39bat Privacy Policy
At 39bat, protecting your personal data is a responsibility we take seriously. This Privacy Policy explains in plain terms what information we collect from you, why we collect it, how it is used and stored, and what rights you have over your own data. Your trust is the foundation of everything we do at 39bat.
Six Privacy Principles We Live By
These are the core data-protection principles that guide how 39bat handles every piece of information you entrust to us. They apply across all our services — casino games, sports betting, payment processing, and customer support.
Purpose Limitation
We collect your personal data only for clearly defined, legitimate purposes directly related to operating the 39bat platform. Your data is never processed for unrelated purposes without your explicit consent.
Data Minimisation
39bat collects only the minimum data necessary to deliver our services effectively. We do not request information that is excessive relative to the stated purpose of collection, and we regularly review the data we hold to ensure ongoing necessity.
Storage Security
All personal data stored on 39bat servers is protected by 256-bit SSL encryption in transit and AES-256 encryption at rest. Access to personal data is restricted to authorised personnel only, under strict access control policies.
Your Rights Come First
You have the right to access, correct, port, restrict, or erase your personal data held by 39bat. We have built clear, reachable processes for exercising each of these rights, and we respond to all valid data requests within 30 days.
No Data Sales
39bat does not sell, rent, or trade your personal data to third-party advertisers, data brokers, or marketing agencies under any circumstances. Your data belongs to you, and we will never monetise it without your knowledge and consent.
Retention Limits
Personal data is retained only for as long as it is necessary to fulfil the purposes for which it was collected, or as required under applicable law or regulatory obligation. Once the retention period expires, data is securely deleted or anonymised.
What Data We Collect and Why
The table below provides a clear overview of each category of personal data 39bat collects, the lawful basis under which it is processed, and the specific purpose it serves.
| Data Category | Examples | Lawful Basis | Purpose |
|---|---|---|---|
| Identity Data | Full name, date of birth, national ID number, photo ID scan | Legal obligation; Contract performance | Age verification (21+), KYC compliance, account registration |
| Contact Data | Email address, mobile number, residential address | Contract performance; Legitimate interest | Account communication, transaction notifications, support responses |
| Financial Data | bKash/Nagad mobile wallet number, bank account details, transaction history | Legal obligation; Contract performance | Processing deposits and withdrawals, anti-money laundering checks |
| Technical Data | IP address, device type, browser type, operating system, session tokens | Legitimate interest | Platform security, fraud detection, account protection, session management |
| Usage Data | Pages visited, games played, bet history, session duration, feature interactions | Legitimate interest; Contract performance | Service improvement, responsible gaming monitoring, personalisation |
| Communications Data | Support chat transcripts, email correspondence, complaint records | Legitimate interest; Legal obligation | Dispute resolution, quality assurance, compliance record-keeping |
| Marketing Preferences | Opted-in promotional email consent, preferred notification channels | Consent | Sending relevant promotional communications; withdrawn at any time |
1. Introduction
This Privacy Policy ("Policy") describes how 39bat ("we", "us", "our") collects, uses, discloses, and safeguards the personal information of individuals ("you", "your", "the Player") who access or use the 39bat online casino and sports betting platform available at https://39bat.io and all associated services, applications, and features.
39bat is committed to protecting the privacy and security of every player's personal data. This Policy is designed to give you clear, honest information about our data practices so that you can make informed decisions about your engagement with the platform. We encourage you to read this Policy carefully and in full before creating an account or using our services.
By registering an account, accessing the platform, or otherwise interacting with 39bat's services, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein. If you do not agree with any part of this Policy, you should cease using the platform and may request account closure by contacting us at [email protected].
2. Personal Data We Collect
39bat collects personal data through several channels, including direct input by the player, automated technical collection, and in limited circumstances from third-party verification providers. The categories of data we collect include the following:
2.1 Information You Provide Directly
- Registration Information: When you create a 39bat account via the 39bat Login page, we collect your full legal name, date of birth, email address, mobile telephone number, and chosen account credentials.
