ef33 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how ef33 ("the Platform", "we", "us", "our") collects, processes, stores, and protects personal data relating to individuals ("User", "you", "your") who access or use the ef33 platform at ef33.io or any associated mobile application.

ef33 is an online betting and casino platform operated for players in Bangladesh. All services are delivered in English and all financial transactions are conducted in Bangladeshi Taka (BDT). This Policy applies to all personal data collected in connection with registration, account management, deposits and withdrawals, sports betting, casino gaming, promotional participation, and customer support interactions.

This Policy should be read alongside the ef33 Terms & Conditions, which govern the overall relationship between ef33 and its registered users. By registering an account or using the ef33 platform, you acknowledge that you have read this Policy and consent to the collection and processing of your personal data as described herein.

2 Data Controller

ef33 acts as the data controller for all personal data collected through the ef33 platform. As the data controller, ef33 determines the purposes for which personal data is processed and the means by which it is processed.

For all data-related enquiries, requests to exercise your rights, or concerns regarding this Policy, please contact the ef33 Data Protection team at the following address:

• Platform name: ef33
• Website: ef33.io
• Data protection contact email: [email protected] (plain text — not a link)
• Support hours: 24/7, Bangladesh Standard Time (BST, UTC+6)
• Response time for data requests: Within 30 calendar days of receipt

ef33 is committed to resolving all data-related concerns promptly and transparently. If you submit a data request or complaint, you will receive an acknowledgement within two business days and a full response within 30 days.

3 Data We Collect

ef33 collects the following categories of personal data from its users. Collection occurs at the time of registration, during account use, and in connection with specific activities such as deposits, withdrawals, and support interactions.

4 How We Collect Data

ef33 collects personal data through a combination of direct collection, automated technical collection, and, in limited circumstances, third-party sources. The primary methods are described below.

• Direct collection: Information you provide during account registration (name, date of birth, mobile number), when completing KYC verification (document uploads), when making deposits or requesting withdrawals, and when contacting customer support.
• Automated collection: Technical and usage data is collected automatically when you visit or use the ef33 platform. This includes your IP address, device identifiers, browser type, session duration, pages visited, and feature interactions. This data is collected via server logs, cookies, and similar tracking technologies.
• Payment provider data: When you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, or a partner bank, the relevant payment provider shares transaction confirmation data with ef33 sufficient to verify and process the transaction.
• Identity verification providers: ef33 may use third-party identity verification services to assist with KYC checks. These providers may return verification status data, risk flags, or document authenticity scores to ef33.
• Game providers: Third-party game providers (Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, Spribe, etc.) share session data with ef33 in connection with games played on the ef33 platform.
• Fraud detection services: ef33 may receive risk signals or device reputation scores from fraud detection partners in order to protect the integrity of the platform and the safety of user funds.

5 How We Use Your Data

ef33 uses the personal data it collects for the following purposes. Each purpose is linked to a lawful legal basis described in Section 6.

• Account creation and management: To register your account, verify your identity, manage your profile, and maintain your account security.
• Service delivery: To provide access to sports betting markets, casino games, card games, slots, and all other platform features.
• Payment processing: To receive deposits, process withdrawals, record transaction history, and resolve payment disputes.
• Bonus and promotion management: To track bonus eligibility, verify wagering completion, apply promotional credits, and communicate promotional offers where you have opted in.
• KYC and compliance: To verify your identity and age, conduct anti-money laundering (AML) checks, and meet our legal and regulatory obligations.
• Fraud prevention and platform security: To detect and prevent fraudulent activity, duplicate accounts, bonus abuse, bot usage, and other prohibited conduct as defined in the Terms & Conditions.
• Responsible gaming: To monitor gambling patterns, enforce self-imposed limits and self-exclusion agreements, and identify users who may be exhibiting signs of problem gambling.
• Customer support: To respond to queries, resolve disputes, investigate complaints, and maintain records of support interactions.
• Platform improvement: To analyse usage patterns, fix bugs, optimise the user interface, and develop new features based on aggregated, anonymised usage data.
• Legal obligations: To comply with applicable laws, respond to lawful requests from authorities, and maintain records required by law.

6 Legal Basis for Processing

ef33 processes personal data only where a valid legal basis exists. The legal bases relied upon are as follows:

• Contractual necessity: Processing required to register your account, deliver the services you have requested, process your payments, and fulfil our obligations to you under the Terms & Conditions. Without this processing, ef33 cannot provide its services.
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering (AML) regulations, age verification obligations, and responses to lawful requests from law enforcement or competent authorities.
• Legitimate interests: Processing carried out in pursuit of ef33's legitimate business interests where those interests are not overridden by your privacy rights. This includes fraud prevention, platform security, duplicate account detection, responsible gaming monitoring, and aggregated analytics for platform improvement.
• Consent: Processing based on your freely given, specific, and informed consent. Consent is relied upon for optional marketing communications and for the placement of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing

ef33 does not sell, rent, or share your personal data with third parties for their own marketing purposes. Personal data is shared with third parties only in the following circumstances, each of which is governed by appropriate data processing agreements and confidentiality obligations.

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — for the purpose of processing deposits and withdrawals. Only the minimum data necessary to execute and confirm the transaction is shared.
• Identity verification providers: Third-party KYC service providers engaged by ef33 to verify the identity, age, and document authenticity of registered users. These providers process data strictly on ef33's instructions.
• Game providers: Evolution Gaming, Ezugi, Pragmatic Play, NetEnt, Microgaming, Spribe, and other licensed game studios — to deliver the games hosted on the ef33 platform. Session data and account identifiers are shared to enable game functionality and the crediting of winnings.
• Fraud and security service providers: Third-party fraud detection and device intelligence services engaged to protect platform integrity. These providers receive technical data (IP addresses, device fingerprints) and return risk scores.
• IT infrastructure providers: Hosting, cloud storage, and content delivery providers who process data on ef33's behalf under strict data processing agreements.
• Law enforcement and regulatory authorities: ef33 will disclose personal data to law enforcement agencies, courts, or regulatory authorities where required to do so by applicable law or in response to a lawful court order or regulatory request.

All third-party data processors engaged by ef33 are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with ef33's documented instructions.

8 International Data Transfers

Some of the third-party providers engaged by ef33 — in particular game providers and cloud infrastructure services — may process data in countries outside Bangladesh. Where personal data is transferred to recipients in other countries, ef33 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections described in this Policy.

Safeguards used for international transfers may include:

• Contractual clauses in data processing agreements that require the recipient to maintain equivalent data protection standards.
• Transfer only to providers who are certified under internationally recognised security frameworks (e.g., ISO 27001).
• Transfer to providers operating in jurisdictions with adequate data protection laws as assessed by ef33.

Where international transfers are necessary for the delivery of a specific service (for example, a live casino game hosted by a provider with data centres outside Bangladesh), the transfer is carried out on the basis of contractual necessity. You may request further information about specific international transfer safeguards by contacting ef33 at [email protected].

9 Data Retention

ef33 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data (identity and contact data): Retained for the duration of your account plus five years after account closure, to meet legal retention obligations and to enable dispute resolution during the statutory limitation period.
• Financial and transaction data: Retained for seven years from the date of the transaction, in accordance with financial record-keeping requirements applicable to payment service activities.
• KYC documents: Retained for five years from the date of account closure or the date of the last transaction, whichever is later, in accordance with anti-money laundering record-keeping obligations.
• Betting and gaming history: Retained for 12 months in your account's accessible history. Full transaction records are retained by ef33 for dispute resolution purposes for up to five years.
• Customer support records: Retained for three years from the date of the interaction, to enable reference in the event of related future disputes.
• Technical and usage data (logs, IP addresses): Retained for 12 months from the date of collection for security and fraud investigation purposes, after which they are anonymised or deleted.
• Marketing consent records: Retained for three years from the date of consent or from the last meaningful interaction, to demonstrate the validity of consent.

When personal data is no longer required for any lawful purpose, it is securely deleted or permanently anonymised using industry-standard data destruction methods. Anonymised and aggregated data (from which no individual can be identified) may be retained indefinitely for statistical and platform improvement purposes.

10 Security Measures

ef33 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Key security measures in place include:

• SSL/TLS encryption: All data transmitted between your device and ef33 servers is encrypted using 256-bit SSL/TLS. The padlock icon in your browser confirms that your connection to ef33.io is secure.
• Data encryption at rest: Sensitive personal data, including identity documents and financial data, is encrypted when stored on ef33 servers.
• Access controls: Access to personal data is restricted to ef33 personnel and third-party processors who have a legitimate need to access that data. All access is logged and subject to regular audit.
• Two-factor authentication: ef33 offers SMS-based two-factor authentication (2FA) for player accounts to reduce the risk of unauthorised account access.
• Intrusion detection: ef33 operates 24/7 intrusion detection and monitoring systems to identify and respond to security incidents in real time.
• Staff training: All ef33 staff with access to personal data are trained in data protection principles and are subject to confidentiality obligations.
• Penetration testing: ef33 conducts regular security assessments and penetration tests of its platform infrastructure to identify and address vulnerabilities proactively.

11 Cookies & Tracking Technologies

ef33 uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device by your browser when you visit a website. ef33 uses cookies for the following purposes:

• Essential cookies: Required for the platform to function correctly. These include session cookies that maintain your logged-in state, security tokens, and load-balancing cookies. These cookies cannot be disabled without impairing platform functionality.
• Functional cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming limit configurations. These cookies improve your experience but are not strictly essential.
• Analytics cookies: Used to collect aggregated, anonymised data about how users interact with the ef33 platform, including pages visited, features used, and session durations. This data is used solely to improve the platform and is not used to identify individual users.
• Security cookies: Used to detect fraudulent activity, identify suspicious session behaviour, and support the platform's fraud detection systems. These cookies process device and session identifiers to protect user accounts and platform integrity.

ef33 does not use advertising or retargeting cookies, and does not permit third-party advertising networks to place cookies on the ef33 platform.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies will prevent you from logging in and using the ef33 platform. Disabling functional or analytics cookies will not affect your ability to place bets or play games but may result in a reduced browsing experience.

12 Your Data Rights

As a registered user of ef33, you have the following rights in relation to your personal data. To exercise any of these rights, submit a written request to [email protected]. ef33 will respond within 30 calendar days of receiving your request.

ef33 will not charge a fee for processing data rights requests unless the request is manifestly unfounded or excessive, in which case a reasonable administrative fee may be applied. Verification of your identity will be required before ef33 processes any data rights request to protect your data from unauthorised disclosure.

13 Amendments to This Policy

ef33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform operations. When material changes are made, ef33 will notify registered users via the mobile number or email address associated with their account at least seven days before the updated Policy takes effect.

Minor changes — such as typographical corrections, clarifications that do not alter your rights, or updates required to reflect minor operational adjustments — may be published without advance notice. The "last updated" date at the top of this page will always reflect the most recent revision.

Your continued use of the ef33 platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should stop using the ef33 platform and may request closure of your account by contacting [email protected].

The most current version of this Privacy Policy is always available at ef33.io/privacy-policy. We encourage you to review this page periodically to stay informed about how ef33 protects your personal data.