Privacy Policy: How 39ok Collects, Uses, and Safeguards Your Personal Data

1. Information We Collect

39ok collects personal data in two broad categories: information you provide directly to us, and information collected automatically when you interact with the platform. The specific data points collected depend on how you use the platform and which services you access.

1.1 Information You Provide Directly

When you register an account, make transactions, or contact support, 39ok may collect the following:

• 1.1.1 Identity data: Full legal name, date of birth, gender, and national identity number (where required for KYC verification).
• 1.1.2 Contact data: Email address, mobile phone number, and residential address in Bangladesh or wherever you are located at the time of registration.
• 1.1.3 Account credentials: Username and encrypted password. We do not store passwords in plain text under any circumstances.
• 1.1.4 Identity verification documents: Copies of government-issued identification such as a National Identity Card (NID), passport, or driver's licence, submitted in connection with KYC or AML compliance checks.
• 1.1.5 Financial data: Your registered bKash, Nagad, Rocket, or Upay mobile number; Visa or Mastercard details (card number, expiry, and billing name, processed directly by our payment partners — see Section 4 for more detail). We do not store full card numbers on 39ok servers.
• 1.1.6 Communications data: Records of correspondence between you and the 39ok support team, including chat logs, emails, and call notes, retained for quality assurance and dispute resolution.

1.2 Information Collected Automatically

When you visit or interact with the 39ok platform, certain technical data is collected automatically:

• 1.2.1 Device and browser data: IP address, browser type and version, operating system, device model, screen resolution, and language settings.
• 1.2.2 Usage data: Pages visited, games played, session duration, bet amounts, win/loss history, deposit and withdrawal history, and navigation patterns within the platform.
• 1.2.3 Cookies and tracking technologies: Session cookies, persistent cookies, and similar technologies as described in Section 4 of this policy.
• 1.2.4 Geolocation data: Approximate geographic location derived from your IP address, used to verify jurisdictional eligibility and to comply with applicable regional access restrictions.

2. How We Use Your Data

39ok uses the personal data collected from you for the following specific purposes. We process your data only where we have a lawful basis for doing so, which in most cases is the performance of our contract with you (your account agreement), compliance with legal obligations, or our legitimate interests in operating a secure and fair gambling platform.

39ok does not use your personal data to make fully automated decisions that produce significant legal effects on you without human review. Where automated systems flag an account for potential fraud or AML concern, a trained compliance team member reviews the case before any account action is taken.

3. Data Sharing and Disclosure

39ok does not sell your personal data to any third party. However, to operate the platform effectively and meet our legal obligations, we share certain data with carefully selected categories of recipients.

3.1 Payment Service Providers

To process deposits and withdrawals, we share necessary financial and identity data with our payment partners — bKash, Nagad, Rocket, Upay, and the card networks Visa and Mastercard. Each of these providers operates under its own privacy and data security standards, which we encourage you to review independently. 39ok shares only the minimum data required to complete each transaction.

3.2 Game Technology Providers

The casino games, live dealer studios, and sportsbook products available on the 39ok platform are powered by third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, among others. These providers receive anonymised or pseudonymised gameplay data necessary to deliver their products. They do not receive your full identity profile.

3.3 Identity Verification and AML Services

Where we are required to verify your identity or conduct anti-money-laundering checks, we may share your identity documents and personal details with accredited third-party verification service providers. These providers are bound by strict confidentiality agreements and data processing terms.

3.4 Legal and Regulatory Authorities

39ok will disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law, court order, or in connection with the investigation of financial crime, fraud, or other unlawful activity. We will notify affected users of such disclosures where legally permitted to do so.

4. Cookies and Tracking Technologies

The 39ok platform uses cookies and similar tracking technologies to deliver a functional, personalised, and secure experience. A cookie is a small text file stored on your device by your browser when you visit a website.

4.1 Types of Cookies We Use

• 4.1.1 Strictly necessary cookies: These are essential for the platform to function. They enable session management, login authentication, and security features. These cookies cannot be disabled without breaking core platform functionality.
• 4.1.2 Performance and analytics cookies: These collect anonymised information about how users interact with the platform, including which pages are visited most frequently and where errors occur. This data is used to improve platform performance and user experience.
• 4.1.3 Functional cookies: These remember your preferences — such as your language setting, last-used payment method, and interface customisations — so that you do not need to reconfigure them each time you visit.
• 4.1.4 Marketing and retargeting cookies: With your consent, these cookies allow 39ok to serve you relevant promotional content. You may withdraw this consent at any time via your browser settings or by contacting support.

