399be Privacy Policy

1 Introduction

Welcome to the 399be Privacy Policy. 399be ("we", "us", "our", or the "Platform") operates the online casino and sports betting platform accessible at https://399be.io and its associated subdomains, mobile interfaces, and related digital services (collectively, the "Platform"). 399be is committed to handling the personal data of all registered members and visitors with the utmost care, transparency, and integrity.

This Privacy Policy describes in detail the categories of personal data we collect from you when you visit or use the 399be platform, the purposes for which that data is processed, the legal bases upon which processing is conducted, the parties with whom data may be shared, the security measures we employ to protect your data, and the rights available to you in relation to your personal information.

This Privacy Policy forms an integral part of the 399be Terms & Conditions. By registering an account with 399be or by otherwise accessing or using our services, you confirm that you have read, understood, and agreed to the practices described in this Privacy Policy. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

2 Data We Collect

399be collects personal data across several categories, depending on how you interact with our platform. The following table provides a structured overview of the data categories we process:

399be does not collect or process sensitive personal data such as biometric data, health records, religious beliefs, or political opinions. The data we collect is limited to what is necessary for the legitimate operational, legal, and security purposes of the Platform.

3 How We Collect Your Data

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

3.1 Direct Submissions

The primary source of personal data is information you provide directly when you register a 399be account, complete the KYC identity verification process, submit a deposit or withdrawal request, contact our customer support team, or respond to promotional surveys or feedback requests. You control the data you submit through these channels.

3.2 Automated Data Collection

When you access and use the 399be platform, certain technical and usage data is collected automatically through our servers and analytics systems. This includes your IP address, device type, browser configuration, pages and games accessed, session timestamps, and interaction patterns. This data is collected passively and does not require any active submission on your part.

3.3 Cookies and Tracking Technologies

399be uses cookies, web beacons, pixel tags, and similar tracking technologies to collect technical and usage data as you navigate the platform. For full details of the cookies we use and how to manage your cookie preferences, please refer to Section 7 of this Privacy Policy.

3.4 Payment Processors and Financial Partners

When you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, or any other integrated payment partner, our payment processing systems receive confirmation data from those providers — including transaction identifiers and masked account references — necessary to credit or debit your 399be account balance. 399be does not store full payment credentials internally; these are handled by the respective payment providers under their own security frameworks.

3.5 Third-Party Game Providers

Game studios integrated with the 399be platform — including Pragmatic Play, Evolution Gaming, Spribe, NetEnt, Ezugi, and Microgaming — may independently collect technical data related to your gameplay sessions within their game environments. Such collection is governed by the respective studio's own data practices. 399be receives aggregated gameplay and outcome data from these studios for the purpose of account balance management and responsible gaming monitoring.

4 How We Use Your Data

399be processes personal data for clearly defined purposes only. We do not use member data for any purpose beyond those described below without first obtaining your explicit consent:

• Account Administration: Creating and maintaining your 399be member account, processing login authentication, and managing account settings and preferences.
• Identity and Age Verification: Conducting mandatory KYC checks to verify your identity, confirm that you are at least 21 years of age, and validate your residential address in Bangladesh.
• Payment Processing: Facilitating deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment channels; reconciling transactions; and maintaining accurate account balance records.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, bonus abuse, and any other conduct that violates our Terms & Conditions or applicable law.
• Regulatory Compliance: Meeting anti-money laundering (AML) obligations, record-keeping requirements, and any other mandatory compliance obligations under applicable law.
• Platform Improvement: Analysing usage patterns and technical performance data to improve the design, functionality, and user experience of the 399be platform.
• Responsible Gaming: Monitoring betting patterns and session behaviour to identify potential signs of problem gambling, enforce self-exclusion and deposit limit settings, and fulfil our responsible gaming obligations.
• Customer Support: Responding to your enquiries, processing complaints, and maintaining records of support interactions for quality assurance purposes.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates — but only where you have provided explicit consent to receive such communications. You may withdraw consent at any time.

5 Legal Basis for Processing

399be processes personal data only where a lawful basis for doing so exists. The primary legal bases upon which we rely are as follows:

• Contractual Necessity: The majority of data processing carried out by 399be is necessary for the performance of the contract between you and the Platform — specifically, the provision of casino gaming and sports betting services as set out in our Terms & Conditions. This covers account registration, payment processing, KYC verification, and ongoing account management.
• Legal Obligation: Certain processing activities — particularly those relating to anti-money laundering checks, fraud reporting, and record retention — are required by applicable law. 399be processes data in these contexts to fulfil mandatory legal obligations.
• Legitimate Interests: 399be processes technical and usage data on the basis of its legitimate interests in maintaining platform security, detecting and preventing fraud, improving service quality, and operating a safe gambling environment. We ensure that such processing does not override your fundamental privacy rights.
• Consent: Where processing is not otherwise justified under the bases above — most notably for direct marketing communications and non-essential cookies — 399be relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of any processing carried out prior to withdrawal.

6 Data Sharing and Disclosure

399be does not sell, rent, or trade your personal data to any third party for commercial purposes. Data sharing is limited strictly to the following categories of recipients, and only to the extent necessary for the stated purpose:

6.1 Payment Service Providers

We share the minimum necessary payment and identity data with our integrated payment partners — including bKash, Nagad, Rocket, Upay, and card processing networks — solely for the purpose of executing and verifying deposit and withdrawal transactions. These providers are contractually bound to handle your data securely and in accordance with applicable data protection standards.

6.2 Game Technology Providers

Game studios including Pragmatic Play, Evolution Gaming, Spribe, NetEnt, Ezugi, and Microgaming receive session and account-reference data necessary to operate their games within the 399be environment. No full identity data is transmitted to game studios beyond anonymised or pseudonymised session identifiers.

6.3 Regulatory and Law Enforcement Authorities

399be may be legally required to disclose member data to regulatory bodies, law enforcement agencies, financial intelligence units, or courts of competent jurisdiction in response to lawful requests, court orders, or mandatory reporting obligations. Such disclosures will be made in strict accordance with applicable legal requirements and will not require prior consent from the affected member where a legal obligation applies.

6.4 Fraud Prevention and AML Services

399be works with third-party fraud detection and anti-money laundering technology providers. These services may process technical and transaction data on 399be's behalf, under strict data processing agreements, for the purpose of identifying suspicious activity and protecting the integrity of the Platform.

6.5 Professional Advisers

In limited circumstances, 399be may share personal data with professional advisers including legal counsel, auditors, and compliance consultants, where such sharing is necessary for the conduct of legitimate business operations. All such advisers are bound by confidentiality obligations.

7 Cookies & Tracking Technologies

399be uses cookies and similar tracking technologies to ensure the proper functioning of the platform, enhance security, and improve the member experience. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core functions such as secure login session management, account balance display, and navigation between platform sections. These cookies cannot be disabled without impairing your ability to use the Platform.
• Performance and Analytics Cookies: These cookies collect anonymised data about how members interact with the 399be platform — including which pages are visited most frequently, average session durations, and error events. This data helps us continuously improve platform performance. Analytics data is not linked to any identifiable individual.
• Functional Cookies: These cookies remember your platform preferences, such as language settings, display configuration, and session timeout preferences, allowing the platform to deliver a personalised experience across sessions.
• Marketing and Targeting Cookies: With your explicit consent, 399be may use cookies to track promotional campaign effectiveness and display contextually relevant bonus offers within the Platform. These cookies do not share data with external advertising networks.

You may manage your cookie preferences at any time through your browser settings. Note that disabling strictly necessary cookies will affect the core functionality of the 399be platform. For full details of the specific cookies in use, please contact our support team at [email protected].

8 Data Retention

399be 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. The following general retention periods apply:

• Active Account Data: Personal, financial, and usage data associated with an active 399be member account is retained for the duration of the account's active status and for a minimum period of five (5) years following account closure.
• KYC and Identity Documents: Copies of identity and address verification documents submitted as part of the KYC process are retained for a minimum of five (5) years from the date of submission, in compliance with anti-money laundering record-keeping requirements.
• Transaction Records: Records of all financial transactions — including deposits, withdrawals, and betting activity — are retained for a minimum of five (5) years from the date of each transaction.
• Support Communications: Live chat transcripts, email correspondence, and formal complaint records are retained for a period of three (3) years from the date of the interaction.
• Marketing Consent Records: Records of your marketing communication consent or withdrawal of consent are retained for as long as necessary to demonstrate compliance with applicable data protection requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction. Where anonymisation is not technically feasible, data is securely destroyed.

9 Your Rights

As a 399be member, you hold the following rights in relation to your personal data. To exercise any of these rights, please contact our Data Protection team at [email protected] with the subject line "Data Rights Request":

• Right of Access: You have the right to request a copy of all personal data that 399be holds about you. We will respond to verified access requests within thirty (30) calendar days.
• 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 many personal details directly via your account settings panel.
• Right to Erasure: Subject to our legal retention obligations (see Section 8), you may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn the consent upon which processing was based. We cannot erase data we are legally required to retain — for example, KYC and transaction records subject to AML retention requirements.
• Right to Restrict Processing: You may request that we restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data is being contested, or while an objection to processing is being assessed.
• Right to Data Portability: Where processing is based on your consent or on contractual necessity, 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 the processing of your personal data where that processing is based on 399be's legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.
• Right to Withdraw Consent: Where any data processing activity 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 withdraw marketing consent, contact us at [email protected].

10 Data Security

399be takes the security of member personal data extremely seriously and has implemented a comprehensive range of technical and organisational security measures to protect your data against unauthorised access, accidental loss, alteration, or destruction. Our security framework includes the following measures:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 399be platform is protected by industry-standard 256-bit SSL/TLS encryption, ensuring that your personal and financial information cannot be intercepted in transit.
• Encrypted Data Storage: Sensitive personal and financial data stored on 399be servers is encrypted at rest using strong encryption standards. Database access is restricted to authorised personnel only, under a strict access-control policy.
• Multi-Factor Authentication: Account access requires strong password authentication and may be further protected by multi-factor authentication options available in your account settings.
• Intrusion Detection and Monitoring: 399be operates continuous server-side intrusion detection and security monitoring systems to identify and respond to potential threats in real time.
• Regular Security Audits: The 399be platform undergoes periodic technical security assessments and penetration testing by qualified security professionals to identify and remediate vulnerabilities proactively.
• Staff Access Controls: Access to member personal data by 399be staff is granted strictly on a need-to-know basis. All staff members with access to personal data are subject to confidentiality obligations and receive regular data protection training.

11 Children's Privacy

The 399be platform is strictly intended for use by adults aged 21 years and above. 399be does not knowingly collect, process, or retain any personal data relating to individuals under the age of 21. Registration on the 399be platform by individuals under 21 years of age is strictly prohibited.

If 399be becomes aware or has reason to believe that personal data has been submitted by or on behalf of an individual under the age of 21, that data will be immediately deleted, the associated account will be permanently closed, and any funds held in that account will be handled in accordance with our Terms & Conditions and applicable law.

If you are a parent or guardian and believe that a minor in your care may have registered a 399be account, please contact us immediately at [email protected] so that we can take appropriate action without delay.

12 Third-Party Links and Services

The 399be platform may contain references to third-party payment services, game studios, and technology providers. While 399be exercises due diligence in selecting its business partners and requires them to maintain appropriate data protection standards, 399be is not responsible for the privacy practices of third-party services operating their own independent platforms or applications.

This Privacy Policy applies exclusively to personal data collected and processed by 399be through the 399be platform (https://399be.io). Any data you provide directly to a third-party service — for example, when completing a bKash or Nagad transaction on their own application — is governed by that service's own privacy policy. We encourage you to review the privacy documentation of any third-party services you use in connection with the 399be platform.

13 Updates to This Privacy Policy

399be reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, the introduction of new platform features, evolving legal requirements, or improvements to our privacy standards. The "Last Updated" date at the top of this document will always reflect the most recent revision.

Where changes to the Privacy Policy are material — meaning they significantly affect the way we process your personal data or the rights available to you — 399be will notify registered members via email and/or a prominent in-platform notification prior to the revised Policy taking effect. For non-material updates, the revised Policy will take effect immediately upon publication at https://399be.io/privacy-policy.

Your continued use of the 399be platform following the publication of any revised Privacy Policy constitutes acceptance of the updated terms. If you do not agree with any changes to the Privacy Policy, you must discontinue use of the platform and may request account closure as described in the 399be Terms & Conditions.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 399be handles your personal data, please reach out to our Data Protection team using the contact details below. All privacy-related communications are handled in English and will receive a response within five (5) business days.

For responsible gaming support, including self-exclusion requests and deposit limit applications, please email [email protected] with the subject line "Responsible Gaming Request" and our team will prioritise your case.