39999 Privacy Policy

1. Introduction

39999 is an online sports betting and casino platform serving players in Bangladesh. We are committed to protecting the privacy and security of all personal information entrusted to us by our players and website visitors. This Privacy Policy sets out in plain, transparent terms exactly what personal data 39999 collects, the purposes for which that data is used, the circumstances in which it may be disclosed to third parties, and the rights that you hold in relation to your own data.

This policy applies to all personal data collected through the 39999 website at https://39999.biz, through any associated mobile-optimised pages, and through any direct communications between you and the 39999 support team (for example, via email or live chat). It does not apply to third-party websites that may be linked from our platform — those sites operate under their own separate privacy policies.

39999 takes data protection seriously. We apply technical and organisational security measures that are proportionate to the risks associated with the processing of your personal data. We also aim to collect only the minimum data necessary to provide you with a safe, enjoyable, and legally compliant gaming experience.

2. Data Controller

For the purposes of this Privacy Policy, 39999 acts as the data controller in respect of all personal data collected through the 39999 platform. This means that 39999 determines the purposes and means by which your personal data is processed.

If you have any questions about how 39999 handles your personal data, or if you wish to exercise any of your data rights as described in Section 10, you may contact our data protection team at the address provided in Section 14 of this policy.

3. Data We Collect

39999 collects the following categories of personal data:

3.1 Registration Data

When you create a 39999 account, we collect the information you provide during registration, which typically includes: your full legal name, date of birth, residential address, email address, and mobile phone number. This data is required to establish your identity and verify that you meet the minimum age requirement of 18 years.

3.2 Identity Verification (KYC) Data

In accordance with our Know Your Customer obligations, we may request copies of government-issued identity documents such as a National Identity Card (NID), passport, or driving licence. We may also request proof of address (for example, a utility bill or bank statement) and, in some cases, proof of source of funds. This data is processed solely for the purpose of verifying your identity and complying with applicable anti-money-laundering obligations.

3.3 Financial and Payment Data

When you make a deposit or request a withdrawal, 39999 collects the information needed to process that transaction. For mobile financial services such as bKash, Nagad, Rocket, and Upay, this includes your registered mobile number and transaction reference. For bank transfers, it includes your bank account name, account number, and bank name. 39999 does not store full payment card numbers; any card details are tokenised and handled by our payment service providers.

3.4 Transaction and Betting History

39999 maintains a record of all deposits, withdrawals, bets placed, casino game rounds played, and bonuses credited to or debited from your account. This data is used for account management, dispute resolution, fraud detection, and regulatory compliance purposes.

3.5 Technical and Device Data

When you access the 39999 platform, our servers automatically collect certain technical data, including: your IP address, browser type and version, operating system, device type, time zone, and the pages or features you access. This data is used to maintain platform security, detect fraudulent access, and improve the performance of our services.

3.6 Communications Data

If you contact 39999 customer support — whether by email, live chat, or any other communication channel — we retain a record of that correspondence, including any attachments you provide. This data is used to resolve your enquiry and to improve our support quality over time.

3.7 Marketing Preferences

If you have opted in to receive promotional communications from 39999, we hold a record of that consent. We may also collect data about how you interact with marketing emails we send (for example, whether you open an email or click a link), in order to measure the effectiveness of our campaigns.

4. How We Use Your Data

39999 uses the personal data we collect for the following purposes:

Purpose	Data Categories Used
Creating and managing your player account	Registration data, KYC data
Processing deposits and withdrawals	Financial and payment data, registration data
Verifying your age and identity (KYC)	KYC data, registration data
Detecting and preventing fraud and money laundering	All categories, including technical and transaction data
Providing customer support	Registration data, communications data, transaction history
Sending account notifications and service updates	Registration data, marketing preferences
Sending promotional offers (where consent given)	Registration data, marketing preferences, betting history
Improving platform performance and user experience	Technical and device data, transaction history
Complying with legal and regulatory obligations	All categories as required by law
Responsible gaming monitoring and intervention	Transaction history, betting history, registration data

5. Legal Basis for Processing

39999 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing that is required to fulfil our contractual obligations to you as a registered player — for example, processing your deposits, settling your bets, and maintaining your account.
• Legal obligation: Processing that is required by applicable law — for example, retaining transaction records for anti-money-laundering compliance or conducting KYC verification.
• Legitimate interests: Processing that is necessary for the legitimate interests of 39999 and does not unduly prejudice your rights — for example, fraud detection, platform security, and improving our services.
• Consent: Processing that is based on your freely given, specific, and informed consent — for example, sending you promotional emails or push notifications about offers and bonuses. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing

39999 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of trusted third-party service providers, strictly for the purposes described:

• Payment service providers: bKash, Nagad, Rocket, Upay, and local bank partners receive the minimum payment data necessary to process your transactions. These providers are bound by their own data protection obligations.
• Identity verification providers: Third-party KYC and age verification services may receive copies of your identity documents to conduct verification checks on our behalf.
• Fraud prevention and security services: IP intelligence and fraud risk scoring providers may receive technical and transaction data to help us identify and prevent fraudulent activity.
• Game content providers: Studio partners including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive session tokens necessary to serve their game content within the 39999 platform. These studios operate under their own data processing agreements and are not granted access to your personal registration details.
• Legal and regulatory authorities: 39999 may disclose personal data to law enforcement agencies, courts, or regulatory bodies where we are legally required to do so, or where disclosure is necessary to protect the rights and safety of 39999, our players, or the public.

All third-party service providers who process personal data on behalf of 39999 are required to handle that data securely and only in accordance with 39999's instructions and applicable data protection obligations.

