytics | Collect aggregate, anonymised data about how members navigate the platform to help us improve page structure, game discovery, and load times | Up to 24 months |
33pmw does not use third-party advertising or retargeting cookies. You can control cookies through your browser settings. Please note that disabling strictly necessary cookies will prevent you from logging in or using the platform's core features. Disabling functional or analytics cookies will not affect your ability to bet or play games.
9. Data Retention
33pmw retains personal data for as long as is necessary to fulfil the purpose for which it was collected, subject to applicable minimum retention periods required by law. The general retention periods applied are as follows:
- Active account data: Retained for the full duration of your account's active status plus a period of 5 years following account closure, to meet anti-money laundering record-keeping requirements.
- Transaction records: Retained for a minimum of 5 years from the date of each transaction to satisfy financial record-keeping obligations.
- KYC documents: Retained for 5 years following the completion of verification, or 5 years following account closure, whichever is later.
- Support communications: Retained for up to 3 years from the date of the last communication in a support thread, unless the communication forms part of an unresolved formal complaint, in which case it is retained until the complaint is fully resolved plus 2 years.
- Technical and analytics data: Anonymised after 24 months; raw technical log data retained for up to 12 months for security and fraud investigation purposes.
- Marketing consent records: Retained for the duration of your account plus 3 years to demonstrate the legal basis for any marketing communications sent.
When data reaches the end of its applicable retention period, it is securely deleted from our systems or, where deletion is not technically practicable, irreversibly anonymised so that it can no longer be linked to you as an individual.
10. Data Security
33pmw implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Key measures include:
- SSL/TLS encryption for all data transmitted between your device and the 33pmw platform.
- AES-256 encryption for personal data stored in our databases, including payment identifiers and identity documents.
- Role-based access control, ensuring that only staff with a specific operational need can access personal data, and that all such access is logged.
- Regular internal and third-party security assessments to identify and remediate vulnerabilities in the platform infrastructure.
- Multi-factor authentication requirements for all internal staff accessing production systems containing member data.
- Incident response procedures that require us to notify affected members promptly in the event of a data breach that poses a material risk to your rights or interests.
11. Your Privacy Rights
As a member of the 33pmw platform, you hold the following rights in relation to your personal data. All rights requests should be submitted in writing to [email protected] with the subject line "Data Rights Request — [Your Username]". We will acknowledge receipt within 3 business days and respond in full within 30 days.
- Right of Access: You may request a copy of all personal data that 33pmw holds about you, together with information about how it is being used.
- Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or complete it.
- Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other legal basis applies), or where the data has been unlawfully processed. Note that we may be required by law to retain certain data (e.g., transaction records) even after a deletion request.
- Right to Restrict Processing: You may request that we temporarily limit our use of your data while a rectification or erasure request is being assessed.
- Right to Data Portability: Where processing is based on your consent or a contract, you may request a copy of your personal data in a structured, commonly used, machine-readable format.
- Right to Object: You may object to processing carried out on the basis of legitimate interests, including profiling for responsible gaming monitoring purposes. We 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 (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
12. Children & Minors
The 33pmw platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If we discover or are notified that personal data belonging to a person under 21 has been collected, we will immediately suspend the relevant account, void all bets placed, and securely delete the personal data concerned.
If you believe that a minor has registered an account on the platform, please notify us immediately at [email protected]. We take underage gambling and child data protection extremely seriously and will act on any such notification without delay.
13. Third-Party Links
The 33pmw platform does not contain links to third-party websites. However, if you navigate to any external website independently — for example, the website of a payment provider such as bKash or Nagad — please be aware that those websites operate under their own privacy policies. 33pmw has no control over, and accepts no responsibility for, the privacy practices of any third-party website or service that you access independently of the 33pmw platform.
14. Changes to This Policy
33pmw reserves the right to update this Privacy Policy at any time. When we make changes, we will update the "Last Updated" date at the top of this page. Where changes are material — for example, changes to the categories of data we collect or to the purposes for which we use your data — we will endeavour to notify registered members via the platform notice board or via the email address registered to their account, providing reasonable advance notice before the change takes effect.
Continued use of the 33pmw platform following the publication of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any change to this policy, you should cease using the platform and may request account closure by contacting [email protected].
15. Contact Us
For all privacy-related enquiries, data rights requests, or concerns about how 33pmw handles your personal data, please contact us using the details below. All communications must be in English and submitted in writing.
- Email: [email protected] (plain text — not a clickable link)
- Subject line for data rights requests: "Data Rights Request — [Your Username]"
- Subject line for privacy complaints: "Privacy Complaint — [Your Username]"
- Support hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6)
- Acknowledgement target: within 3 business days of receipt
- Full response target: within 30 days of receipt