39ko Privacy Policy — Your data is our responsibility

1 Introduction & Applicability

39ko ("we", "us", or "the platform") takes your privacy seriously. This Privacy Policy explains how we collect, store, use, and protect your personal information. It applies to our website, mobile application, and all associated services.

By registering for or using our platform, you agree to this Privacy Policy. We may update this policy at any time, but you will be notified before any significant changes take effect.

2 What information we collect

39ko only collects information that is genuinely needed to provide you with our services. Collecting unnecessary data goes against our policy. Below is a breakdown of the types of information we collect:

We never digitally store your National ID number or passport number. For KYC verification, only a confirmation record of completed verification is kept.

3 How We Collect Data

39ko collects information through the following methods:

• Directly Provided Information: Information you provide directly when registering, updating your profile, or contacting support.
• Automatically Collected Information: System logs, cookies, and device information are collected automatically while you use the platform.
• Payment Gateway: Limited payment data is collected when processing transactions via Mobile Banking, Nagad, or Rocket.
• Third-Party Verification: Where necessary, your information may be verified through authorized verification agencies for age or identity checks.

4 Purpose of Data Use

39ko uses your information only for specific, legitimate purposes. We never use your data for anything you have not consented to.

• Account management: For registration, login verification, and profile management.
• Financial transactions: To process deposits and withdrawals.
• Security Assurance: To prevent fraud, money laundering, and cyberattacks.
• Service Improvement: To analyze usage patterns and improve the quality of the platform.
• Legal obligations: To comply with government guidelines and legal requirements.
• Responsible Gaming: To detect early signs of potential addiction and provide timely support.
• Contact: To send important updates, security alerts, and transaction confirmations.

5 Data Sharing & Third Parties

39ko may share your personal information with third parties only in limited circumstances and with strict security measures in place. Those circumstances are outlined below:

• Payment Processor: Only the information necessary to complete transactions is shared with Mobile Banking, Nagad, and Rocket.
• Legal authorities: Data may be disclosed to government or legal authorities in accordance with the laws of Bangladesh.
• Technology Service Provider: Limited data may be shared with trusted technology partners for server, database, and security services — all of whom are bound by our confidentiality agreements.
• Fraud Prevention: In cases of serious fraud, necessary information may be shared with industry-standard fraud prevention organizations.

6 Data Protection Measures

39ko follows the highest industry security standards to protect your information. Our technology team monitors security 24/7.

• SSL/TLS Encryption: All data transfers are encrypted using 256-bit SSL technology.
• Secure Database: Stored data is protected with AES-256 encryption.
• Two-Factor Authentication (2FA): OTP verification is required every time you access your account.
• Firewall & DDoS Protection: Advanced firewalls are in place to protect our servers from cyberattacks.
• Regular Security Audits: Regular security audits are conducted by third parties.
• Restricted Access: Only authorized personnel are permitted to access specific data.

7 Data Retention Period

39ko retains your data only for as long as necessary — no longer. After account closure, certain information may be kept for a defined period to meet legal obligations.

• Active Account: All data is retained in full while the account is active.
• Closed Accounts: Financial records are kept for up to 5 years after account closure (legal requirement).
• Transaction Logs: Financial transaction records are retained for up to 7 years.
• Support Conversations: Support tickets and chat logs are retained for up to 2 years.
• Marketing Data: Removed immediately upon opt-out.

8 Your Rights

Under 39ko's Privacy Policy, you have important rights over your own data. Contact our support team to exercise any of these rights.

• Right to Access: You may request to know what information we hold about you.
• Right to Rectification: You may request corrections to any inaccurate or outdated information.
• Right to Erasure: You may request deletion of any data held beyond legal requirements.
• Right to Restrict Processing: You may request that we restrict the use of your data for specific purposes.
• Right to Data Portability: You can obtain a copy of your data in a readable format.
• Right to object: You may object to certain types of data processing.

9 Child Protection

39ko strictly prohibits use of the platform by anyone under 18. We do not knowingly collect personal information from minors.

• Age verification is mandatory at the time of registration.
• Accounts are suspended immediately if a minor is suspected.
• If data belonging to a minor is collected inadvertently, it will be deleted immediately.

10 Policy Changes & Contact

39ko reserves the right to update this Privacy Policy at any time. For significant changes, advance notice will be provided via SMS to your registered mobile number or through a notice on the platform.

Continued use of our services after any changes to this policy will be considered acceptance of the updated terms. For any privacy-related questions or concerns, please reach out to our support team — we are available 24/7 to assist you.