7. Cookies and Tracking Technologies

39999 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the platform, remember your preferences, and gather analytics data. The categories of cookies we use are as follows:

• Strictly necessary cookies: These cookies are essential for the 39999 platform to function. They enable core features such as session authentication, security token validation, and load balancing. The platform cannot operate without these cookies and they cannot be disabled.
• Performance and analytics cookies: These cookies collect anonymised or pseudonymised information about how players use the 39999 platform — for example, which pages are visited most frequently, how long players spend on each section, and where technical errors occur. This data is used to improve the platform.
• Functionality cookies: These cookies remember choices you make on the platform — such as your preferred language — to provide a more personalised experience during your session.
• Marketing and targeting cookies: Where you have given consent, these cookies are used to track your activity across the 39999 platform in order to deliver more relevant promotional content and measure the effectiveness of our campaigns.

You can control and delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 39999 platform. For detailed instructions on managing cookies, refer to your browser's help documentation.

8. Data Retention

39999 retains personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. Our general retention principles are as follows:

• Active account data: Personal data associated with an active player account is retained for the lifetime of the account plus a minimum of five years after account closure, to meet anti-money-laundering and regulatory record-keeping requirements.
• Transaction and betting records: All financial transaction records and bet settlement records are retained for a minimum of five years from the date of the transaction, in line with standard financial record-keeping obligations.
• KYC documents: Identity verification documents are retained for the same period as the associated account records and are deleted securely once the retention period has expired.
• Customer support communications: Records of support interactions are retained for up to three years from the date of the final communication in a given support thread.
• Technical and device logs: Server access logs and device data are typically retained for up to 12 months unless a longer period is required for ongoing security investigation purposes.
• Marketing data: If you withdraw consent to marketing communications, your marketing preferences data is updated immediately and promotional communications will cease within a reasonable period, not exceeding 72 hours.

When personal data is no longer required and the applicable retention period has expired, 39999 will securely delete or anonymise that data so that it can no longer be linked to an identifiable individual.

9. Security Measures

39999 implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your browser or device and the 39999 platform.
• Encryption at rest for databases storing sensitive personal and financial data.
• Role-based access controls that restrict employee access to personal data on a strict need-to-know basis.
• Two-factor authentication requirements for all internal staff accessing production data systems.
• Regular penetration testing and vulnerability scanning of the 39999 platform infrastructure.
• Formal incident response procedures to detect, contain, and remediate data security incidents promptly.

Despite these measures, no internet-based platform can guarantee absolute security against all possible threats. Players are encouraged to use strong, unique passwords for their 39999 accounts and to enable any available two-factor authentication features.

10. Your Rights

As a data subject, you hold a number of rights in relation to the personal data that 39999 holds about you. These rights include:

• Right of access: You have the right to request a copy of the personal data that 39999 holds about you. We will provide this information within a reasonable timeframe upon receipt of a valid request.
• 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. You may update certain account information directly within your account settings, or by contacting support.
• Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data. This right is subject to limitations — for example, 39999 is required by law to retain certain financial and KYC records for a minimum period and cannot delete these upon request before that period expires.
• Right to restrict processing: You have the right to request that 39999 restrict the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved.
• Right to data portability: Where processing is based on your consent or on a contract with you, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: You have the right to object to processing of your personal data that is based on 39999's legitimate interests. You also have an unconditional right to object to processing of your data for direct marketing purposes at any time.
• 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 39999 customer support at [email protected]. We will respond to all valid requests as promptly as possible. We may need to verify your identity before processing a data rights request to prevent unauthorised disclosure.

11. Minors

The 39999 platform is strictly intended for adults aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. If you are a parent or guardian and believe that a minor has registered an account or provided personal data to 39999, please contact us immediately at [email protected]. We will investigate and, if confirmed, immediately suspend the account, delete any associated personal data to the extent permitted by law, and return any eligible funds in accordance with our standard procedures.

39999 employs age verification controls during the registration process and conducts KYC checks that include verification of date of birth. Any account identified as belonging to a minor will be terminated without notice and any winnings accumulated will be forfeited.

12. International Data Transfers

In the course of operating the 39999 platform, your personal data may be transferred to and processed in countries other than Bangladesh. This may occur, for example, where a game content provider's servers or a payment processing partner's infrastructure is located outside Bangladesh.

Where such transfers occur, 39999 takes steps to ensure that appropriate safeguards are in place to protect your personal data in transit and at rest in the recipient jurisdiction. These safeguards may include contractual data protection clauses with the relevant third-party service provider, or reliance on the data protection laws and certification frameworks applicable in the destination country.

13. Changes to This Privacy Policy

39999 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, changes in applicable law, or improvements to the 39999 platform. The most current version of this Privacy Policy will always be published at https://39999.biz/privacy-policy, with the effective date of the most recent revision clearly stated at the top of the document.

Where changes to this Privacy Policy are material — meaning they significantly affect how we use your data or the rights available to you — 39999 will endeavour to notify registered players by email at the address associated with their account, or via a prominent notice on the platform, in advance of the changes taking effect. Your continued use of the 39999 platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms.

14. Contact Us

If you have any questions, concerns, or complaints relating to this Privacy Policy, or if you wish to exercise any of your data rights as described in Section 10, please contact the 39999 data protection team. We are committed to resolving all privacy-related enquiries promptly and transparently.

For responsible gaming concerns, please also visit our dedicated Responsible Gaming page, which provides guidance on self-exclusion tools, deposit limits, and external support resources available to players in Bangladesh.

For general account or betting enquiries, our customer support team is available around the clock via the contact information above. Please reference "Privacy Request" in the subject line of any data rights enquiry to ensure it is routed to the correct team promptly.