4.2 Managing Your Cookie Preferences

Most modern browsers allow you to control cookie behaviour through browser settings, including the ability to block or delete cookies entirely. Please note that disabling strictly necessary cookies will impair the functionality of the 39ok platform and may prevent you from logging in or completing transactions. For instructions on managing cookies in your specific browser, consult your browser's help documentation.

5. Data Retention

39ok retains your personal data for as long as your account remains active and for a defined period after account closure, in accordance with our legal and regulatory obligations. The general retention principles we apply are as follows:

• 5.1 Active accounts: All personal data associated with an active account is retained for the duration of the account's existence plus any mandatory post-closure retention period required by applicable law.
• 5.2 Closed accounts: Following voluntary or involuntary account closure, 39ok retains identity, transaction, and communication records for a minimum of five (5) years to comply with anti-money-laundering legislation and financial record-keeping requirements.
• 5.3 Marketing data: Where you have consented to receive marketing communications, your contact details are retained for this purpose until you withdraw consent. Withdrawal of marketing consent does not affect the retention of data required for other lawful purposes.
• 5.4 Support communications: Records of customer support interactions are retained for a minimum of two (2) years from the date of the most recent interaction, for quality assurance and dispute resolution purposes.
• 5.5 Responsible gaming records: Self-exclusion requests, deposit limit settings, and related responsible gaming records are retained for a minimum of five (5) years following account closure to prevent circumvention of these protections through re-registration.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any individual.

6. Data Security Measures

39ok implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, alteration, disclosure, or destruction. While no platform can guarantee absolute security, the measures we maintain include:

• 6.1 Transport Layer Security (TLS): All data transmitted between your device and 39ok servers is encrypted using TLS 1.2 or higher. This protects your login credentials, payment details, and personal information in transit.
• 6.2 Password hashing: Account passwords are stored using a strong one-way cryptographic hashing algorithm. Plain-text passwords are never written to disk or logged anywhere in our systems.
• 6.3 Two-factor authentication (2FA): 39ok offers SMS OTP-based two-factor authentication for all accounts. We strongly recommend enabling 2FA to add a second layer of protection against unauthorised access.
• 6.4 Access controls: Access to systems storing personal data is restricted to authorised 39ok personnel on a need-to-know basis. All access is logged, and access rights are reviewed periodically.
• 6.5 Security monitoring: Our infrastructure is subject to continuous monitoring for anomalous activity, intrusion attempts, and potential data breaches. Incident response procedures are in place to contain and address security events promptly.
• 6.6 Vendor due diligence: Third-party service providers who process personal data on our behalf are vetted for their security practices and are required to maintain data processing agreements that bind them to equivalent security standards.

7. Your Privacy Rights

As a user of the 39ok platform, you hold a number of rights in relation to your personal data. To exercise any of the rights listed below, please submit a written request to our support team at [email protected]. We will acknowledge your request within 5 business days and aim to fulfil it within 30 days, subject to identity verification.

• 7.1 Right of access: You have the right to request a copy of the personal data that 39ok holds about you, along with information about how it is being processed.
• 7.2 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 may also update certain details directly via your account settings.
• 7.3 Right to erasure: You may request that 39ok delete your personal data where it is no longer necessary for the purposes for which it was collected. Please note that this right is subject to our legal obligations to retain certain records (see Section 5).
• 7.4 Right to restrict processing: In certain circumstances, you may request that 39ok limit how your personal data is processed — for example, while a dispute about data accuracy is being resolved.
• 7.5 Right to data portability: Where processing is based on your consent or on a contract, you may request a copy of your personal data in a structured, machine-readable format for transfer to another service provider.
• 7.6 Right to withdraw consent: Where 39ok processes your data on the basis of your consent (for example, for 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.
• 7.7 Right to object: You have the right to object to processing of your personal data carried out on the basis of legitimate interests, including profiling for direct marketing purposes.

We will not charge a fee for exercising any of the rights listed above in standard circumstances. However, where requests are manifestly unfounded or excessive — particularly where they are repetitive — we reserve the right to charge a reasonable administrative fee or to refuse to act on the request, with written justification provided to you.

8. Updates to This Policy

39ok reserves the right to update this Privacy Policy at any time. When material changes are made, we will post the revised policy on this page with an updated effective date at the top of the document. For significant changes that materially affect how your data is processed, we will notify registered users via the email address associated with their 39ok account.

Your continued use of the 39ok platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you should discontinue use of the platform and request account closure by contacting our support team.

For any questions, concerns, or requests relating to this Privacy Policy or to the handling of your personal data, please contact us at: