Your Privacy Matters — The ad33 Privacy Policy

1.1 This Privacy Policy (hereinafter "Policy") describes how ad33 (hereinafter "we", "us", or "the Platform") collects, uses, stores, shares, and protects the personal data of players and visitors who access the ad33 platform at https://ad33.io and any associated mobile-optimised URLs (collectively, "the Platform").

1.2 This Policy applies to all personal data processed in connection with the registration, use, and closure of a player account on the Platform, regardless of the device or method of access used.

1.3 By registering an account on the Platform, or by continuing to use the Platform after the effective date of this Policy, you confirm that you have read and understood this Policy and that you consent to the processing of your personal data as described herein.

1.4 This Policy should be read in conjunction with the ad33 Terms & Conditions, which are available at https://ad33.io/terms-conditions and are incorporated into the overall agreement between you and ad33 by reference.

2.1 Identity Data. When you register an account, we collect your full legal name, date of birth, and — where required for KYC verification — a copy of your national identity card, passport, or other government-issued photo identification document. This data is used solely for the purposes of age verification, fraud prevention, and regulatory compliance.

2.2 Contact Data. We collect the mobile number and, where provided, the email address associated with your account. This data is used to deliver one-time passwords (OTPs), account notifications, and support communications. We do not use contact data for unsolicited marketing communications.

2.3 Financial Data. We collect the mobile wallet reference (bKash, Nagad, Rocket, or Upay account number) associated with your deposits and withdrawals. We do not store full card numbers. Transaction amounts, timestamps, and reference codes are retained for accounting and anti-money laundering (AML) compliance purposes.

2.4 Technical Data. When you access the Platform, we automatically collect certain technical information including your IP address, device type, operating system, browser type and version, and session identifiers. This data is used to maintain platform security, detect unauthorised access, and improve platform performance.

2.5 Usage Data. We collect data about how you interact with the Platform, including pages visited, games accessed, bet history, deposit and withdrawal activity, session start and end times, and the use of responsible gaming tools. This data is used to monitor for problem gambling indicators, comply with responsible gaming obligations, and improve the platform experience.

2.6 Communications Data. When you contact our support team via live chat or email, we retain transcripts of those interactions. This data is used for dispute resolution, quality assurance, staff training, and fraud investigation where applicable.

3.1 ad33 uses the personal data described in Clause 2 for the following purposes:

• Account Registration & Management: To create and maintain your player account, verify your identity and age, and communicate important account-related updates.
• Payment Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and any other supported payment channels, and to maintain accurate transaction records.
• Security & Fraud Prevention: To detect, investigate, and prevent unauthorised access, account takeover attempts, money laundering, bonus abuse, and other fraudulent activity on the Platform.
• Regulatory Compliance: To comply with applicable legal obligations including KYC requirements, AML obligations, and any lawful requests from regulatory or law enforcement authorities.
• Responsible Gaming: To monitor player activity for signs of problem gambling, to apply player-requested limits and self-exclusions, and to provide relevant support resources where needed.
• Platform Improvement: To analyse aggregated, anonymised usage data in order to improve platform performance, game offerings, and the overall player experience.
• Customer Support: To investigate and resolve support queries, disputes, and complaints in a timely and accurate manner.

3.2 ad33 does not use personal data for automated individual decision-making that produces significant legal or similarly significant effects, except where such processing is required by law or is necessary to prevent fraud.

4.1 ad33 processes personal data only where a valid legal basis exists. The legal bases we rely upon are as follows:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you under the Terms & Conditions, including account management, payment processing, and bet settlement.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC, AML, and data retention obligations.
• Legitimate Interests: Processing carried out in pursuit of ad33's legitimate business interests — including platform security, fraud prevention, and platform improvement — where those interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent as the legal basis for processing (for example, for certain optional marketing communications), you have the right to withdraw that consent at any time by contacting support at [email protected]. Withdrawal of consent does not affect the lawfulness of any processing carried out before the withdrawal.

5.1 ad33 uses cookies and similar tracking technologies to enable core platform functionality, maintain your session state, and collect technical and usage data as described in Clause 2. Cookies are small text files placed on your device when you access the Platform.

5.2 The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without preventing core platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings and responsible gaming configurations. Disabling these cookies may affect your experience but will not prevent you from using the Platform.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform. This data is used exclusively for internal improvement purposes and is not shared with third-party advertising networks.

5.3 ad33 does not use third-party advertising or retargeting cookies. We do not permit third-party ad networks to place cookies on the Platform or to track your activity across other websites for the purpose of delivering targeted advertising.

5.4 You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to access and use the Platform.

6.1 ad33 does not sell, rent, or trade personal data to any third party for commercial purposes. Data sharing is limited to the following categories of recipients, each of whom processes data only as necessary for the specified purpose and under binding data processing agreements:

• Payment Processors: bKash, Nagad, Rocket, Upay, and any other payment service providers through which deposits and withdrawals are processed. These providers receive only the data necessary to execute the transaction.
• KYC Verification Providers: Third-party identity verification services used to confirm player age and identity. These services process identity documents under strict confidentiality obligations.
• Cloud Infrastructure Providers: The hosting and cloud services on which Platform data is stored and processed. These providers operate under ISO-certified data security standards.
• Fraud Prevention Services: Specialist providers used to detect and prevent fraudulent transactions and account activity. Data shared with these providers is limited to technical and transactional identifiers.
• Law Enforcement & Regulatory Authorities: Where required by applicable law or a lawful order, ad33 may disclose personal data to government authorities, law enforcement agencies, or regulatory bodies. We will notify affected players of such disclosure where we are legally permitted to do so.

