Privacy Policy for 3patte

1 Information We Collect

When you interact with the 3patte platform — whether by creating an account, placing a bet, making a deposit, contacting our support team, or simply browsing the website — certain categories of personal information may be collected. We collect only what is necessary to provide the Service, fulfil our legal obligations, and protect the integrity of the platform.

1.1 Information You Provide Directly

This is information you submit to us voluntarily when using the Service. It includes:

• Registration data: Full legal name, date of birth, email address, mobile phone number, and residential address provided when you open a 3patte account.
• Identity verification documents: Government-issued photo ID (National ID card, passport, or driving licence) and proof of address (utility bill or bank statement) submitted during KYC verification.
• Financial information: Payment method details such as your bKash or Nagad mobile number, Dutch-Bangla Bank account reference, or card details provided when making a deposit or requesting a withdrawal. We do not store full card numbers — these are handled by our PCI-DSS-compliant payment processors.
• Communications: The content of messages, emails, or live-chat transcripts you send to our support team, including any attachments you provide.
• Preferences and settings: Responsible gaming limits, notification preferences, and any other account settings you configure within your player dashboard.

1.2 Information Collected Automatically

When you access the 3patte website or mobile platform, our systems automatically record certain technical and behavioural data, including:

• Device and connection data: IP address, device type, operating system, browser type and version, screen resolution, and mobile network operator.
• Usage data: Pages visited, games launched, duration of gaming sessions, betting history, search queries within the platform, and clickstream data showing how you navigate through the site.
• Location data: Approximate geographic location derived from your IP address. We do not collect precise GPS coordinates unless you explicitly grant permission on a mobile device.
• Cookie and tracking data: Identifiers set by first-party and third-party cookies and similar technologies. See Section 4 for full details.

1.3 Information from Third Parties

In limited circumstances, 3patte may receive information about you from third-party sources, including identity verification agencies used to confirm your KYC documents, payment providers confirming transaction status, and fraud-prevention databases. We use this information solely to verify your identity, process payments, and maintain the security and integrity of the platform.

2 How We Use Your Data

3patte uses the personal data we collect for the following purposes, each grounded in a legitimate legal basis:

Purpose	Data Used	Legal Basis
Account creation and management	Registration data, identity documents	Contractual necessity
Processing deposits and withdrawals	Financial information, KYC documents	Contractual necessity
Age and identity verification (KYC)	ID documents, date of birth, address	Legal obligation
Fraud prevention and platform security	Device data, IP address, usage data	Legitimate interest
Responsible gaming monitoring	Betting history, session data, limits	Legal obligation / legitimate interest
Customer support and complaints	Communications, account data	Contractual necessity
Marketing and promotions (opt-in only)	Email, mobile number, preferences	Consent
Analytics and platform improvement	Usage data, device data, cookies	Legitimate interest

2.1 Marketing Communications

3patte will only send you promotional emails, SMS messages, or push notifications if you have explicitly opted in to receive them during registration or through your account preferences. You may withdraw your consent and unsubscribe from marketing communications at any time by updating your notification settings within your account dashboard or by contacting our support team. Withdrawing consent for marketing does not affect your ability to continue using the Service.

2.2 Automated Decision-Making

3patte uses automated systems to detect suspicious activity, flag potential instances of problem gambling, and enforce responsible gaming limits. Where an automated decision may significantly affect your account — for example, a temporary suspension triggered by unusual login activity — you have the right to request human review of that decision. Please contact [email protected] to exercise this right.

3 Data Sharing and Disclosure

3patte does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the specific, limited circumstances described below, and only to the extent necessary for each purpose.

3.1 Service Providers and Technology Partners

We engage trusted third-party vendors to help us operate the 3patte platform. These include game software providers (such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi), payment processors handling bKash, Nagad, Rocket, Upay, Visa, and Mastercard transactions, identity verification agencies, cloud hosting providers, customer support software platforms, and fraud detection services. Each of these providers is bound by strict data processing agreements and may only use your data for the specific purpose for which it was shared.

3.2 Legal and Regulatory Disclosures

We may disclose your personal data to law enforcement agencies, regulatory authorities, or other government bodies where we are legally required to do so or where we believe in good faith that such disclosure is necessary to:

• Comply with a court order, legal process, or regulatory investigation.
• Detect, prevent, or investigate fraud, money laundering, or other financial crimes.
• Protect the rights, property, or safety of 3patte, its players, or the general public.
• Enforce our Terms & Conditions or other agreements.

3.3 Business Transfers

In the event that 3patte undergoes a merger, acquisition, restructuring, or sale of all or a substantial portion of its assets, your personal data may be transferred to the successor entity as part of that transaction. We will provide reasonable notice of any such transfer and of any material changes to how your data is handled as a result.

4 Cookies and Tracking Technologies

3patte uses cookies and similar tracking technologies (collectively "cookies") on our website. A cookie is a small text file placed on your device by your web browser when you visit a website. Cookies allow us to recognise your device on subsequent visits, remember your preferences, and understand how you use the platform.

4.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the website to function. They enable core features such as secure login sessions, account authentication, and navigation between pages. These cookies cannot be disabled without rendering the Service unusable.
• Functional cookies: Remember your preferences such as language settings, game lobby filters, and responsible gaming limit configurations, so you do not have to re-enter them on each visit.
• Analytics cookies: Collect aggregated, anonymised data about how visitors interact with the website — such as which pages are visited most, how long sessions last, and where players navigate from. This data is used solely to improve platform performance and user experience.
• Security cookies: Help us detect and prevent fraudulent activity, enforce session timeouts, and protect your account from unauthorised access.