- Identity Verification Documents: To comply with age verification requirements (21+ only) and anti-money laundering obligations, we may collect copies of government-issued photo identification, utility bills, or other documents confirming your identity and address.
- Financial Information: When you make a deposit or request a withdrawal, we collect details of the payment method used, including bKash wallet numbers, Nagad account numbers, Rocket or Upay identifiers, or bank account information for Dutch-Bangla Bank, BRAC Bank, Islami Bank, Sonali Bank, or City Bank transfers.
- Support Communications: Any messages, emails, or chat transcripts exchanged between you and our customer support team are retained as part of our service records.
- Responsible Gaming Requests: If you submit a self-exclusion request, deposit limit, or cooling-off request, we record the details of that request and the date it was actioned.
2.2 Information Collected Automatically
- Technical Data: Your IP address, browser type and version, operating system, device identifiers, screen resolution, and time zone are logged automatically when you access the platform.
- Session and Usage Data: We record pages visited, games launched, duration of play sessions, bet placement data, game outcomes, and feature interactions to monitor platform performance and detect irregular activity.
- Cookie Data: 39bat uses cookies and similar tracking technologies as described in Section 5 of this Policy.
3. How We Use Your Personal Data
39bat uses the personal data we collect for the following purposes, each of which is grounded in a lawful basis of processing:
- Account Creation and Management: To register your account, maintain your player profile, authenticate your identity at login, and manage your account settings and preferences.
- Service Delivery: To provide access to casino games, sports betting markets including cricket BPL, IPL, T20 World Cup, and Bangladesh national team fixtures, live dealer tables, and all other platform features.
- Payment Processing: To process deposits made via bKash, Nagad, Rocket, Upay, or bank transfer, and to execute withdrawal requests to your designated payment method in Bangladeshi Taka (BDT).
- Identity and Age Verification: To confirm that you meet the minimum age requirement of 21 years and to verify the accuracy of the information provided during registration.
- Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, bonus abuse, money laundering, and other prohibited activities described in the Terms and Conditions.
- Legal and Regulatory Compliance: To fulfil obligations under applicable anti-money laundering laws, record-keeping requirements, and any lawful requests from regulatory or law enforcement authorities.
- Customer Support: To respond to your support queries, resolve disputes, and maintain a record of communications for quality assurance purposes.
- Responsible Gaming: To monitor your play patterns for signs of problem gambling, enforce self-exclusion and limit requests, and proactively reach out where our systems identify concerning behaviour.
- Platform Improvement: To analyse aggregate, anonymised usage data to improve the design, performance, and content of the 39bat platform.
- Marketing Communications: Where you have given explicit consent, to send you promotional emails or notifications about bonuses, new games, seasonal offers (such as Eid or Pohela Boishakh promotions), and BPL or IPL betting specials. You may withdraw this consent at any time by contacting [email protected].
39bat will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing a fresh lawful basis for doing so.
4. Sharing Your Personal Data
39bat does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. However, in order to operate the platform and comply with our legal obligations, we may share certain personal data with the following categories of recipients:
- Payment Processors: We share financial data with the operators of bKash, Nagad, Rocket, Upay, and partner banking institutions (Dutch-Bangla Bank, BRAC Bank, Islami Bank, Sonali Bank, City Bank) solely for the purpose of processing your deposit and withdrawal transactions.
- Identity Verification Providers: We may share identity documents with third-party KYC and age verification service providers to fulfil our regulatory obligations. These providers are bound by strict data processing agreements and may not use your data for any independent purpose.
- Game Software Providers: When you play a game powered by Pragmatic Play, NetEnt, Microgaming, Habanero, Evolution Gaming, Ezugi, or Spribe, certain technical session data is shared with those providers to facilitate gameplay. Game providers do not receive your financial or full identity information.