6.2 In the event that ad33 undergoes a business restructuring, merger, or acquisition, player data may be transferred to the acquiring entity as part of that transaction. Players will be notified of any such transfer and will retain their data rights under this Policy.

7.1 ad33 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations.

7.2 The following retention periods apply as a general framework:

• Account Data (identity, contact): Retained for the duration of the account and for a minimum of 5 years following account closure, in compliance with AML and KYC obligations.
• Financial Transaction Data: Retained for a minimum of 7 years following the date of the transaction, in line with financial record-keeping requirements.
• Technical & Usage Data: Retained for up to 24 months from the date of collection, after which it is anonymised or deleted.
• Communications Data (support transcripts): Retained for 3 years from the date of the interaction, or longer where a related dispute remains unresolved.

7.3 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with our data destruction procedures.

8.1 ad33 implements technical and organisational security measures appropriate to the sensitivity of the personal data we hold. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the Platform.
• AES-256 encryption for personal and financial data stored at rest on our servers.
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent necessary for their function.
• Multi-factor authentication requirements for all administrative access to Platform systems.
• Regular independent security audits and penetration testing of Platform infrastructure.
• Automated intrusion detection and real-time monitoring for anomalous access patterns.
• Physical security controls at all data centre facilities where Platform data is hosted.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights or interests, ad33 will notify affected players without undue delay via the contact details registered to their account.

8.3 While ad33 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. Players are responsible for maintaining the security of their account credentials and for notifying us immediately of any suspected unauthorised access.

9.1 Subject to applicable legal limitations, you hold the following rights in relation to the personal data ad33 holds about you:

• Right of Access: You may 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 personal data we hold about you is inaccurate or incomplete, you may request that it be corrected. Where corrections affect your KYC status, supporting documentation may be required.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations. Deletion requests relating to data that must be retained under AML or KYC requirements will be partially fulfilled, with a full explanation provided.
• Right to Restriction: You may request that we restrict the processing of your personal data in certain circumstances, for example while the accuracy of the data is in dispute.
• Right to Data Portability: Where processing is carried out on the basis of consent or contractual necessity, you may request that we provide your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to the processing of your personal data where that processing is based on legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where we rely on consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

9.2 To exercise any of the rights listed above, please contact our support team at [email protected] with the subject line "Data Rights Request" and your registered mobile number. All requests are processed at no charge and will receive a substantive response within 30 calendar days.

10.1 The ad33 Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from any person under the age of 21. Where we discover that personal data has been collected from a person who is under 21, that data will be deleted immediately and the associated account will be permanently closed.

10.2 Parents and guardians are responsible for ensuring that minors do not access the Platform. ad33 recommends the use of parental control software on any device to which minors have access. If you believe a minor has registered an account on the Platform, please contact us immediately at [email protected].

11.1 ad33 operates infrastructure that may involve the transfer of personal data to servers or service providers located outside Bangladesh. Where such transfers occur, we ensure that appropriate safeguards are in place to protect the data to a standard equivalent to that described in this Policy.

11.2 Safeguards used for international transfers include contractual data processing agreements with all third-party recipients, requiring them to process data in accordance with applicable data protection standards and restricting any onward transfer or unauthorised use.

11.3 Players who wish to obtain further information about the specific safeguards applied to international transfers of their data may contact us at [email protected].

12.1 ad33 reserves the right to update or amend this Privacy Policy at any time. Where amendments are material — meaning they affect the scope of data collected, the purposes for which it is used, or the rights available to players — we will notify registered players via the account notification centre or via the mobile number linked to their account, with a minimum of 7 days' notice before the changes take effect.

12.2 Non-material amendments, such as corrections of typographical errors or clarifications that do not alter player rights, may be made without advance notice and take effect immediately upon publication.

12.3 The effective date displayed at the top of this Policy reflects the date on which the most recent version was published. Players are responsible for reviewing this Policy periodically. Continued use of the Platform following any update constitutes acceptance of the revised Policy.

13.1 If you have any question, concern, or request relating to this Privacy Policy or the way ad33 processes your personal data, please contact our support team using the following channels:

• Email: [email protected] (subject line: "Privacy Enquiry")
• Live Chat: Available 24/7 via the Platform's in-app support widget
• WhatsApp Support: Available 08:00 – 00:00 BST (UTC+6)

13.2 We aim to acknowledge all privacy-related enquiries within 2 business days and to provide a substantive response within 30 calendar days. For complex requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and its reason.

13.3 If you are not satisfied with our response to a privacy complaint, you may refer the matter to the relevant data protection or consumer protection authority in Bangladesh. ad33 will cooperate fully with any such authority in the investigation of a complaint.

13.4 Governing Language. This Privacy Policy is issued in English, which is the operative language for all purposes. Any translation provided for convenience does not carry legal weight. In the event of any discrepancy between the English version and any translation, the English version prevails.