4.2 Managing Your Cookie Preferences

You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or alert you when a new cookie is set. Please note that disabling non-essential cookies may affect the functionality and personalisation features of the 3patte platform. Strictly necessary cookies cannot be disabled via browser settings without impacting your ability to use the Service.

5 Data Retention

3patte retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements. The specific retention periods that apply are as follows:

• Account and registration data: Retained for the lifetime of your active account, and for a minimum of five years after account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction and betting records: Retained for a minimum of five years from the date of each transaction, as required by financial record-keeping regulations applicable to online payment processing in Bangladesh.
• KYC identity documents: Retained for the period your account is active and for at least five years following account closure. Documents are stored in encrypted format on secure servers.
• Customer support communications: Retained for three years from the date of the most recent correspondence in the relevant support thread.
• Marketing consent records: Retained for the duration of your account and for two years following withdrawal of consent, as evidence that we processed your data lawfully.
• Analytics and log data: Aggregated, anonymised analytics data may be retained indefinitely. Raw server log files are retained for a maximum of 12 months before being deleted.

When the applicable retention period expires, we securely delete or irreversibly anonymise your personal data in accordance with our internal data destruction procedures. If you request erasure of your data before the retention period has elapsed, we will assess your request and delete everything that is not subject to a mandatory legal retention obligation.

6 Data Security Measures

3patte implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. While no system can guarantee absolute security, we are committed to maintaining industry-standard safeguards at all times.

6.1 Technical Safeguards

• SSL/TLS encryption: All data transmitted between your device and the 3patte platform is encrypted in transit using SSL/TLS protocols. The padlock icon in your browser's address bar confirms this connection is active.
• Encrypted data storage: Sensitive data including identity documents, financial records, and account credentials are stored in encrypted form on access-controlled servers.
• Password hashing: Player passwords are never stored in plain text. We use industry-standard cryptographic hashing algorithms to store password representations that cannot be reversed.
• Two-factor authentication (2FA): Players are encouraged to enable 2FA on their accounts. This adds a secondary verification step that significantly reduces the risk of unauthorised access even if your password is compromised.
• Firewalls and intrusion detection: Our infrastructure is protected by enterprise-grade firewalls and continuously monitored intrusion detection systems that alert our security team to anomalous activity in real time.

6.2 Organisational Safeguards

Access to player personal data within 3patte is restricted on a strict need-to-know basis. Only personnel whose role requires access to specific categories of data are granted the relevant permissions. All staff with access to personal data receive regular training on data protection obligations and information security best practices. We conduct periodic security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.

6.3 Data Breach Response

In the event of a personal data breach that poses a risk to your rights and freedoms, 3patte will notify affected players without undue delay once the breach has been identified and contained. Notifications will be sent to the email address registered on your account and will describe the nature of the breach, the categories of data affected, the likely consequences, and the steps 3patte is taking to address the situation.

7 Your Privacy Rights

As a player on the 3patte platform, you hold the following rights in relation to your personal data. We are committed to honouring these rights promptly and without undue obstacles. To exercise any of the rights listed below, contact us at [email protected] with the subject line "Privacy Rights Request".

7.1 Right of Access

You have the right to request a copy of the personal data that 3patte holds about you. Upon receiving a verified request, we will provide a structured summary of your data in a commonly used format within a reasonable timeframe, and at no charge for a standard first request.

7.2 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 can update many data fields directly within your account settings; for fields that cannot be self-edited (such as your name following a legal change), please contact our support team with supporting documentation.

7.3 Right to Erasure

You may request that we delete your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent (and no other legal basis applies), or where we have processed it unlawfully. Please note that we may be required to retain certain data to comply with legal obligations — such as anti-money laundering record-keeping requirements — and in such cases we will inform you of the specific data that cannot be erased and the reason why.

7.4 Right to Restrict Processing

You have the right to request that 3patte restricts the processing of your personal data in specific circumstances — for example, while you contest the accuracy of data we hold, or while we assess your objection to processing based on legitimate interest. During a restriction period, we will continue to store your data but will not actively process it for other purposes.

7.5 Right to Data Portability

Where we process your data on the basis of your consent or contractual necessity, and the processing is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format. You may also request that we transmit this data directly to another service provider where technically feasible.

7.6 Right to Object to Marketing

You have the right to object at any time to the use of your personal data for direct marketing purposes. If you object to marketing, we will immediately cease processing your data for that purpose. You can also unsubscribe directly from any marketing email using the unsubscribe link in the message footer.

8 Contact and Policy Updates

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 3patte handles your personal data, please contact our data protection team using the details below. We are committed to addressing your concerns promptly and transparently.

Email: [email protected]
Subject line for privacy matters: "Privacy Rights Request"
Response time: Within 30 calendar days of receiving a verified request.

8.1 Policy Updates

3patte reviews this Privacy Policy periodically and will update it when our data practices change, when new legal obligations arise, or when we introduce new features that affect the personal data we collect or process. When we make material changes, we will notify registered players via email to the address on file and by posting a prominent notice on the website with the effective date of the updated policy. The version of this Privacy Policy displayed on the website is the currently operative version. We recommend that you review this page periodically to stay informed.

8.2 Children's Privacy

The 3patte platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor has provided us with personal data or has accessed the Service, we will immediately close the account, forfeit any associated balance, and delete the personal data in question. If you have reason to believe that a minor has registered on the platform, please contact us immediately at [email protected].