399de Privacy Policy

1. Introduction

This Privacy Policy ("Policy") sets out the practices of 399de ("399de", "we", "us", "our") with respect to the collection, use, storage, and disclosure of personal information provided by or collected from users ("you", "your", "Player") who access and use the online gaming platform at https://399de.io ("Platform").

By registering an account on the 399de Platform, making a deposit, placing a bet, or otherwise using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

This Policy should be read alongside the 399de Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of a conflict between this Policy and those documents on a privacy-related matter, this Policy shall prevail.

2. Data Controller

399de is the data controller responsible for the personal information collected through the Platform. As data controller, 399de determines the purposes and means by which your personal data is processed. All enquiries relating to data protection and privacy should be directed to our support team at [email protected] with the subject line "Privacy Enquiry".

3. Data We Collect

399de collects the following categories of personal data from players in Bangladesh and other eligible jurisdictions:

3.1 Identity Data

Full legal name, date of birth, gender, nationality, and copies of government-issued identity documents (such as Bangladesh National Identity Card, passport, or driving licence) provided during account registration or KYC verification.

3.2 Contact Data

Email address, mobile phone number registered to a Bangladesh network operator, and residential address including city (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar), district, and postcode.

3.3 Financial Data

Payment method details including mobile banking account numbers associated with bKash, Nagad, Rocket, or Upay; bank account details for Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, or Sonali Bank; and masked card details for Visa or Mastercard transactions. Full card numbers are never stored on 399de servers — they are handled directly by PCI-DSS compliant payment processors.

3.4 Transactional Data

Records of all deposits, withdrawals, bonuses claimed, bets placed, games played, and winnings received. This includes timestamps, amounts in Bangladeshi Taka (৳), game titles, market selections (e.g., BPL or IPL cricket markets), and transaction reference numbers.

3.5 Technical Data

IP address, device type and model, operating system version, browser type and version, screen resolution, time zone, and referring URL. This data is collected automatically when you access the Platform.

3.6 Usage Data

Session start and end times, pages and game screens visited, features accessed, search queries made within the Platform, and interaction patterns such as click paths and scroll depth.

3.7 Communications Data

Records of all communications between you and 399de, including live chat transcripts, support emails, feedback submissions, and any documents or attachments you send to us.

4. How We Collect Your Data

399de collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and usage data collected automatically via cookies, server logs, and similar tracking technologies when you access the Platform.
• Third-party sources: Identity and address verification data received from KYC service providers; fraud risk scores from fraud prevention partners; payment confirmation data from bKash, Nagad, Rocket, Upay, and other payment processors.
• Public sources: Publicly available information used to verify identity details or to comply with anti-money laundering (AML) obligations.

5. Legal Basis for Processing

399de processes your personal data on one or more of the following legal bases:

6. How We Use Your Data

399de uses the personal data we collect for the following purposes:

• To create, maintain, and manage your 399de account;
• To verify your identity and age (21+ requirement) in accordance with our KYC obligations;
• To process your deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods in Bangladeshi Taka (৳);
• To provide access to casino games (including titles from Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi) and cricket betting markets (BPL, IPL, T20 World Cup, Bangladesh Tigers fixtures);
• To administer bonuses, promotions, and loyalty programmes in accordance with the applicable offer terms;
• To detect, investigate, and prevent fraud, cheating, collusion, money laundering, and other prohibited activities;
• To monitor playing behaviour for responsible gaming purposes and to make appropriate interventions where warranted;
• To respond to your customer support queries and to maintain records of those communications;
• To send you transactional communications such as deposit confirmations, withdrawal notifications, and security alerts;
• To send you promotional communications about 399de offers and new features, where you have consented to receive such communications;
• To analyse Platform usage patterns in order to improve the user experience, game offering, and technical performance;
• To comply with applicable legal and regulatory obligations.

6.1 Marketing Communications

If you have opted in to receive promotional communications from 399de, we may send you emails or platform notifications about new games, bonus offers, cricket betting promotions, and seasonal campaigns (for example, during BPL season, Eid, or Pohela Boishakh). You may withdraw your consent to receive marketing communications at any time by contacting [email protected] or by using the unsubscribe link included in every marketing email. Withdrawal of consent for marketing communications does not affect the lawfulness of processing carried out before withdrawal.

7. Data Sharing & Third Parties

399de does not sell your personal data. We may share your data with the following categories of third parties only to the extent necessary for the stated purposes:

7.1 Payment Processors

Deposit and withdrawal transactions require the transfer of necessary payment reference data to your chosen payment provider (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, Mastercard). These providers process your payment data under their own privacy policies and are bound by the security standards applicable to their respective industries (e.g., PCI-DSS for card processors).

7.2 Identity Verification Providers

To satisfy our KYC obligations, we share identity documents and relevant personal data with third-party identity verification service providers. These providers are contractually bound to process your data only for the verification purpose and to maintain appropriate security standards.

7.3 Game Software Providers

Game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and others) may receive technical session data and game result records necessary for the operation of their games. These providers do not receive your full identity or financial data.

7.4 Fraud Prevention & Security Partners

We may share IP addresses, device fingerprints, and transaction data with fraud prevention partners to detect and prevent abuse of the Platform. This sharing is carried out on the basis of 399de's legitimate interests in maintaining a secure and fair gaming environment.

7.5 Legal & Regulatory Authorities

399de may disclose personal data to law enforcement agencies, regulatory bodies, or other government authorities where required to do so by applicable law, court order, or regulatory direction. We will notify you of any such disclosure unless prohibited from doing so by law.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files stored on your device by your web browser when you visit a website. 399de uses cookies and similar technologies (including local storage and session tokens) to keep your login session active, remember your display preferences, and collect anonymised analytics data about how the Platform is used.

8.2 Types of Cookies We Use

399de does not use third-party advertising cookies or cross-site tracking pixels. You may control cookie settings through your browser preferences; however, disabling strictly necessary cookies will prevent you from logging in to your 399de account.

9. Data Retention

399de retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account data: Retained for the lifetime of your account and for a minimum of five years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction records: Retained for a minimum of five years from the date of each transaction.
• KYC documents: Retained for a minimum of five years following account closure or the completion of the transaction to which the KYC check relates.
• Customer support communications: Retained for three years from the date of the last communication in the relevant support thread.
• Analytics data: Retained in anonymised, aggregated form indefinitely; identifiable usage data is deleted or anonymised after 12 months.
• Marketing consent records: Retained until you withdraw consent and for a period of three years thereafter as evidence of the consent having been given.

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

10. Data Security

399de implements a range of technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS 1.2 or higher SSL encryption on all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial data;
• Multi-factor authentication options for player accounts;
• Role-based access controls ensuring that staff members access only the data necessary for their specific job function;
• Regular penetration testing and vulnerability assessments of Platform infrastructure;
• Automated monitoring and alerting for unusual login patterns or transaction behaviours indicative of account compromise;
• Contractual data processing agreements with all third-party service providers who handle personal data on our behalf.

While 399de takes every reasonable precaution to secure your data, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately at [email protected] if you suspect any unauthorised access to your account.

11. Your Data Rights

Subject to applicable law, you have the following rights in relation to the personal data that 399de holds about you:

• Right of Access: You may request a copy of the personal data we hold about you. We will respond to verified access requests within 30 calendar days.
• Right to Rectification: You may request that we correct any inaccurate or incomplete personal data held about you. Certain corrections (e.g., name changes) may require supporting documentation.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Data that we are required by law to retain (e.g., KYC and transaction records) cannot be erased during the applicable retention period.
• Right to Restriction: You may request that we restrict the processing of your data in certain circumstances, for example while a rectification request is being assessed.
• Right to Data Portability: You may request that we provide your personal data to you in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your data where it is carried out on the basis of legitimate interests, including direct marketing. Upon receipt of a valid objection to marketing processing, we will cease such processing immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please contact [email protected] with the subject line "Data Rights Request" and include your registered account username and a description of the right you wish to exercise. We may ask you to verify your identity before processing your request. We will respond to all valid requests within 30 calendar days; where a request is particularly complex or numerous, we may extend this period by up to a further 30 days and will inform you accordingly.

12. Children's Privacy

The 399de Platform is strictly intended for adults aged 21 and above in Bangladesh. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register an account or use the Platform in any way.

If 399de becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has created a 399de account, please notify us immediately at [email protected].

13. Changes to This Policy

399de reserves the right to update or amend this Privacy Policy at any time. When we make a material change to how we collect, use, or share your personal data, we will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending an email to your registered address, at least 14 calendar days before the change takes effect.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy. We encourage you to review this page periodically. The date of the most recent revision is displayed at the top of this document.

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 399de handles your personal data, please contact us through the following channel:

• Email: [email protected]
• Subject line for privacy matters: "Privacy Enquiry" or "Data Rights Request"
• Support hours: 24 hours a day, 7 days a week (Bangladesh Standard Time, UTC+6)
• Response time: Typically within 2 hours for general queries; within 30 calendar days for formal data rights requests

We are committed to working with you to resolve any privacy concerns fairly and promptly. If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.