pd33 Privacy Policy — How We Protect Your Personal Data

1. Who We Are

pd33 ("we", "us", "our", "the Platform") is an online sports betting and casino platform operating under the brand name pd33, accessible at pd33.io. For the purposes of data protection, pd33 acts as the data controller in respect of all personal data collected from players and visitors to the platform. This means we are responsible for determining the purposes and means by which your personal data is processed.

Our primary market is Bangladesh, and our platform is designed to serve adult players (aged 21 and above) located across Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar, and all other regions of Bangladesh. This Privacy Policy applies to all personal data collected from players and visitors regardless of their location, but is specifically tailored to the Bangladesh market context.

2. Scope of This Policy

2.1  This Privacy Policy applies to all personal data collected by pd33 through the following channels and interactions:

• Registration and account creation on the pd33 website (pd33.io).
• Account login, session activity, and use of any feature, game, or service on the Platform.
• Deposits, withdrawals, and all financial transactions processed through the Platform.
• Customer support interactions via email or live chat.
• Identity verification (KYC) procedures conducted at any point during the account lifecycle.
• Participation in promotional campaigns, bonuses, or loyalty programmes offered by pd33.
• Passive data collection through cookies and tracking technologies as described in Section 9.

2.2  This Policy does not apply to the data practices of third-party payment providers (such as bKash, Nagad, Rocket, and Upay), third-party game studios (such as Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, or Spribe), or any other external service whose platforms you may interact with in connection with your pd33 account. Those entities operate under their own independent privacy policies, for which pd33 accepts no responsibility.

3. Data We Collect

3.1 Data You Provide Directly

We collect personal data that you voluntarily provide to us during the course of your relationship with pd33. This includes, but is not limited to:

• Identity data: Full legal name, date of birth, gender, and government-issued identification number (national ID card, passport, or birth certificate).
• Contact data: Residential address, email address, and mobile phone number.
• Account credentials: Username and hashed password (passwords are never stored in plain text).
• Financial data: Mobile wallet identifiers (bKash, Nagad, Rocket, Upay), bank account reference numbers, and transaction details. Full payment card numbers are not collected or stored.
• KYC documentation: Copies of identity documents, utility bills, or other proof-of-address documents submitted during the verification process.
• Support communications: The content of any messages you send to our customer support team, including email correspondence and live chat transcripts.

3.2 Data We Collect Automatically

When you access and use the pd33 platform, we automatically collect certain technical and behavioural data, including:

• Device and browser data: Device type, operating system, browser type and version, screen resolution, and language settings.
• Network data: IP address and approximate geolocation derived from IP address (city or district level — we do not collect precise GPS coordinates).
• Session data: Login timestamps, session duration, pages visited, navigation path, and feature interactions within the Platform.
• Gaming data: Full wagering and gaming history, including bet amounts, game types, outcomes, bonus usage, and session timing. This data is retained for regulatory compliance, responsible gaming monitoring, and dispute resolution.

3.3 Data from Third Parties

In certain circumstances, pd33 may receive personal data about you from third-party sources, including:

• Identity verification service providers engaged to confirm the authenticity of KYC documentation.
• Fraud prevention and AML screening services that check your details against sanctions lists, politically exposed persons (PEP) databases, and adverse media sources.
• Payment processors, who may share transaction status and verification flags with us in connection with deposit and withdrawal processing.

4. How We Use Your Data

pd33 uses the personal data we collect for the following specific purposes:

Purpose	Data Categories Used
Account registration and management	Identity data, contact data, account credentials
Identity verification (KYC)	Identity data, KYC documentation, financial data
Processing deposits and withdrawals	Financial data, identity data
Delivering and personalising gaming services	Gaming data, session data, contact data
Fraud prevention and AML compliance	All data categories
Responsible gaming monitoring	Gaming data, session data, financial data
Customer support	Identity data, contact data, support communications
Promotional communications (where consented)	Contact data, gaming data
Platform security and technical maintenance	Device data, network data, session data
Legal and regulatory compliance	All data categories

pd33 does not use personal data for any automated decision-making or profiling that produces legal or similarly significant effects on players, except where such processing is strictly necessary for fraud detection or AML screening, in which case you have the right to request human review of any adverse decision.

