39ok Privacy Policy
How We Collect, Use & Protect Your Data

This Privacy Policy ("Policy") describes how 39ok ("39ok", "we", "us", "our") collects, processes, stores, and protects personal data relating to individuals ("you", "your", "Player", "User") who access or use the 39ok platform at https://39ok.io, including all betting, casino, and account-related services offered therein.

39ok is committed to handling your personal information responsibly, transparently, and in a manner consistent with widely recognised data protection principles. This Policy applies to all players, registered account holders, and visitors to the 39ok website, regardless of whether you hold an active account with us.

This Policy should be read alongside our Terms and Conditions and our Responsible Gaming Policy, each of which forms part of the overall agreement between you and 39ok. By using the 39ok platform, you acknowledge that you have read and understood the data practices described in this Policy.

39ok collects personal data in the following categories. We collect only what is necessary and proportionate to the purposes described in this Policy.

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information unless required by law or expressly consented to by you for a specific purpose.

39ok collects personal data through the following channels:

Direct Collection

Data you provide directly to us when registering an account, completing KYC verification, making a deposit or withdrawal, submitting a support request, or communicating with our team via email or live chat.

Automated Collection

Data collected automatically when you access the 39ok platform, including technical and usage data captured through server logs, cookies, pixel tags, and similar tracking technologies. This data is collected each time you visit the site, whether or not you are logged in to an account.

Third-Party Sources

In certain circumstances, 39ok may receive data about you from trusted third parties, including:

• Payment service providers (bKash, Nagad, Rocket, Upay, Visa, Mastercard, Dutch-Bangla Bank) who confirm the status and ownership of payment methods used for deposits and withdrawals.
• Identity verification and KYC service providers who assist in confirming the authenticity of identity documents.
• Fraud detection services that flag suspicious account or payment activity for review.
• Analytics partners who provide aggregated, anonymised data about platform performance and user behaviour patterns.

39ok uses the personal data it collects for the following specific purposes:

• Account Creation and Management: To register your account, verify your identity, maintain your player profile, and provide access to all platform features.
• Payment Processing: To process deposits and withdrawals in BDT via your chosen payment method, and to maintain accurate transaction records.
• Identity and Age Verification (KYC): To confirm that you are aged 21 or above and that the personal information you have provided is accurate, as required before withdrawal processing.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct as defined in our Terms and Conditions.
• Responsible Gaming Compliance: To monitor betting patterns for indicators of problem gambling, to apply account restrictions where requested, and to honour self-exclusion requests in accordance with our Responsible Gaming Policy.
• Customer Support: To respond to your support queries, resolve disputes, and maintain a record of communications for quality and training purposes.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the overall quality, performance, and user experience of the 39ok platform.
• Legal and Regulatory Compliance: To comply with applicable legal obligations, including responding to lawful requests from law enforcement or regulatory authorities.
• Marketing Communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and platform updates via email or SMS. You may withdraw this consent at any time.

39ok processes your personal data on one or more of the following legal grounds, depending on the specific purpose of processing:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms and Conditions you agreed to at registration — including account management, payment processing, and service delivery.
• Legal Obligation: Processing necessary to comply with applicable laws, including anti-money laundering (AML) regulations, age verification requirements, and responses to lawful authority requests.
• Legitimate Interests: Processing carried out to pursue 39ok's legitimate business interests — including fraud prevention, platform security, responsible gaming monitoring, and improving our services — where those interests are not overridden by your privacy rights.
• Consent: Processing based on your explicit, freely given consent — specifically for optional marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

39ok does not sell, rent, or trade your personal data. We share your information only in the circumstances listed below and only to the minimum extent necessary for the stated purpose.

Service Providers and Data Processors

We share personal data with third-party service providers who process data on our behalf under strict contractual data processing agreements. These include:

• Payment processors — bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, Mastercard — for the purpose of processing your financial transactions.
• KYC and identity verification providers who verify the authenticity of documents submitted during the verification process.
• Fraud detection and security analytics providers who help identify and prevent prohibited activity on the platform.
• Game content providers — including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi — who may receive limited technical session data necessary for delivering their game content to your device.
• Cloud hosting and IT infrastructure providers who provide the secure server environments in which 39ok data is stored and processed.
• Email and SMS communication platforms used to deliver transactional and (where consented) marketing messages.

Legal Disclosures

39ok may disclose your personal data to law enforcement agencies, regulatory bodies, courts, or other governmental authorities where required or permitted by law, including in connection with investigations into fraud, money laundering, or other criminal activity.

39ok uses cookies and similar tracking technologies (including pixel tags and session tokens) to operate the platform, remember your preferences, maintain your login session, and gather analytical data about how the platform is used.

Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your preferences such as preferred language, display settings, and previously selected payment methods, to provide a more personalised experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how visitors interact with the platform — including pages visited, time spent, and navigation paths — to help us improve the platform's performance and user experience.
• Marketing Cookies: Used where you have consented to receive targeted promotional content. These cookies track your activity on the platform to enable relevant and timely promotional communications.

