ace35 Privacy Policy — How We Handle Your Data

1Introduction

This Privacy Policy ("Policy") describes how ace35 ("ace35", "we", "us", "our") collects, uses, stores, shares, and protects the personal data of individuals ("you", "your", "Player") who access or use the ace35 online casino and sports betting platform available at ace35.club ("Platform"). This Policy forms part of our Terms and Conditions and should be read alongside them.

By accessing the Platform or registering an Account, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not consent to this Policy, you must not use the Platform. ace35 takes its obligations in respect of personal data seriously and processes all personal data in a lawful, fair, and transparent manner.

ace35 is the data controller responsible for personal data collected through the Platform. All data processing activities described in this Policy are carried out either directly by ace35 or by authorised third-party service providers acting under ace35's instruction and bound by appropriate data protection obligations.

2Personal Data We Collect

ace35 collects the following categories of personal data, depending on how you interact with the Platform:

3How We Use Your Personal Data

ace35 uses the personal data we collect for the following specific purposes:

• Account creation and management — registering your account, verifying your identity, maintaining your profile, and processing login authentication.
• Payment processing — enabling deposits via bKash, Nagad, Rocket, and Upay; processing withdrawal requests; and maintaining transaction records for financial compliance.
• KYC and age verification — verifying that all Players are at least 21 years of age, confirming the identity of each Player before processing their first withdrawal, and maintaining records as required by our compliance procedures.
• Responsible gaming monitoring — tracking gaming activity to identify patterns that may indicate problem gambling behaviour, and enabling Players to use deposit limits, session limits, and self-exclusion tools from within their account settings.
• Fraud prevention and security — detecting and investigating suspicious activity, protecting the Platform against misuse, and preventing financial fraud, identity fraud, and bonus abuse.
• Customer support — responding to queries, complaints, and requests submitted by Players via live chat or email, and maintaining support interaction records to improve service quality.

ace35 does not use your personal data for automated profiling that produces legal effects or similarly significant decisions without human review. ace35 does not use your personal data for purposes that are incompatible with those stated in this Policy.

4Legal Basis for Processing

ace35 processes personal data on one or more of the following legal bases:

• Contractual necessity — processing required to perform the contract between ace35 and the Player (i.e. to provide the Platform services you have signed up for, including account management and payment processing).
• Consent — where you have provided explicit consent to a specific processing activity, such as receiving promotional communications. You may withdraw consent at any time by contacting support.
• Legal obligation — processing required to comply with applicable legal or regulatory requirements, including financial record-keeping, anti-money laundering checks, and responding to lawful requests from competent authorities.
• Legitimate interests — processing carried out for ace35's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.

5Sharing Your Personal Data

ace35 does not sell your personal data to third parties. We share personal data only in the following limited circumstances:

• Authorised service providers — third-party companies that provide specific services to ace35, including payment processors (bKash, Nagad, Rocket, Upay), game software providers (Pragmatic Play, Evolution Gaming, Spribe, Ezugi), identity verification services, and technical infrastructure providers. All such providers are contractually bound to process personal data only as instructed by ace35 and to maintain appropriate security standards.
• Law enforcement and regulatory authorities — where ace35 is required by law, court order, or lawful demand from a competent government authority to disclose personal data. ace35 will notify the Player of any such request where it is legally permitted to do so.
• Business transfers — in the event of a merger, acquisition, or sale of all or part of ace35's business, personal data held by ace35 may be transferred to the acquiring entity, subject to equivalent data protection commitments.
• Fraud prevention — sharing relevant data with fraud detection networks and financial compliance services where required to prevent or investigate financial crime, money laundering, or identity fraud.

6Payment Data and Financial Information

When you make a deposit or withdrawal using bKash, Nagad, Rocket, or Upay, ace35 receives confirmation of the transaction from the relevant payment provider along with a masked reference identifier for your mobile wallet. ace35 does not receive or store your full mobile banking PIN, OTP codes, or complete mobile wallet password. Payment transactions are completed within the secure environment of your mobile wallet app or mobile banking portal, and ace35 receives only the confirmation and reference data needed to credit or debit your Platform Wallet.

ace35 maintains transaction records as required for financial compliance and dispute resolution purposes. These records include transaction amounts, timestamps, payment method references, and outcome records. Transaction records are retained for the period required by applicable financial compliance obligations, which may extend beyond account closure.

7Cookies and Session Tracking

The ace35 Platform uses browser-based session cookies and local storage to maintain your login session, remember your preferences, and ensure the Platform operates correctly. ace35 uses the following categories of cookies:

• Essential cookies — strictly necessary for the Platform to function. These include session authentication cookies that keep you logged in during a gaming session. These cannot be disabled without breaking Platform functionality.
• Functional cookies — used to remember your language preference, display settings, and responsible gaming tool configurations (such as your active deposit limit or session limit setting). These improve your experience but are not strictly required for core Platform operation.
• Analytics cookies — used to collect aggregated, anonymised data about how Players navigate the Platform. This data is used solely to improve Platform performance, identify broken flows, and optimise the user experience for Bangladesh mobile users. No individually identifiable data is extracted from analytics cookies.

Most mobile browsers allow you to control or delete cookies via your browser settings. Disabling essential cookies will prevent the Platform from functioning correctly. Disabling functional or analytics cookies will not prevent you from accessing the Platform but may reduce the quality of your experience.

8Data Retention

ace35 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable legal and compliance obligations. The following general retention periods apply: Account data (including identity, contact, and KYC documents) is retained for the duration of an active Account plus a minimum of 5 years following Account closure, to satisfy financial compliance and anti-money laundering record-keeping requirements. Gaming and transaction data is retained for a minimum of 5 years from the date of the relevant activity. Support interaction records are retained for 2 years. Device and session data is retained for 12 months.

Where personal data is no longer required and no legal obligation requires its continued retention, ace35 will securely delete or anonymise the data in a manner that prevents recovery or re-identification. Players may request confirmation of the retention period applicable to their specific data by contacting ace35 support.

9Data Security

ace35 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. Our security programme is reviewed and updated on a regular basis to account for evolving threats and industry best practices.

While ace35 takes all reasonable steps to protect your personal data, no internet-based system is completely immune to security risks. You are also responsible for maintaining the security of your Account login credentials, including your password. If you believe your Account has been compromised, contact ace35 support immediately.

10Your Data Rights

You have the following rights in respect of your personal data held by ace35. To exercise any of these rights, contact ace35 support via live chat or email. ace35 will respond to all valid rights requests within a reasonable timeframe.

ace35 may need to verify your identity before processing a data rights request. Where a request is complex or numerous, ace35 reserves the right to extend the response period by up to one additional month, with notification to you. ace35 will not charge a fee for data rights requests unless they are manifestly unfounded or excessive.

11Children's Privacy and the 21+ Requirement

The ace35 Platform is strictly intended for adults aged 21 and above. ace35 does not knowingly collect personal data from individuals under the age of 21. If ace35 discovers that personal data has been collected from a person under 21, that data will be deleted immediately and the associated Account will be closed. If you believe that a person under 21 has registered on the Platform, please contact support immediately so that the Account can be investigated and closed.

12Third-Party Links and Services

The ace35 Platform integrates third-party game content provided by game studios including Pragmatic Play, Evolution Gaming, Spribe, and Ezugi. When you interact with games provided by these studios, the game software may operate within an iframe or embedded environment. ace35 is responsible for the personal data it shares with these providers under data processing agreements. However, ace35 is not responsible for the independent privacy practices of third-party studios where Players interact directly with those studios' own websites or applications outside of the ace35 Platform.

13Changes to This Privacy Policy

ace35 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, ace35 will notify Players via the Platform or via the contact details registered on the Player's Account prior to the changes taking effect. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision.

Your continued use of the Platform after a revised Privacy Policy has been published and notified constitutes your acceptance of the updated Policy. If you do not accept the revised Policy, you must stop using the Platform and may request Account closure by contacting ace35 support.

14Contact Us About This Policy

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ace35 handles your personal data, please contact our support team. We aim to respond to all privacy-related enquiries within 5 business days.

Our Privacy Commitments at a Glance

A plain-language summary of what ace35 promises every player in Bangladesh regarding their personal data.