5. Legal Bases for Processing

5.1  Contractual necessity: The majority of the data processing described in this Policy is necessary for the performance of the contract between you and pd33 (i.e., the Terms & Conditions you accepted at registration). This includes account management, KYC verification, payment processing, and the delivery of gaming services.

5.2  Legal obligation: Certain processing activities — in particular, AML screening, identity verification, and the retention of financial transaction records — are required by applicable law and regulations. pd33 must perform this processing regardless of your consent.

5.3  Legitimate interests: pd33 processes some data on the basis of our legitimate business interests, where those interests are not overridden by your rights and freedoms. This includes fraud prevention, platform security monitoring, and the improvement of our services. We have conducted a balancing assessment for each such activity and are satisfied that our interests are proportionate and do not unduly prejudice players.

5.4  Consent: Where we seek to send you marketing communications or use non-essential cookies and tracking technologies, we will do so only on the basis of your explicit consent, which you may withdraw at any time by contacting [email protected] or adjusting your account communication preferences.

6. Data Sharing and Disclosure

6.1 Service Providers

pd33 engages a limited number of trusted third-party service providers who process personal data on our behalf and under our instruction, strictly for the purposes described in this Policy. These include identity verification providers, payment processors (bKash, Nagad, Rocket, Upay, and Bangladeshi banking partners), fraud and AML screening services, cloud hosting and infrastructure providers, and customer support technology providers. All service providers are bound by contractual data processing agreements that require them to apply security standards no less stringent than those pd33 itself applies.

6.2 Game Studios

pd33 hosts games supplied by third-party studios including Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, Microgaming, and Spribe. When you play a game provided by one of these studios, certain session and gameplay data may be processed by the relevant studio's game server infrastructure. pd33 ensures that such data sharing is limited to what is technically necessary and that studio partners operate under appropriate data protection obligations.

6.3 Legal and Regulatory Disclosure

pd33 may be required by law, court order, or regulatory authority to disclose certain personal data without prior notice to you. We will comply with all such legally valid demands and, where permitted by law, we will notify you of any such disclosure after the fact.

6.4 Business Transfers

In the event that pd33 undergoes a merger, acquisition, or sale of all or substantially all of its assets, player personal data may form part of the transferred assets. In such an event, you will be notified via email and/or a prominent notice on the Platform, and your data will continue to be governed by this Privacy Policy or a successor policy of equivalent or greater protection.

6.5 No Sale of Data

pd33 does not and will not sell, rent, lease, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. This commitment is unconditional and applies regardless of the commercial circumstances of the Platform.

7. Data Retention

7.1  pd33 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, after which it is securely deleted or irreversibly anonymised. The following indicative retention periods apply:

• Account and identity data: Retained for the duration of your active account, plus a minimum of 5 years following account closure, to meet AML and regulatory record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, in accordance with applicable financial regulations.
• KYC documentation: Retained for the duration of your account plus 5 years post-closure, or longer if required by a specific regulatory obligation or legal hold.
• Gaming and session data: Retained for 3 years from the date of the session or wager, for the purposes of dispute resolution and responsible gaming auditing.
• Support communications: Retained for 2 years from the date of the final communication in a given support thread, unless the communication is relevant to an ongoing legal matter, in which case it is retained until that matter is resolved.
• Marketing consent records: Retained for the duration of your account plus 3 years following account closure, as evidence of consent for regulatory compliance purposes.

7.2  Where pd33 is subject to a legal hold — for example, where data is relevant to litigation, a regulatory investigation, or a law enforcement request — the relevant data will be retained for the duration of that hold, irrespective of the standard retention periods above.

8. Data Security

8.1  pd33 applies a layered security approach to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

• SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption-at-rest for all sensitive personal data stored in our databases.
• Hashed storage of account passwords using industry-standard cryptographic algorithms — we never store passwords in plain text.
• Role-based access controls ensuring that only authorised pd33 personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing of our platform infrastructure.
• Incident response procedures to detect, contain, and report data breaches in a timely manner.

8.2  In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pd33 will notify affected players without undue delay, providing details of the nature of the breach, the data affected, the likely consequences, and the measures we have taken or propose to take to address the breach.

9. Cookies and Tracking Technologies

9.1  pd33 uses cookies and similar tracking technologies on its platform to support essential functionality, improve user experience, and analyse platform performance. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. These cookies cannot be disabled without impairing core Platform functionality.
• Functional cookies: Remember your preferences such as language settings, display options, and previously selected payment methods to provide a more personalised experience.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and use the Platform, enabling us to identify and resolve usability issues and improve our services. These cookies are only placed with your consent.
• Marketing cookies: Used to track the effectiveness of any promotional campaigns pd33 runs. These cookies are only placed with your explicit consent and are not used to serve advertising on third-party websites.

9.2  You may withdraw consent for non-essential cookies at any time by contacting [email protected]. Withdrawal of consent will not affect the lawfulness of any processing that occurred prior to withdrawal, and will not impair your access to the core features of the pd33 Platform.

10. Your Data Rights

10.1  As a pd33 player, you hold the following rights in respect of your personal data. To exercise any of these rights, please contact us at [email protected] with your registered username and a clear description of your request. We will respond within 30 days of receipt:

• Right of access: You have the right to request a copy of all personal data we hold about you, along with information about how it is processed.
• Right to rectification: You have the right to request the correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to restriction: You have the right to request that we restrict the processing of your personal data in certain circumstances, for example while the accuracy of the data is disputed.
• Right to data portability: You have the right to receive the personal data you have provided to us in a structured, commonly used, machine-readable format, and to transmit that data to another controller.
• Right to object: You have the right to object to the processing of your personal data where that processing is based on legitimate interests, including profiling. You also have an unconditional right to object to the use of your data for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

10.2  pd33 will not charge a fee for responding to data rights requests unless the requests are manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable administrative fee or decline to respond, providing written reasons for that decision.

11. Children's Privacy

11.1  The pd33 platform is strictly an adult service. We do not knowingly collect, process, or retain personal data from individuals under the age of 21. Our registration process includes age verification steps designed to prevent underage access.

11.2  If pd33 becomes aware that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete all personal data collected from that individual, and return any deposited funds to the payment method from which they originated. Any winnings accrued on an underage account will be forfeited.

11.3  If you are a parent or guardian and you believe that your child has registered on the pd33 platform, please contact us immediately at [email protected] so that we may investigate and take appropriate action without delay.

12. Third-Party Links

12.1  The pd33 platform does not contain links to external third-party websites for commercial or advertising purposes. However, in the course of using the Platform, you may interact with third-party services — such as bKash or Nagad — to process payments. When you are redirected to a third-party service, you leave the pd33 platform and the privacy practices of that third party apply.

12.2  pd33 is not responsible for the privacy practices, data security, or content of any third-party service you access in connection with using our Platform. We encourage you to review the privacy policies of any third-party service before providing them with your personal data.

13. Amendments to This Policy

13.1  pd33 reserves the right to amend this Privacy Policy at any time. Where an amendment materially affects how we process your personal data or reduces the protections afforded to you under this Policy, we will provide at least 14 days' advance notice via email to your registered email address and via a prominent notice on the Platform.

13.2  The effective date of the most recent version of this Policy will always be displayed at the top of this page. Your continued use of the pd33 Platform following the effective date of any amendment constitutes your acknowledgement of the revised Policy. If you do not accept the revised Policy, you must discontinue use of the Platform and may request account closure in accordance with our Terms & Conditions.

14. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 10, please contact our Data Support team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please use "Privacy Policy Enquiry" or "Data Rights Request" as the subject of your email.
• Availability: 24 hours a day, 7 days a week, Bangladesh Standard Time (UTC+6)
• Response Time: We aim to acknowledge all privacy-related enquiries within 48 hours and to provide a substantive response within 30 calendar days.

Please include your registered pd33 username or account reference number in all correspondence to allow us to locate your account and respond efficiently.