You may manage your cookie preferences through your browser settings at any time. Disabling non-essential cookies will not prevent you from using the core features of the 39ok platform, though some personalisation features may be reduced.

39ok retains personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable legal and regulatory obligations. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of 5 years following account closure, to comply with anti-money laundering record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in accordance with financial record-keeping obligations.
• KYC Verification Documents: Retained for the duration of your account plus 5 years following closure. Documents are stored securely and access is restricted to authorised personnel only.
• Support and Communications Data: Retained for 3 years from the date of the last communication, to support dispute resolution and quality assurance purposes.
• Technical and Usage Data: Retained in identifiable form for up to 24 months. Older data is anonymised for long-term analytical purposes.
• Marketing Consent Records: Retained for as long as you hold an account with 39ok plus 3 years, as evidence of consent or withdrawal of consent.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data may be retained indefinitely for statistical and research purposes, as it can no longer be used to identify any individual.

39ok implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure.

Technical Measures

• All data in transit between your device and 39ok servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Stored personal data and financial records are encrypted at rest using AES-256 encryption.
• Account passwords are stored using a one-way cryptographic hashing function — 39ok staff cannot read or retrieve your password in plain text.
• Access to systems containing personal data is restricted to authorised personnel only, controlled through role-based access management and multi-factor authentication.
• Platform infrastructure is monitored continuously for intrusion attempts, anomalous activity, and vulnerability exposure.

Organisational Measures

• All 39ok staff with access to personal data are trained on data protection obligations and bound by confidentiality agreements.
• Third-party service providers are evaluated for data security compliance before engagement and are bound by contractual data processing obligations.
• An internal incident response procedure is maintained to ensure prompt detection, containment, and notification of any security breach affecting personal data.

As a player whose personal data is processed by 39ok, you hold the following rights with respect to your personal information. To exercise any of these rights, contact our support team at [email protected]. We will respond to all verified requests within a reasonable timeframe and without undue delay.

The 39ok platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from any individual under the age of 21. If you are under 21, you are not permitted to register an account, access the platform, or use any of its services.

If 39ok becomes aware that personal data has been collected from an individual under the age of 21 — whether through a misrepresentation of age at registration or by any other means — we will take immediate steps to suspend the relevant account, void any associated activity, and permanently delete all personal data associated with that account.

If you believe that a minor has created an account on the 39ok platform, please notify us immediately at [email protected] so that the appropriate action can be taken without delay.

With your explicit consent, 39ok may send you promotional communications by email or SMS relating to our latest offers, bonuses, game releases, seasonal promotions (such as Eid special offers, Pohela Boishakh promotions, or BPL season offers), and other platform updates.

Your consent to receive marketing communications is entirely optional and may be withdrawn at any time using any of the following methods:

• Clicking the "unsubscribe" link included in every marketing email sent by 39ok.
• Replying "STOP" to any promotional SMS received from 39ok.
• Updating your communication preferences in your account settings dashboard.
• Contacting 39ok support at [email protected] and requesting removal from all marketing lists.

Withdrawal of marketing consent will be processed within 5 business days. Please note that withdrawing marketing consent does not affect the delivery of transactional communications — such as deposit confirmations, withdrawal notifications, security alerts, and support responses — which are necessary for the operation of your account and cannot be opted out of while your account remains active.

The 39ok platform may occasionally reference third-party services — such as payment providers or game studios — by name. Where any link to a third-party website appears on the platform, please be aware that 39ok has no control over and accepts no responsibility for the privacy practices or content of those external sites. Third-party websites operate under their own privacy policies, which we encourage you to review before providing any personal information to those sites.

39ok is not responsible for any data collected by third-party websites, even where those websites are referenced in connection with services available on the 39ok platform. The inclusion of any third-party name or reference on this platform does not constitute an endorsement of that party's data practices.

39ok reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, platform services, legal obligations, or regulatory requirements. When material changes are made, we will:

• Update the "Last Updated" date shown at the top of this page and in the Table of Contents sidebar.
• Display a prominent notice on the 39ok platform informing players that the Policy has been updated.
• Send a notification email to all registered account holders with a summary of the key changes, at least 7 days before those changes take effect.

Your continued use of the 39ok platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any changes to this Policy, you should cease using the platform and may request account closure by contacting [email protected].

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 39ok processes your personal data, please contact our support team using the details below. We are committed to responding to all privacy-related enquiries promptly and thoroughly.

When contacting us regarding a data subject rights request, please include your registered account email address and a clear description of the request you are making. We may ask you to verify your identity before processing certain requests, to ensure that personal data is not disclosed to or acted upon by an unauthorised person.

39ok is committed to resolving all privacy concerns fairly and transparently. If you are not satisfied with our response to a privacy enquiry, you may have the right to escalate the matter to the appropriate data protection authority in your jurisdiction.