cl33 Privacy Policy — How We Protect Your Data

1Who We Are

cl33 operates the online betting and casino platform accessible at cl33.io. cl33 is the data controller responsible for the personal data of registered players and visitors to the cl33.io website. As data controller, cl33 determines the purposes and means by which your personal data is processed.

cl33 is a safe and reliable platform designed and built for the Bangladesh market. All services are delivered in English and all transactions are conducted in Bangladeshi Taka (৳). Players based in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and elsewhere across Bangladesh are served by this platform under a single consistent data protection framework.

For all privacy-related enquiries, data subject requests, or concerns regarding the use of your personal data, please contact the cl33 Data Protection team via the channels listed in Section 14 of this Policy.

2Data We Collect

cl33 collects personal data across several categories depending on how you interact with the platform. The categories and specific data types we collect are detailed below:

2.1 Identity and Contact Data

• Full name as provided at registration
• Date of birth (for age verification — 21+ requirement)
• Registered Bangladesh mobile number
• Email address (where provided)
• National Identity Card (NID) number or passport number (collected during KYC verification)
• Residential address in Bangladesh

2.2 Account Data

• cl33 username and account ID
• Encrypted password hash (your actual password is never stored in plain text)
• Account creation date and registration device fingerprint
• Account status, verification tier, and self-exclusion history
• Responsible gaming settings including deposit limits, session limits, and cooling-off periods

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction history including amounts, dates, and payment method types (bKash, Nagad, Rocket, Upay, Visa, Mastercard)
• Payment method identifiers (e.g., the last four digits of a card or the registered mobile wallet number)
• BDT wallet balance history
• Bonus credits, wagering history, and promotional redemption records

2.4 Betting and Gaming Activity Data

• Full betting history including event, market, selection, stake, odds, and settlement outcome
• Casino game session records including game title, provider, stake, result, and duration
• Live casino session participation records
• Crash game rounds (Aviator, Spribe) and outcome history
• Aggregate win/loss statistics and playing pattern data used for responsible gaming monitoring

2.5 Technical and Device Data

• IP address at time of login and at time of each transaction
• Device type, operating system, and browser version
• Session duration and frequency of platform access
• Geolocation data (city-level) derived from IP address
• Referral source (the URL or channel through which you reached cl33.io)

2.6 Communications Data

• Support chat transcripts from the cl33 live chat system
• Email correspondence with the cl33 support team
• WhatsApp support message records (content and timestamps)
• Feedback, complaint, and dispute submissions

3How We Collect Your Data

cl33 collects personal data through the following channels and mechanisms:

3.1 Directly From You

The majority of your personal data is collected directly from you when you register an account, complete KYC verification, make a deposit or withdrawal, place a bet, play a casino game, contact our support team, or update your account settings. You provide this data voluntarily as part of using the cl33 platform.

3.2 Automatically Through Platform Use

When you access cl33.io, certain technical data is collected automatically by our systems. This includes your IP address, device information, browser type, session timestamps, and in-platform navigation behaviour. This data is collected using server logs, session tracking technology, and cookies as described in Section 7 of this Policy.

3.3 From Third-Party Service Providers

cl33 may receive personal data from third-party service providers in the following contexts:

• Payment processors (bKash, Nagad, Rocket, Upay, Visa/Mastercard acquiring banks) confirm the status of your payment transactions and may share transaction verification data with cl33.
• Identity verification providers used during KYC processing may return verification status flags and document authenticity results to cl33.
• Game providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi) share game round and session data with cl33 through their platform integration APIs in order to credit winnings, process refunds, and maintain complete betting records.
• Fraud prevention services may share risk signals or device fingerprint data with cl33 where suspicious activity patterns are detected.

4How We Use Your Data

cl33 uses the personal data we collect for the following clearly defined purposes:

5Legal Basis for Processing

cl33 processes your personal data on the following legal grounds, depending on the purpose of processing:

5.1 Contractual Necessity

Processing your identity data, financial data, and gaming activity data is necessary for cl33 to fulfil its contractual obligations to you as a registered player. This includes creating and managing your account, processing transactions, settling bets, and providing customer support. Without this processing, cl33 cannot deliver the services you have signed up for.

5.2 Legal Obligation

cl33 is required by applicable law to collect and retain certain categories of personal data, including identity verification records and financial transaction history, for defined minimum periods. Processing for anti-money laundering (AML), counter-terrorism financing (CTF), and fraud prevention purposes is carried out on the basis of legal obligation.

5.3 Legitimate Interest

cl33 processes technical and device data, platform usage patterns, and aggregated gaming statistics on the basis of legitimate interest in operating a secure, fair, and well-functioning platform. This includes fraud detection, security monitoring, platform performance analytics, and responsible gaming monitoring. Where we rely on legitimate interest, we have assessed that our interests do not override your fundamental rights and freedoms.

5.4 Consent

Where cl33 sends you marketing communications, processes non-essential cookies, or uses your data for purposes beyond those listed above, we do so only with your explicit, freely given, informed, and revocable consent. You may withdraw consent for marketing or non-essential cookies at any time without penalty — withdrawal of consent does not affect your ability to continue using the cl33 platform.

6Sharing Your Data

cl33 does not sell, rent, or trade your personal data. We share your data only in the limited, necessary circumstances described below:

6.1 Payment Processing Partners

When you make a deposit or withdrawal, your payment details are shared with the relevant payment processor (bKash, Nagad, Rocket, Upay, or the relevant card acquiring bank via Visa/Mastercard networks). These partners receive only the data required to authorise and process the transaction. They are contractually prohibited from using your data for any other purpose.

6.2 Game Providers

To deliver casino games and live dealer experiences on the cl33 platform, game session data (account token, stake, game result) is exchanged in real time with providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. This data exchange is necessary for the technical operation of the games and the accurate crediting of winnings. Game providers do not receive your name, contact details, or financial account information.

6.3 Identity Verification Providers

Where cl33 uses a third-party KYC service provider to assist with identity document verification, your NID or passport image and associated identity data is shared with that provider solely for the purpose of verification. Verification providers are bound by confidentiality agreements and data processing restrictions.

6.4 Fraud Prevention and Security Services

cl33 may share limited technical data (IP address, device fingerprint, transaction patterns) with specialist fraud prevention services to identify and block fraudulent activity. This sharing is carried out on the basis of legitimate interest in maintaining platform security for all players.

6.5 Legal and Regulatory Disclosure

cl33 will disclose personal data to law enforcement agencies, regulatory authorities, or other public bodies where required by law, court order, or formal legal process. cl33 will comply with all lawful requests for data disclosure and will notify affected players of such requests where legally permitted to do so.

6.6 Business Transfers

In the event of a merger, acquisition, asset sale, or corporate restructuring involving cl33, player personal data may be transferred as part of that transaction. Any acquirer of cl33's business would be required to honour the commitments made in this Privacy Policy or provide players with appropriate notice and choices prior to any change in data processing practices.

7Cookies & Tracking Technologies

cl33 uses cookies and similar tracking technologies on the cl33.io website to operate the platform effectively, remember your preferences, maintain your login session, and analyse how players use the site. The categories of cookies used by cl33 are as follows:

7.1 Strictly Necessary Cookies

These cookies are essential for the cl33 platform to function. They maintain your authenticated session when you are logged in, preserve your language and currency settings, enable secure payment processing handoffs, and support other core operational features. These cookies cannot be disabled without preventing the platform from functioning correctly.

7.2 Performance and Analytics Cookies

cl33 uses analytics cookies to understand how players navigate the platform — which pages are visited most frequently, how long sessions last, and where technical errors occur. This information is used in aggregated, anonymised form to improve platform performance and the overall player experience. These cookies are set only with your consent.

7.3 Functional Cookies

Functional cookies remember your platform preferences — such as your preferred sports categories, bet slip state, table game preferences, and notification settings — so you do not need to reconfigure them on each visit. These cookies enhance convenience without being strictly necessary for platform operation.

8Data Retention

cl33 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to minimum retention periods required by applicable law. The general retention periods applied by cl33 are as follows:

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with any individual player. Where cl33 is required to retain data beyond these standard periods due to ongoing legal proceedings or regulatory investigations, data will be retained for the duration of those proceedings.

9Data Security

cl33 takes the security of your personal data seriously and implements a layered set of technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction.

9.1 Encryption

All data transmitted between your device and cl33.io is encrypted using TLS (Transport Layer Security) via HTTPS. Sensitive stored data, including passwords (stored as salted hashes) and identity document references, is encrypted at rest using industry-standard encryption protocols.

9.2 Access Controls

Access to player personal data within cl33 is restricted on a strict need-to-know basis. Internal staff members can only access data relevant to their specific role. All internal access to player data is logged and subject to periodic access rights reviews.

9.3 Security Monitoring

cl33 operates continuous security monitoring across its platform infrastructure. Automated systems flag anomalous login behaviour, unusual transaction patterns, and potential intrusion attempts for immediate review by the cl33 security team. Regular penetration testing and vulnerability assessments are conducted on the cl33.io platform.

9.4 Data Breach Response

In the event of a personal data breach that poses a risk to the rights and freedoms of affected players, cl33 will take immediate steps to contain the breach, assess its scope, and notify affected players without undue delay. The cl33 security team maintains a documented incident response procedure for handling data security events.

10Your Rights

As a registered cl33 player, you have the following rights with respect to your personal data. To exercise any of these rights, contact cl33 support at [email protected] with the subject line "Data Rights Request — [Your Username]". cl33 will acknowledge your request within 2 business days and provide a substantive response within 14 days.

10.1 Right of Access

You have the right to request a copy of all personal data that cl33 holds about you. This includes your account data, transaction history, betting records, KYC documents, and communications history. cl33 will provide this information in a structured, readable format within 14 days of a verified request.

10.2 Right to Rectification

If any personal data cl33 holds about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. For basic account information, you may be able to make corrections directly through your account settings. For KYC or identity data corrections, please contact support and provide supporting documentation.

10.3 Right to Erasure

You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been unlawfully processed. This right is subject to cl33's legal obligation to retain certain categories of data (see Section 8). Where deletion is not possible due to a legal retention requirement, cl33 will restrict processing of your data instead.

10.4 Right to Restriction of Processing

You may request that cl33 restrict the processing of your personal data in certain circumstances — for example, while the accuracy of the data is being contested, or while a legitimate interest assessment is being reviewed. During a restriction period, cl33 may store your data but will not actively process it for operational purposes.

10.5 Right to Data Portability

Where cl33 processes your personal data on the basis of your consent or on the basis of a contract, you have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller where technically feasible.

10.6 Right to Object

You have the right to object to cl33 processing your personal data on the basis of legitimate interest, including profiling carried out for responsible gaming monitoring. Where you raise a valid objection, cl33 will cease processing unless compelling legitimate grounds exist that override your interests, rights, and freedoms.

10.7 Rights Related to Marketing

You have the right to withdraw consent to receive marketing communications from cl33 at any time. Withdrawal of marketing consent will be actioned within 5 business days and will not affect your ability to use any other feature of the cl33 platform.

11Children's Privacy

The cl33 platform is strictly intended for adults aged 21 years and above. cl33 does not knowingly collect, process, or store personal data from any person under the age of 21. Registration on the cl33 platform requires confirmation that the registrant meets the minimum age requirement, and age verification is conducted as part of the KYC process.

If cl33 becomes aware that personal data has been collected from an individual under 21 years of age, that account will be immediately suspended, all associated data will be securely deleted, and any deposited funds (net of applicable checks) will be returned to the original payment method. If you believe that a minor may have registered on the cl33 platform, please contact us immediately at [email protected].

12Third-Party Links

The cl33.io website does not contain links to external third-party websites. All links on the cl33 platform lead to internal pages within cl33.io. Should cl33 ever include links to third-party resources in the future, those external sites would have their own privacy policies which cl33 does not control. cl33 would not be responsible for the privacy practices of any such third-party sites, and players would be advised to review those sites' privacy policies independently.

Game provider content delivered within the cl33 platform (for example, live casino streams from Evolution Gaming or slot games from Pragmatic Play) is delivered via embedded integration and governed by those providers' data processing agreements with cl33. Players do not interact directly with game provider privacy policies when playing on the cl33 platform.

13Changes to This Privacy Policy

cl33 reserves the right to update, revise, or replace this Privacy Policy at any time. Changes may be made to reflect updates in applicable law, changes in data processing practices, new platform features, or feedback from players and regulatory guidance.

When material changes are made to this Privacy Policy, cl33 will notify registered players via a platform announcement on cl33.io and, where possible, via direct communication to the registered contact details associated with your account. The updated Privacy Policy will be clearly dated at the top of the page, and continued use of the cl33 platform following the effective date of any changes constitutes your acknowledgement of the updated Policy.

Players are encouraged to review this Privacy Policy periodically to stay informed about how cl33 protects their personal data. The most current version of this Privacy Policy will always be accessible at cl33.io/privacy-policy.

14Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way cl33 handles your personal data, please contact the cl33 Data Protection team using the details below:

cl33 is committed to resolving all privacy-related enquiries promptly and fairly. If you are not satisfied with the response you receive from cl33 regarding a data privacy concern, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction.