37bd Privacy Policy — Your Data, Your Rights
This Privacy Policy explains exactly what personal data 37bd collects from players in Bangladesh, how that data is used and protected, who it may be shared with, and what rights you hold over your information at all times.
Our Core Privacy Principles
Six commitments that guide how 37bd handles your personal data — every day, across every part of the platform.
Data Minimisation
37bd collects only the personal data that is strictly necessary for account registration, identity verification, payment processing, and legal compliance. We do not collect data for the sake of collecting it.
Security by Default
All data held by 37bd is stored with encryption at rest and transmitted exclusively over HTTPS with SSL/TLS encryption. Passwords are hashed using industry-standard algorithms — no 37bd employee can read your password.
Your Rights Are Real
You have the right to access, correct, or request deletion of your personal data held by 37bd, subject to our legal retention obligations. These rights can be exercised at any time by contacting our support team.
No Data Sales
37bd will never sell, rent, or trade your personal data to third-party advertisers or data brokers. Your information exists to enable your account and protect the platform — not to generate revenue from your profile.
Full Transparency
This Privacy Policy is written in plain, accessible English so you understand exactly what 37bd does with your data. If anything changes materially, we will notify you through the platform before the change takes effect.
Limited Retention
37bd retains personal data only for as long as it is needed for the purpose it was collected, or as required by applicable anti-money laundering and financial record-keeping obligations. Data no longer needed is securely deleted.
1 Introduction
37bd ("we", "us", "our") operates the online betting and gaming platform accessible at 37bd.io. In the course of providing our services to players in Bangladesh and beyond, we collect and process certain personal data about you. This Privacy Policy sets out the full details of that processing — what data we collect, why we collect it, how we use it, and your rights in relation to it.
This policy should be read alongside the 37bd Terms & Conditions, which govern your use of the platform. Where processing of personal data is connected to a specific feature of the platform (such as the responsible gaming tools or promotional offers), additional privacy notices may be provided at the point of data collection to supplement this policy.
If you have any questions about this Privacy Policy or how 37bd handles your data, you can reach our team at any time via the live chat function within the platform or by emailing . We are committed to responding to all privacy-related enquiries within 5 business days.
2 Data We Collect
37bd collects personal data from you through several channels: directly when you register or update your account, automatically as you use the platform, and from third-party verification and payment providers as part of our legal compliance obligations. The categories of data we collect are set out below.
Registration and Identity Data
- Full legal name as it appears on your government-issued identification document
- Date of birth (used for age verification — 37bd is a 21+ platform)
- Email address (used as your primary account identifier and communications channel)
- Residential address, including division (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh)
- Mobile phone number
- Username and hashed password
Identity Verification (KYC) Data
- Scanned or photographed copy of a government-issued photo ID (National ID Card, passport, or driving licence)
- Proof of address document (utility bill, bank statement, or similar, dated within three months)
- In cases where enhanced due diligence is required: source of funds documentation
Financial and Transaction Data
- Payment method details — mobile financial services account identifiers for bKash, Nagad, Rocket, and Upay; card type and last four digits for Visa and Mastercard transactions
- Deposit and withdrawal history, including amounts in BDT and timestamps
- Betting and gaming transaction records, including wager amounts, game types, outcomes, and balances
Technical and Usage Data
- IP address and approximate geolocation derived from IP
- Device type, operating system, and browser information
- Session timestamps, duration, and navigation patterns within the platform
- Cookie identifiers and similar tracking technologies (see Section 6)
Communications Data
- Content of messages sent to 37bd via live chat, email, or any support channel
- Records of promotional communications sent to you and your engagement with those communications
3 How We Use Your Data
37bd uses the personal data it collects for the following purposes:
| Purpose | Data Used |
|---|---|
| Creating and managing your 37bd account | Registration data, identity data |
| Verifying your identity and age (KYC) | KYC documents, date of birth, address |
| Processing deposits and withdrawals | Financial data, payment method identifiers |
| Preventing fraud and money laundering | All categories; transaction patterns, IP data |
| Providing customer support | Account data, communications data |
| Administering bonuses and promotions | Account data, transaction data |
| Responsible gaming monitoring | Transaction data, usage data, communications data |
| Improving platform performance and UX | Technical data, usage data (aggregated) |
| Sending service communications | Email address, mobile number |
| Sending promotional offers (with consent) | Email address, mobile number, gaming preferences |
| Complying with legal obligations | All categories as required by applicable law |
37bd does not use your data for automated decision-making that produces legal or similarly significant effects on you without human review. Where automated tools are used for fraud detection or responsible gaming monitoring, a human member of our compliance team reviews any outcome before action is taken on your account.