- Fraud Prevention and Security Services: We may share technical and usage data with fraud detection service providers to protect the integrity of the platform and the security of all players.
- Legal and Regulatory Authorities: We may disclose personal data to law enforcement agencies, regulatory bodies, or courts where we are legally compelled to do so or where disclosure is necessary to protect our legal rights or the safety of our players.
- Professional Advisers: In limited circumstances, we may share data with legal, financial, or auditing advisers operating under professional confidentiality obligations.
5. Cookies and Tracking Technologies
39bat uses cookies, web beacons, and similar tracking technologies to operate the platform, maintain your session, personalise your experience, and gather analytics data that helps us improve our services. A cookie is a small text file placed on your device when you visit a website. The cookies we use fall into the following categories:
- Strictly Necessary Cookies: These cookies are essential for the platform to function. They enable core features such as account login, session management, and security protections. These cookies cannot be disabled without impairing your ability to use the platform.
- Functional Cookies: These cookies remember your preferences — such as your preferred game category or language settings — to provide a more personalised experience.
- Analytics Cookies: We use analytics cookies to collect aggregate, anonymised data about how players use the platform. This data helps us understand which pages and games are most popular, identify performance issues, and make data-driven improvements to the platform.
- Security Cookies: These cookies support our fraud detection and responsible gaming systems by tracking session behaviour patterns that may indicate suspicious or high-risk activity.
Most web browsers allow you to manage cookie settings through their preferences or settings menus. You may disable or delete cookies at any time; however, disabling strictly necessary cookies will impair the functionality of the 39bat platform, including the ability to log in or complete transactions.
39bat does not use cookies to serve third-party advertising or share your browsing behaviour with advertising networks.
6. Data Retention
39bat retains personal data only for as long as is necessary to fulfil the purposes outlined in this Privacy Policy, or as required by applicable law. The following general retention principles apply:
- Active Account Data: Personal data associated with an active 39bat account is retained for the full duration of the account's active status.
- Closed Account Data: Following the closure of a player account — whether by the player or by 39bat — we retain identity, financial, and transaction records for a minimum of five (5) years to satisfy anti-money laundering record-keeping requirements and to defend against potential legal claims.
- Support Communications: Customer support records, including chat transcripts and email correspondence, are retained for three (3) years from the date of the final communication.
- Responsible Gaming Records: Self-exclusion, cooling-off, and limit records are retained for the full self-exclusion period plus five (5) years, to prevent inadvertent re-registration during an active exclusion period.
- Analytics Data: Anonymised, aggregated analytics data is retained indefinitely as it cannot be linked back to any individual player.
- Marketing Consent Records: Records of marketing consent and withdrawal are retained for five (5) years to evidence compliance.
Upon expiry of the applicable retention period, personal data is securely and permanently deleted or irreversibly anonymised. Where deletion requests are received before the end of a mandatory retention period, we will restrict processing of the data to the extent possible while retaining only what is legally required.
7. Data Security
39bat implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include, but are not limited to:
- Encryption: All data transmitted between your device and the 39bat platform is encrypted using 256-bit TLS (Transport Layer Security). Data at rest on our servers is encrypted using AES-256 encryption.
- Access Controls: Access to personal data is restricted to authorised 39bat personnel who require it to perform their job functions. All staff with data access are subject to confidentiality obligations and undergo regular data protection training.
- Penetration Testing: 39bat conducts regular security assessments, vulnerability scans, and penetration tests on its platform infrastructure to identify and remediate potential security weaknesses before they can be exploited.
- Incident Response: We maintain a documented data breach response procedure. In the event of a confirmed data breach that poses a risk to your personal data, we will notify affected players promptly and take all necessary remediation steps.
- Two-Factor Authentication: Players are strongly encouraged to enable two-factor authentication (2FA) on their 39bat accounts for an additional layer of login security.
While we take every reasonable precaution to protect your data, no internet-based system is completely immune to all security risks. Players are advised to use strong, unique passwords for their 39bat accounts and to never share their login credentials with anyone.
8. Your Data Rights
Subject to applicable law, you have the following rights with respect to the personal data that 39bat holds about you. You may exercise any of these rights at any time by contacting us at [email protected]:
- Right of Access: You have the right to request a copy of the personal data we hold about you, together with information about how it is processed. We will respond to access requests within 30 days.
- 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 or updated.
- Right to Erasure: In certain circumstances, you have the right to request that we delete the personal data we hold about you. This right is subject to exceptions, including where we are required to retain data by law or to defend legal claims.
- Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances — for example, while you contest the accuracy of the data or while an objection is under consideration.
- Right to Data Portability: Where processing is based on your consent or on contract performance, you have the right to receive a copy of your personal data in a structured, machine-readable format.
- Right to Object: You have the right to object to processing of your personal data where it is based on our legitimate interests, including processing for direct marketing purposes. We will honour marketing opt-out requests immediately.
- Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
To exercise any of the above rights, please send a written request to [email protected], clearly identifying yourself and specifying the right you wish to exercise. We may request proof of identity before processing your request. We will acknowledge receipt of your request promptly and respond in full within 30 days.
9. Children and Minors
The 39bat platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from anyone under the age of 21, and we do not permit minors to register an account or access any of our services.
If we become aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any winnings associated with an account found to belong to a minor will be voided.
We strongly encourage parents and guardians in Bangladesh to make use of parental control software to prevent minors from accessing online gambling services. If you believe a minor may have created a 39bat account, please contact us immediately at [email protected].
10. Third-Party Services and Links
The 39bat platform integrates with third-party game software providers — including Pragmatic Play, NetEnt, Microgaming, Habanero, Evolution Gaming, Ezugi, and Spribe — whose game engines operate within iFrames or embedded environments on our platform. When you engage with these games, certain technical session data is processed by the respective game provider under their own data protection terms.
39bat is not responsible for the privacy practices of third-party game providers, payment processors, or any other external service. We recommend that you review the privacy policies of any third-party provider with whom your data is shared as a result of using our platform.
The 39bat website does not contain links to external third-party websites for advertising or affiliate purposes. All internal navigation directs you to pages within the 39bat.io domain only.
11. International Data Transfers
39bat operates as an internationally licensed platform. As a result, certain personal data may be transferred to and processed in countries outside Bangladesh, including countries where our server infrastructure, game providers, or service partners are located.
Where personal data is transferred internationally, 39bat takes appropriate steps to ensure that the transfer is subject to adequate safeguards, including contractual data transfer agreements that require recipient parties to protect your data to a standard equivalent to that described in this Privacy Policy.
By using the 39bat platform, you acknowledge and consent to the transfer of your personal data to countries outside Bangladesh as described in this section, subject to the protections outlined above.
12. Changes to This Privacy Policy
39bat reserves the right to update or revise this Privacy Policy at any time. Changes may be made to reflect developments in our data practices, changes in applicable law, new platform features, or feedback from players and regulators.
When material changes are made to this Policy, we will notify all registered players by email to the address held on their account, and we will post a prominent notice on the 39bat homepage, at least seven (7) days before the changes take effect. The "Last Updated" date at the top of this page will always reflect the most recent revision.
Your continued use of the 39bat platform after the effective date of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree to the revised Policy, please cease using the platform and contact [email protected] to request account closure.
13. How to Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or about how 39bat handles your personal data, please do not hesitate to get in touch with our support team. We are committed to addressing all privacy-related enquiries promptly and transparently.
- Email: [email protected]
- Response Time: Typically within 1 hour; critical data protection matters resolved within 24 hours.
- Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (BST, UTC+6).
When contacting us about a data protection matter, please include your registered account username or email address, a clear description of your query or complaint, and — where applicable — the specific right you wish to exercise. This will help us handle your request as efficiently as possible.
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