Your Privacy Matters
to 399bd

01Introduction

This Privacy Policy ("Policy") is issued by 399bd, the operator of the online betting and gaming platform accessible at https://399bd.im (the "Platform"). It describes how 399bd collects, uses, stores, and discloses personal data relating to registered users and visitors ("you", "your") of the 399bd Platform.

By registering a 399bd account, accessing the Platform, or otherwise providing personal information to 399bd, you confirm that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not register an account or continue using the 399bd Platform.

This Policy should be read alongside the 399bd Terms & Conditions, which govern your overall use of the Platform. Capitalised terms used in this Policy that are not defined herein have the meanings given to them in the Terms & Conditions.

02Data We Collect

399bd collects the following categories of personal data in the course of operating the Platform and providing services to registered players:

399bd does not intentionally collect special categories of sensitive personal data (such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health data). If you voluntarily disclose such information in a support communication, it will be treated with the highest level of confidentiality and will not be used for any purpose other than addressing your specific query.

03How We Collect Your Data

399bd collects personal data through the following channels and mechanisms:

• Direct submission: Data you provide when registering a 399bd account, completing identity verification, initiating a deposit or withdrawal, contacting customer support, or responding to a promotion.
• Automated collection: Technical and usage data collected automatically when you access the Platform, including via cookies, server logs, and session tracking technologies. See Section 07 (Cookies & Tracking) for full details.
• Third-party payment processors: When you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, the payment provider may share transaction confirmation data and wallet identifiers with 399bd solely for the purpose of completing the transaction and conducting AML checks.
• Identity verification providers: Where you submit identity documents for KYC verification, 399bd may use a third-party identity verification service to confirm authenticity. The verification provider shares only the outcome of the check (verified / not verified) and any required regulatory data with 399bd.
• Fraud and risk detection partners: 399bd may receive data from third-party fraud prevention services that flag suspicious IP addresses, device fingerprints, or behavioural patterns associated with fraudulent activity on online gaming platforms.

04How We Use Your Data

399bd uses your personal data only for the purposes identified at the time of collection and as described in this Policy. The primary purposes for which your data is used are set out below:

• Account creation and management: To register your 399bd account, maintain your account settings, and provide you with access to all Platform features.
• Identity and age verification: To confirm that you meet the minimum age requirement of 21 years and to verify your identity in compliance with our Know Your Customer (KYC) obligations.
• Payment processing: To process deposits and withdrawals via your chosen payment method (bKash, Nagad, Rocket, Upay, Visa, Mastercard) and to maintain accurate financial records.
• Platform security and fraud prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, multiple account registrations, and bonus abuse.
• Customer support: To respond to your queries, complaints, and disputes in a timely and effective manner.
• Legal and regulatory compliance: To meet our obligations under applicable anti-money laundering (AML), counter-terrorist financing (CTF), and data protection requirements, including responding to lawful requests from regulatory authorities.
• Responsible gaming: To monitor your gaming behaviour for indicators of problem gambling and to apply responsible gaming tools such as deposit limits, session time-outs, and self-exclusion where appropriate or requested.
• Platform improvement: To analyse aggregated and anonymised usage data to improve Platform functionality, game offerings, and the overall player experience.
• Marketing communications: To send you promotional offers, bonus notifications, and updates about 399bd services — but only where you have provided express consent to receive such communications. You may opt out at any time by contacting [email protected].

05Legal Basis for Processing

399bd processes your personal data on the following legal bases, depending on the specific purpose of the processing:

• Contractual necessity: Processing required to perform the contract between you and 399bd — including account registration, payment processing, bet settlement, and customer support.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML/CTF obligations, age verification requirements, and responses to lawful authority requests.
• Legitimate interests: Processing necessary for 399bd's legitimate business interests, including fraud prevention, Platform security, responsible gaming monitoring, and anonymised analytics — provided that such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — in particular, the sending of direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

06Data Sharing & Disclosure

399bd does not sell, rent, or trade your personal data. Your data may be shared with the following categories of third parties only where strictly necessary and for the purposes described in this Policy:

• Payment service providers: bKash, Nagad, Rocket, Upay, Visa, and Mastercard processing partners receive only the data required to complete your transaction (e.g., wallet identifier, transaction amount). These providers operate under their own privacy policies and are contractually bound to protect your data.
• Identity verification providers: Third-party KYC partners receive your identity documents and personal details for the sole purpose of verifying your identity and age. Verification results are returned to 399bd in a structured, minimal format.
• Game studios and software providers: Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, Spribe, and other certified game providers may receive anonymised session data necessary to operate their games within the 399bd Platform environment. No personally identifiable data beyond a session token is shared with game providers.
• Fraud prevention services: 399bd may share device fingerprint data, IP address information, and anonymised behavioural signals with fraud detection partners to identify and prevent fraudulent activity on the Platform.
• Regulatory and law enforcement authorities: 399bd will disclose personal data to competent authorities where required to do so by law, court order, or other binding legal process. 399bd will, where legally permissible, notify affected users of such disclosure.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 399bd's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it.

All third-party data processors engaged by 399bd are subject to contractual data processing agreements that require them to protect your personal data in accordance with standards no less stringent than those applied by 399bd itself.

07Cookies & Tracking Technologies

399bd uses cookies and similar tracking technologies to operate the Platform, maintain your session, and collect anonymised analytics. Cookies are small text files stored on your device by your browser when you visit the Platform. The following categories of cookies are used by 399bd:

• Essential cookies: These cookies are strictly necessary for the Platform to function. They enable you to log in, maintain your session, navigate between pages, and use core features such as the betting interface and account settings. Essential cookies cannot be disabled without significantly impairing Platform functionality.
• Analytics cookies: 399bd uses anonymised, first-party analytics cookies to understand how players use the Platform — including which pages are visited most frequently, which games are most popular, and where users encounter difficulties. This data is used solely to improve the Platform and is not linked to individually identifiable users.
• Security cookies: These cookies support 399bd's fraud detection and session security systems, helping to identify suspicious activity and protect your account from unauthorised access.
• Preference cookies: These cookies remember your in-Platform settings, such as your preferred language, display preferences, and responsible gaming limit configurations, so that you do not need to re-enter them on each visit.

399bd does not use third-party advertising cookies, retargeting pixels, or any cross-site tracking mechanism. You can manage or delete cookies through your browser settings at any time. Please note that disabling essential cookies may prevent some Platform features from functioning correctly.

08Data Retention

399bd retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of each transaction, in line with standard financial record-keeping obligations.
• Support and communication records: Retained for three (3) years from the date of the last communication, to support dispute resolution and quality assurance purposes.
• Technical and usage data: Anonymised and aggregated after thirteen (13) months from collection. Raw technical log data is deleted after ninety (90) days unless it is required in connection with an active security investigation.
• Self-excluded player data: Where a player has registered a self-exclusion, identifying data is retained throughout the self-exclusion period and for a minimum of five (5) years thereafter to prevent inadvertent re-registration.

On expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that makes re-identification impossible. If you request deletion of your data before the end of an applicable retention period, 399bd will inform you of the minimum period for which your data must be retained and the legal basis for doing so.

09Data Security

399bd implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 399bd Platform.
• AES-256 encryption for sensitive personal data stored in 399bd databases, including identity documents and financial identifiers.
• Multi-factor authentication (MFA) and OTP device verification for account login sessions.
• Role-based access controls ensuring that 399bd staff can access personal data only to the extent required to perform their specific job functions.
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified security professionals.
• Intrusion detection systems and real-time monitoring of Platform infrastructure for anomalous activity.
• Formal incident response procedures that include prompt notification to affected users in the event of a data breach that is likely to result in a risk to their rights and freedoms.

10Your Rights

Subject to applicable law and certain conditions, you have the following rights in relation to the personal data that 399bd holds about you:

• Right of access: You have the right to request a copy of the personal data that 399bd holds about you, together with information about how it is used and with whom it is shared.
• Right to rectification: You have the right to request that inaccurate or incomplete personal data held by 399bd be corrected or completed without undue delay.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing was unlawful. This right is subject to 399bd's legal data retention obligations.
• Right to restriction: You have the right to request that 399bd restrict the processing of your personal data in certain circumstances, for example while a rectification request is being assessed.
• Right to data portability: Where processing is based on your consent or on a contractual necessity, you have the right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing of your personal data where that processing is based on 399bd's legitimate interests, including profiling for responsible gaming purposes.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to human review: Where an automated decision has a significant effect on your account, you have the right to request that the decision be reviewed by a human member of the 399bd team.

To exercise any of the above rights, please contact the 399bd support team at [email protected] with the subject line "Data Rights Request". 399bd will acknowledge your request within 72 hours and aim to fulfil it within 30 days. In complex cases, this period may be extended by a further 60 days, in which case you will be informed of the extension and the reason for it.

11Children & Minors

The 399bd Platform is strictly for adults aged 21 years and above. 399bd does not knowingly collect personal data from any person under the age of 21. If 399bd becomes aware that personal data has been collected from a person under 21, the account will be closed immediately, all associated data will be deleted, and any funds deposited will be returned in accordance with 399bd's underage gambling policy.

If you are a parent or guardian and believe that a minor in your care has registered a 399bd account or provided personal data to 399bd, please contact [email protected] immediately. 399bd will investigate all such reports as a matter of urgent priority.

12International Data Transfers

399bd primarily serves players located in Bangladesh. However, some of the third-party service providers engaged by 399bd — including game studio infrastructure providers, identity verification partners, and fraud detection services — may process data on servers located outside Bangladesh. Where such international transfers occur, 399bd ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual data processing agreements incorporating internationally recognised data protection clauses.
• Transfers only to service providers operating in jurisdictions with recognised data protection standards or subject to equivalent contractual protections.
• Minimisation of transferred data to only what is strictly necessary for the specific service being provided.

You may request further information about the international transfers that affect your data and the safeguards in place by contacting [email protected].

13Third-Party Links

The 399bd Platform may contain references to third-party services, such as payment method providers ( bKash, Nagad, Rocket, Upay) and game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi). These third-party services operate under their own independent privacy policies and terms of service. 399bd has no control over and accepts no responsibility for the data practices of these third parties. We strongly encourage you to review the privacy policy of any third-party service before providing personal data to it.

This Privacy Policy applies solely to the 399bd Platform at https://399bd.im and does not extend to any third-party websites, services, or platforms that may be referenced in connection with the 399bd service.

14Policy Updates

399bd reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable legal obligations. When material changes are made to this Policy, 399bd will notify registered users via email or via a prominent notice on the Platform at least fourteen (14) days before the revised Policy takes effect.

The "Last Reviewed" date shown at the top of this Policy and in the Table of Contents indicates when the most recent version was published. Your continued use of the 399bd Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and may request closure of your account by contacting [email protected].

We recommend that you review this Privacy Policy periodically to stay informed about how 399bd protects your personal data. Archived versions of previous Privacy Policy documents are available on request.

15Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 399bd handles your personal data, please contact the 399bd Data Protection team using the details below. All privacy-related enquiries are handled with the utmost confidentiality and will receive a substantive response within 72 hours.

When submitting a data rights request, please include your registered email address or username so that 399bd can locate your account records. For identity verification purposes, 399bd may ask you to confirm additional account details before processing certain data rights requests, particularly requests for access to or deletion of personal data.

399bd is committed to resolving all privacy concerns directly and promptly. If you feel that your concern has not been adequately addressed after contacting our support team, you retain the right to escalate your complaint to any applicable supervisory authority or data protection regulator in your jurisdiction.