Privacy Policy of 33wm

Introduction

Our Commitment to Your Privacy

33wm ("we", "us", "the Platform") operates the online gaming and sports betting platform at https://33wm.ws. We are committed to handling your personal data with care, transparency and respect. This Privacy Policy describes the types of personal information we collect from players located in Bangladesh, the purposes for which that information is processed, the parties with whom it may be shared, and the rights you have in relation to your personal data.

By registering an account and using the 33wm platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any provision of this Policy, you should not create an account or use the platform.

This Policy is to be read together with the 33wm Terms and Conditions, which govern your use of the platform. In the event of any conflict between this Policy and the Terms, the Terms prevail with respect to matters of platform use, and this Policy prevails with respect to matters of personal data processing.

Data Collection

What Personal Information We Collect

We collect personal information in several ways: directly from you when you register or use the platform, automatically as you interact with the platform, and from third-party payment processors. The categories of personal data we process are set out below.

Data Use

How 33wm Uses Your Personal Information

33wm processes personal data only for the purposes described below. We do not use personal data for purposes incompatible with the purpose for which it was originally collected, and we do not sell personal data to any third party under any circumstances.

• Account creation and management: verifying your identity and age, setting up your player account, and maintaining accurate account records.
• Payment processing: facilitating deposits via bKash, Nagad and Rocket, processing withdrawal requests, and maintaining a transaction history for audit purposes.
• Fraud prevention and platform security: monitoring account activity to detect and prevent fraud, money laundering, multi-accounting, and other prohibited conduct described in our Terms.
• Responsible gaming compliance: using gaming activity data to identify problem gambling indicators, applying deposit limits, and supporting self-exclusion requests.
• Legal and regulatory obligations: retaining transaction records in compliance with applicable anti-money laundering requirements and responding to lawful requests from competent authorities.
• Customer support: using your contact details and account information to respond to enquiries, investigate complaints, and resolve disputes.
• Service improvement and analytics: using aggregated, anonymised data to understand how players use 33wm, improve platform features, and optimise the gaming experience for Bangladeshi players.

Legal Basis

Our Legal Grounds for Processing Personal Data

33wm processes personal data on one or more of the following legal grounds, depending on the specific processing activity involved.

• Contractual necessity: processing required to fulfil our obligations under the Terms of Service you accepted when creating your account, including processing payments and maintaining your account.
• Legal obligation: processing required for 33wm to comply with applicable laws, including anti-money laundering regulations, age verification obligations, and responding to lawful authority requests.
• Legitimate interests: processing for fraud prevention, platform security, and responsible gaming monitoring, which are necessary for the safe and fair operation of the platform and do not override your fundamental rights.
• Consent: where we send you promotional communications or non-essential cookies, we rely on your consent. You may withdraw consent at any time by contacting [email protected] or adjusting your browser cookie settings without affecting the lawfulness of processing before withdrawal.

Data Sharing

When and With Whom We Share Your Data

33wm does not sell, rent or trade personal data. We share personal data only in the limited circumstances set out below, and only to the minimum extent necessary for the stated purpose.

• Payment processors: mobile wallet providers (bKash, Nagad, Rocket) receive the minimum transaction data necessary to process your deposit or withdrawal. These providers operate under their own privacy policies and are independent data controllers for their own processing activities.
• Game providers: software providers such as Pragmatic Play, Evolution Gaming, Spribe, Ezugi, and Microgaming may receive session identifiers and game data necessary to serve game content. Game providers do not receive your identity or payment data.
• Regulatory and law enforcement authorities: where required by applicable law or a lawful order from a competent authority, 33wm may disclose personal data to government agencies, law enforcement bodies, or regulatory authorities. 33wm will notify you of such disclosure to the extent permitted by law.
• Service providers and technical partners: hosting, analytics, and infrastructure providers who process data on our behalf under strict data processing agreements that prohibit them from using your data for any purpose beyond providing services to 33wm.

Payment Data

How We Handle bKash, Nagad and Rocket Transaction Data

When you make a deposit or withdrawal via bKash, Nagad or Rocket, 33wm receives a transaction reference number, the mobile wallet number associated with the transaction, the transaction amount in Bangladeshi Taka (৳), and the transaction timestamp. We do not receive or store your mobile wallet PIN or password at any point in this process. Payment data is processed solely for the purpose of crediting or debiting your 33wm balance and maintaining your transaction history.