4 Legal Bases for Processing
37bd processes personal data under the following legal bases:
Contractual Necessity
The majority of data processing at 37bd is necessary to perform our contract with you as a registered player — that is, to provide the betting and gaming services you have signed up for. This includes account creation, payment processing, KYC verification, and customer support. Without this processing, we cannot deliver the services.
Legal Obligation
Certain processing is required for 37bd to comply with applicable anti-money laundering regulations, age-verification requirements, and financial record-keeping obligations. This includes the collection and retention of KYC documents and transaction records for the periods prescribed by law.
Legitimate Interests
37bd processes technical and usage data for the purposes of fraud prevention, platform security, and improving the quality of our services. These activities serve a legitimate interest that we have carefully balanced against your privacy rights. We also use limited data to identify responsible gaming concerns — which we consider a legitimate and necessary interest in the context of an online gambling platform.
Consent
Where 37bd sends you marketing communications about promotional offers, new games, or seasonal events, we do so only on the basis of your consent, which you provide at the time of registration and which you may withdraw at any time by updating your communication preferences within your account settings or by contacting support.
5 Data Sharing
37bd shares personal data with third parties only where there is a clear and lawful basis for doing so. We do not sell personal data to any third party. The categories of recipients with whom we share data are as follows:
Payment Service Providers
To process your deposits and withdrawals, 37bd shares the minimum necessary data with our payment partners, including bKash, Nagad, Rocket, Upay, and card processing networks (Visa, Mastercard). These providers operate under their own privacy policies and are contractually bound to handle your data securely and exclusively for payment processing purposes.
Identity Verification Providers
37bd uses third-party KYC and identity verification services to authenticate the documents you submit during account verification. These providers process your identity documents on our behalf under strict data processing agreements and do not retain your documents beyond the verification period.
Fraud Prevention and AML Services
37bd employs third-party fraud detection and anti-money laundering screening tools. These services may receive account activity data, device fingerprints, and IP data in order to identify suspicious patterns. All such providers are contractually bound to process data only for the stated purpose.
Game Providers
When you play games provided by third-party studios (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi), the game software may receive a session token and your account tier to enable gameplay. Game providers do not receive your full personal profile or payment details.
Regulatory and Law Enforcement Bodies
37bd will disclose personal data to government authorities, regulators, or law enforcement agencies where required to do so by applicable law, court order, or where disclosure is necessary to prevent or detect crime, protect national security, or exercise or defend legal rights.
6 Cookies and Tracking Technologies
37bd uses cookies and similar technologies (such as local storage objects and session tokens) to operate the platform, maintain your login session, and collect anonymised analytics data about platform usage. The types of cookies used are described below:
Strictly Necessary Cookies
These cookies are essential for the platform to function. They include session authentication tokens that keep you logged in, CSRF protection tokens, and load-balancing identifiers. These cookies cannot be disabled without preventing the platform from operating correctly.
Analytics Cookies
37bd uses anonymised analytics tools to understand how players navigate the platform, which pages are visited most frequently, and where technical errors occur. This data is aggregated and does not identify individual users. Analytics data is used exclusively to improve the platform's performance and user experience.
Functional Cookies
Functional cookies remember your preferences — such as your chosen language, notification settings, and responsible gaming configurations — so that these are preserved between sessions without requiring you to reset them each time you log in.
Managing Cookies
You can control cookie behaviour through your browser settings. Note that disabling strictly necessary cookies will impair or prevent access to the 37bd platform. Disabling analytics or functional cookies will not affect your ability to place bets or access your account, but may result in a degraded or less personalised experience.
7 Data Security
37bd takes the security of your personal data seriously. We implement a comprehensive set of technical and organisational measures to protect your data against unauthorised access, disclosure, alteration, and destruction. Key security measures include:
- Encryption in transit: All data exchanged between your browser or device and the 37bd platform is encrypted using TLS 1.2 or higher. The platform is accessible exclusively over HTTPS.
- Encryption at rest: Sensitive personal data stored on 37bd servers, including identity documents and financial records, is encrypted at rest using AES-256 encryption.
- Password hashing: Account passwords are hashed using a one-way cryptographic algorithm. 37bd employees and systems cannot retrieve your password in plain text under any circumstances.
- Access controls: Access to personal data within the 37bd organisation is restricted on a strict need-to-know basis. Staff with access to sensitive data undergo regular security training and are subject to confidentiality obligations.
- System monitoring: 37bd maintains continuous monitoring of its systems and infrastructure for unusual activity, with automated alerts and a defined incident response process.
- Regular security assessments: The platform undergoes periodic security testing to identify and remediate vulnerabilities before they can be exploited.
In the event of a data breach that is likely to result in a risk to your rights and freedoms, 37bd will notify affected players without undue delay and take all reasonable steps to contain and mitigate the breach.
8 Data Retention
37bd retains your personal data for as long as your account remains active and for the period required by applicable law following account closure. The principal retention periods are as follows:
| Data Category | Retention Period | Reason |
|---|---|---|
| Account and registration data | Duration of account + 5 years post-closure | AML and financial record-keeping obligations |
| KYC identity documents | Duration of account + 5 years post-closure | Age-verification and AML compliance |
| Transaction records | Duration of account + 5 years post-closure | Financial regulation and dispute resolution |
| Support communications | 3 years from last interaction | Dispute resolution and service improvement |
| Marketing consent records | Until consent is withdrawn + 1 year | Demonstrating lawful marketing basis |
| Technical/usage logs | 13 months on a rolling basis | Security monitoring and analytics |
Data that has reached the end of its retention period is securely deleted or anonymised so that it can no longer be associated with your identity. Anonymised, aggregated data may be retained indefinitely for statistical and platform-improvement purposes.
9 Your Rights
As a 37bd player, you hold the following rights in respect of your personal data. To exercise any of these rights, contact our support team via live chat or at . We will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days.
Right of Access
You may request a copy of all personal data 37bd holds about you, along with information about how it is being used.
Right to Rectification
If any personal data 37bd holds about you is inaccurate or incomplete, you have the right to have it corrected without undue delay.
Right to Erasure
You may request that 37bd delete your personal data. This right is subject to our legal retention obligations and may not apply to data we are required to keep by law.
Right to Restriction
In certain circumstances, you may request that 37bd restrict the processing of your data while a query or complaint is being resolved.
Right to Portability
Where technically feasible and lawfully permitted, you may request a machine-readable copy of the personal data you provided to 37bd directly.
Right to Withdraw Consent
Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time with immediate effect.
10 Children and Minors
The 37bd platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from anyone under the age of 21. Age verification is a mandatory step in the account registration and withdrawal process, and 37bd employs active measures to detect and prevent underage access.
If 37bd discovers that personal data has been collected from a person under the age of 21, the account in question will be immediately suspended, all balances will be returned to the source payment method (where this does not conflict with our AML obligations), and the personal data will be deleted from our systems as promptly as possible consistent with our legal obligations.
If you believe that a minor has registered a 37bd account or has gained access to the platform, please report this to us immediately at . We treat reports of this nature as the highest priority.
11 International Data Transfers
37bd is an internationally operated platform. In the course of delivering our services and working with third-party providers (such as KYC verification services, fraud prevention tools, and game providers), your personal data may be transferred to and processed in countries outside Bangladesh. Such transfers occur exclusively with providers who are contractually bound to maintain data protection standards consistent with this Privacy Policy.
Where data is transferred internationally, 37bd ensures appropriate safeguards are in place — including data processing agreements with standard contractual clauses or equivalent protections — to ensure that your data receives an adequate level of protection regardless of where it is processed.
12 Third-Party Links and Services
The 37bd platform may display informational references to third-party game providers and payment services. 37bd is not responsible for the privacy practices of any third-party service, and this Privacy Policy does not apply to any third-party website, application, or service that you access independently of the 37bd platform. We encourage you to read the privacy policies of any third-party service before providing them with your personal information.
13 Updates to This Privacy Policy
37bd reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. Where a material change is made to this policy, we will notify you by displaying a prominent notice on the platform or by sending a notification to the email address registered on your account, prior to the change taking effect.
The effective date at the top of this document reflects the date of the most recent revision. Continued use of the 37bd platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any update, you may request account closure in accordance with the Terms & Conditions.
14 Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the way 37bd handles your personal data, please contact our team through any of the following channels:
- Live Chat: Available 24/7 within the 37bd platform — the quickest way to reach our team for any privacy-related query.
- Email: — for formal data subject requests, complaints, or document submissions. Please include "Privacy Request" in your subject line so your message is routed to the appropriate team member.
Our support team operates in English around the clock, every day of the year, in Bangladesh Standard Time (BST, UTC+6). We are committed to acknowledging all privacy-related enquiries within 5 business days and resolving them within 30 calendar days wherever possible.
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