Privacy Policy

At 39bat, the privacy and security of our players is a responsibility we take seriously. This Privacy Policy explains in clear terms what personal information we collect from players based in Bangladesh and across South Asia, why we collect it, how we use it, and the rights you hold regarding your own data. By using the 39bat platform — including our website, mobile experience, sports betting, live casino, slots, crash games, and any other services we offer — you agree to the practices described in this document.

We are committed to transparency. We will never sell your personal data to third parties for their own marketing purposes. Any data sharing that does occur is strictly limited to what is necessary to deliver our services, comply with applicable regulations, and maintain the safety and integrity of the 39bat platform for all players.

1. Information We Collect

To deliver a personalised, secure, and compliant gaming and betting experience, 39bat collects certain categories of personal information. The specific data collected depends on the services you access and your level of engagement with the platform. Categories of information we may collect include:

• Identity information: full name, date of birth, gender, and government-issued identification documents required for account verification (KYC).
• Contact information: email address, mobile phone number, and residential address (including city — e.g. Dhaka, Chittagong, Sylhet, Khulna, or Rajshahi).
• Financial information: transaction history, deposit and withdrawal records, payment method details (e.g. bKash wallet number, Nagad account, Rocket mobile banking reference) strictly for processing payments.
• Technical data: IP address, device type, browser type and version, operating system, session timestamps, and clickstream data collected automatically when you visit 39bat.
• Behavioural data: game preferences, betting history, session durations, bonus usage patterns, and responsible gaming interaction logs used to personalise your experience and detect problem gambling indicators.

2. How We Use Your Information

39bat uses the personal information we collect solely for legitimate purposes that are necessary to operate our platform and serve our players responsibly. We do not use your data for purposes beyond what is described here without obtaining your explicit consent. Primary uses of your data include:

• Account creation, verification, and management: processing your registration, confirming your identity through KYC procedures, and maintaining your account in good standing.
• Payment processing: facilitating secure deposits and withdrawals through supported channels including bKash, Nagad, Rocket, Upay, and bank transfer options available to Bangladeshi players.
• Customer support: responding to queries, resolving disputes, and providing assistance in English and Bengali through our 24/7 support channel.
• Fraud prevention and platform integrity: monitoring activity for signs of fraudulent behaviour, money laundering, underage gambling, or violation of our Terms & Conditions to keep 39bat safe for all players.

3. Legal Basis for Processing

39bat processes your personal data on the following legal grounds: (a) Contractual necessity — processing required to fulfil our obligations to you under the user agreement you accepted when registering; (b) Legitimate interests — processing for fraud detection, platform security, and service improvement that does not override your fundamental privacy rights; (c) Legal compliance — processing required by applicable regulations, including anti-money laundering obligations and age-verification requirements; and (d) Consent — where you have voluntarily provided your data or opted into specific communications, you may withdraw that consent at any time by contacting us.

We are committed to ensuring that our data processing is proportionate, transparent, and always in line with your reasonable expectations as a player on our platform.

4. Cookies and Tracking Technologies

39bat uses cookies and similar tracking technologies to operate essential site functions, remember your preferences, analyse platform usage, and deliver a more personalised experience. Cookies are small text files placed on your device when you visit our site. The types of cookies we use include:

• Essential cookies: required for the core functionality of the 39bat platform, including login sessions, cart/bet states, and security tokens. These cannot be disabled without breaking the service.
• Analytics cookies: help us understand how players navigate 39bat — which pages are visited most, where sessions begin and end, and how features are used — so we can continuously improve the platform.
• Preference cookies: store your language selection (English or Bengali), display settings, and other personalisation options so your experience is consistent across sessions.

5. Data Sharing and Third Parties

39bat does not sell, rent, or trade your personal information to third parties. We may, however, share limited and necessary data with trusted service providers and partners who assist us in operating the platform. All such parties are bound by strict confidentiality obligations and are only permitted to use your data for the specific purposes we outline. Scenarios where limited data sharing may occur include:

• Payment processors: to facilitate transactions via bKash, Nagad, Rocket, Upay, Visa, and Mastercard, we share only the transactional data necessary for settlement and fraud prevention.
• Game providers: game studios such as Pragmatic Play, Evolution Gaming, Spribe, Ezugi, NetEnt, and Microgaming may receive anonymised session data necessary to deliver their games and enforce fair-play standards.
• Legal and regulatory authorities: where we are required by applicable law or regulatory directive, 39bat may disclose your information to relevant authorities. We will always comply with valid legal process while protecting your rights to the fullest extent possible.
• Technology infrastructure partners: hosting, content delivery, and cybersecurity partners who may process data on our behalf under strict data processing agreements that mirror our privacy commitments.

6. Data Retention

39bat retains personal data only for as long as it is necessary for the purposes set out in this Privacy Policy, or as required by applicable law. In practice, account data is retained for the duration of your active account plus a minimum period following account closure to satisfy anti-money laundering regulations and resolve any outstanding disputes. Transaction records are kept for a period required under financial compliance obligations. Anonymised or aggregated data derived from your activity may be retained indefinitely for statistical and analytical purposes, as it can no longer be linked to you as an individual.

When data is no longer required to be retained, 39bat takes appropriate technical and organisational measures to securely delete, destroy, or anonymise it so that it cannot be recovered or reconstructed in a form that identifies you.

7. Security of Your Data

Protecting your personal data against unauthorised access, loss, or misuse is a core operational priority at 39bat. We have implemented a range of technical and organisational security measures appropriate to the nature of the data we process, including:

• SSL/TLS encryption on all data transmissions between your device and our servers, ensuring your credentials, financial data, and personal details are protected in transit.
• Access controls and role-based permissions that restrict internal access to personal data to only those employees and contractors with a legitimate operational need.
• Secure and encrypted storage of sensitive data including passwords (stored as salted cryptographic hashes, never in plain text) and payment reference numbers.
• Ongoing monitoring for suspicious activity, automated fraud detection systems, and regular security audits to identify and remediate vulnerabilities before they can be exploited.

8. Children and Minors

39bat is strictly an adults-only platform. Our services are not directed at, and must not be used by, any individual under the age of 21. We do not knowingly collect personal information from anyone under 21 years of age. If we become aware that a minor has created an account or provided personal data to us, we will immediately suspend the account, delete the data, and take appropriate steps to prevent recurrence.

Parents and guardians who believe their child may have accessed 39bat or provided personal information to us are strongly encouraged to contact our support team immediately at [email protected] so we can act swiftly.

9. Your Rights Over Your Data

As a player on the 39bat platform, you hold meaningful rights over your personal data. We are committed to honouring these rights promptly and without undue restriction. Your rights include:

• Right of access: you may request a copy of all personal data 39bat holds about you, along with information about how it is used and with whom it has been shared.
• Right to rectification: if any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
• Right to erasure: in certain circumstances you may request that 39bat delete your personal data — for example, where the data is no longer necessary for the purpose it was collected, or where you withdraw consent that was the sole legal basis for processing.
• Right to object: you have the right to object to processing of your personal data for direct marketing purposes or where we rely on legitimate interests as the legal basis, unless we can demonstrate compelling grounds that override your interests.

To exercise any of the above rights, please contact our support team in writing at [email protected]. We will respond to all valid requests within a reasonable timeframe. Note that certain rights may be limited where retention of your data is required by law or is necessary to protect the rights of others.

10. International Data Transfers

39bat's primary operations and player base are centred in Bangladesh. In certain circumstances, data we collect may be transferred to, stored, or processed in locations outside of Bangladesh — for example, by a cloud hosting provider or a game studio whose servers operate in another jurisdiction. Where such transfers occur, 39bat takes steps to ensure an appropriate level of protection is applied to your data, equivalent to the standards described in this Privacy Policy, by using contractual safeguards and working only with providers that meet our data security requirements.

By using 39bat, you acknowledge that your data may be transferred internationally in the manner described above, subject always to the protections outlined in this Privacy Policy.

11. Changes to This Privacy Policy

39bat reserves the right to update or amend this Privacy Policy at any time to reflect changes in our services, technology, legal requirements, or business practices. When we make material changes to this policy, we will update the 'Last Updated' date at the top of this page. We encourage all players to review this page periodically to stay informed about how we protect your data. Your continued use of the 39bat platform after any changes have been posted constitutes your acceptance of the revised Privacy Policy.

We will not reduce your rights under this Privacy Policy without your explicit consent. If changes are significant, we may notify active players via email or an on-platform notification.

12. Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 39bat handles your personal data, please contact our support team. We are available 24 hours a day, 7 days a week, in both English and Bengali, and we aim to respond to all privacy-related correspondence within 5 business days. You can reach us at [email protected]. Please do not send sensitive personal documents (such as identity cards or passport scans) via unencrypted email — our support team will guide you through a secure submission process if document upload is required for verification purposes.