Transaction records are retained for a minimum of five years from the date of the transaction in order to comply with applicable anti-money laundering record-keeping requirements. After this period, transaction records are permanently deleted unless a longer retention period is required by law or is necessary in connection with ongoing legal proceedings.

Cookies

How 33wm Uses Cookies and Similar Tracking Technologies

33wm uses cookies and similar technologies (such as local storage and session tokens) to operate the platform, maintain your logged-in session, detect fraud, and improve the player experience. The categories of cookies we use are described below.

• Essential cookies: strictly necessary for the platform to function. These include session authentication cookies that keep you logged in and security tokens that protect your account from cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Functional cookies: remember your preferences such as language settings and display options so you do not need to re-configure them on each visit. These are set on the basis of your consent and can be disabled via your browser settings.
• Analytics cookies: collect anonymised, aggregated data about how players navigate the platform (pages visited, time on page, referral source). This data is used solely to improve platform design and performance and cannot be used to identify you individually.
• Security and fraud-detection cookies: identify unusual patterns of platform use that may indicate fraud, bot activity, or multi-accounting. These operate as essential cookies and cannot be disabled.

You can manage non-essential cookie preferences through your browser settings at any time. Please note that disabling functional cookies may affect your user experience on the platform, such as requiring you to re-enter language preferences on each visit.

Data Retention

How Long We Keep Your Personal Data

33wm retains personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply: active account data is retained for the duration of your account plus two years after account closure; transaction and financial records are retained for a minimum of five years from the date of the transaction; identity and KYC verification documents are retained for five years from the date of account closure; and support correspondence is retained for three years from the date of the last communication.

When the applicable retention period expires, 33wm permanently deletes or anonymises personal data so that it can no longer be linked to an identifiable individual. Where permanent deletion is not immediately possible due to technical constraints (for example, data held in backup storage), the data is isolated and protected from further processing until deletion is practicable.

Data Security

How 33wm Protects Your Personal Information

33wm implements appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Our security framework includes the measures described below.

No security measure is completely impenetrable. In the unlikely event of a personal data breach that is likely to result in a risk to your rights and freedoms, 33wm will notify affected players without undue delay and take immediate steps to contain and remediate the breach.

Your Rights

Your Data Protection Rights as a 33wm Player

As a player on 33wm, you have the following rights in relation to your personal data. To exercise any of these rights, contact [email protected] with your registered mobile number and a description of your request. We will respond within 30 days of receiving a valid request.

Please note that some rights are qualified and may not apply in every circumstance. 33wm will always explain the reason if it is unable to fulfil a data rights request, and will inform you of any available remedies.

Minors

Age Restriction and Protection of Minors

33wm does not knowingly collect personal data from any person under 21 years of age. The platform is strictly for adults aged 21 and above. If 33wm discovers that it has inadvertently collected personal data from a person under 21, that data will be permanently deleted immediately and the associated account will be closed.

Third Parties

Third-Party Platforms and External Links

33wm integrates third-party game content provided by independent software vendors. While these game providers operate their games within the 33wm platform environment, they may independently collect technical data (such as game session performance data) necessary to serve their content. 33wm is not responsible for the privacy practices of independent game providers. We encourage you to review the privacy policies of game providers directly if you have concerns about how they handle data generated during gameplay.

33wm does not include links to external websites in its platform content. If you navigate away from 33wm to any external website, 33wm is not responsible for the privacy or security practices of that site. This Privacy Policy applies solely to the 33wm platform at https://33wm.ws.

Policy Updates

Changes to This Privacy Policy

33wm may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable law, or improvements to the platform. The revised Policy will be published on this page with an updated "Last Updated" date. We encourage you to review this page periodically to remain informed of how we handle your personal data.

Where a change to this Policy materially affects your rights or the way we process your data, 33wm will notify you via your registered mobile number or by displaying a prominent notice on the platform. Continued use of the platform following the effective date of any revision constitutes your acceptance of the updated Policy.

Contact Us

Privacy Enquiries and Data Rights Requests

If you have any questions about this Privacy Policy, wish to exercise any of your data protection rights, or have a concern about how 33wm has handled your personal data, please contact our support team. All privacy-related requests are handled by our support team and we aim to respond within 30 days of receiving a complete request. Bangladesh Standard Time (BST, UTC+6) applies to all response-time commitments.