193bet Privacy Policy – Data Protection

1. Data Controller

The controller of your personal data — that is, the entity responsible for decisions on how data is collected and processed — is 193bet, the operator of the platform available at https://193bet.biz.

For any questions related to privacy or the handling of your personal data, you can reach us directly at contato@193bet.biz, with the subject line "Privacy – LGPD".

2. Data We Collect

193bet collects only the data necessary to provide the services requested by the user. The categories of data collected include:

2.1 Registration Data

• Full name as it appears on your official ID;
• CPF (Cadastro de Pessoas Físicas);
• Date of birth;
• Email address;
• Mobile phone number;
• Residential address (street, number, neighborhood, city, state, zip code).

2.2 Identity Verification Data (KYC)

• Copy of a government-issued ID (national ID card, driver's license, or passport);
• Recent proof of residence;
• Selfie with ID document (when requested for advanced verification);
• Proof of source of funds (when required for compliance purposes).

2.3 Financial Data

• Deposit and withdrawal history, including the payment method used (Pix, boleto bancário, credit/debit card, PicPay, Mercado Pago, TED);
• Pix key linked to the user's CPF;
• Credit or debit card details (stored via tokenization — the full card number is never held on our servers).

2.4 Platform Usage Data

• Betting history (sports, events, markets, amounts, and outcomes);
• Casino, poker, and crash games history;
• Session duration and usage patterns;
• Notification and communication preferences.

2.5 Technical Data

• IP address;
• Browser type and version;
• Operating system and device type (mobile, tablet, desktop);
• Approximate geolocation data (country and state — not real-time precise location tracking);
• Cookies and session identifiers (detailed in section 6).

3. How We Use Your Data

The data collected by 193bet is used exclusively for the following purposes:

193bet does not use personal data for purposes incompatible with those listed above without prior notice and, where required, renewed consent from the data subject.

4. Legal Basis for Processing

Under the LGPD, all processing of personal data must have a legal basis. 193bet relies on the following legal bases:

• Contract performance (Art. 7, V of the LGPD): To process registrations, bets, deposits, and withdrawals — without this data, we cannot provide the service.
• Legal or regulatory obligation (Art. 7, II): To comply with anti-money laundering regulations, KYC identity verification requirements, and other legal obligations applicable to the sector.
• Legitimate interest (Art. 7, IX): For fraud detection, security analysis, bonus abuse prevention, and platform improvement — provided this does not override the rights and freedoms of the data subject.
• Consent (Art. 7, I): For sending marketing communications, personalized promotions, and optional messages. Consent may be withdrawn at any time through your account settings or via email.

5. Sharing Data with Third Parties

193bet may share users' personal data only in the situations listed below, and always with appropriate contractual and security safeguards in place:

5.1 Operational Partners

To deliver our platform services, 193bet works with specialized partners who may have limited access to your data:

• Payment processors: To confirm and process transactions via Pix, bank slip (boleto bancário), credit/debit card, PicPay, and Mercado Pago. These partners receive only the data necessary for each specific transaction.
• Game providers: Live Casino, slots, and crash game providers may receive an anonymized player identifier for technical game-operation purposes.
• Identity verification providers: Specialized KYC companies that assist with document verification and fraud prevention.
• Cloud infrastructure: Server and storage providers that host data under data processing agreements compliant with the LGPD.

5.2 Legal Obligation

193bet may disclose personal data to government authorities, regulatory bodies, or law enforcement agencies when required under applicable Brazilian law — such as in cases involving money laundering investigations, fraud, or other financial crimes.

5.3 What We Never Do

• We sell personal data to advertisers or data brokers;
• We share data with other betting houses or gaming companies without explicit consent;
• We do not transfer data outside Brazil without the legal safeguards required by the LGPD for international data transfers.

6. Cookies and Tracking Technologies

193bet uses cookies and similar technologies to ensure the platform functions correctly, improve the user experience, and — with your consent — personalize content and promotions.

6.1 Types of Cookies We Use

• Essential cookies: Required for the basic operation of the platform — session authentication, bet slip, and language preferences. These cannot be disabled.
• Performance cookies: These collect anonymous data on how users navigate 193bet — pages visited, session duration, and errors encountered — helping us identify and resolve technical issues.
• Functionality cookies: These remember your preferences — such as your favorite sport on the home page or live betting settings — so your experience is personalized without needing to reconfigure anything on each visit.
• Marketing cookies (with consent): Used to display relevant content on the platform based on your interests and usage history. They are only activated with your explicit consent.

6.2 How to Manage Cookies

You can manage your cookie preferences through your browser settings (Chrome, Firefox, Safari, Edge) or mobile device (Android, iPhone). Disabling non-essential cookies may affect certain platform features, such as the automatic saving of your betting preferences.

7. Data Security

193bet implements appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, or improper disclosure. Key measures include:

• SSL/TLS Encryption: All traffic between users and 193bet's servers is encrypted — including registration data, financial transactions, and bets;
• Payment data tokenization: Credit and debit card data is never stored in plain text — it is replaced by encrypted tokens managed by our payment partner;
• Access control: Users' personal data is accessible only to 193bet employees who need it to carry out their specific roles — access is granted on a need-to-know basis;
• Two-factor authentication (2FA): Available for users who want an extra layer of protection when accessing their account;
• Continuous monitoring: Intrusion detection systems and anomaly monitoring run continuously to identify unauthorized access attempts;
• Security audits: Conducted periodically by internal teams and, where applicable, by independent external auditors.

7.1 Security Incidents

In the event of a security incident that could put users' personal data at risk, 193bet will follow the protocol required by the LGPD — notifying the National Data Protection Authority (ANPD) and the affected users within the legal timeframe, with clear information about the nature of the incident, the data involved, and the measures taken to mitigate it.

8. Data Retention and Deletion

193bet retains personal data only for as long as necessary to fulfill the purposes for which it was collected or to meet applicable legal obligations. The general retention criteria are:

• Active account data: Retained for the full duration of the user's active account on the platform;
• Closed account data: After account closure, data is retained for up to 5 years to comply with legal obligations related to tax and anti-money laundering requirements, as mandated by Brazilian law;
• Financial transaction data: Deposit, withdrawal, and bet records are retained for a minimum of 5 years, in accordance with Brazilian Federal Revenue requirements and COAF regulations;
• Support and communication data: Support history is retained for 2 years to ensure quality assurance and dispute resolution;
• Cookies and technical data: Session data is deleted when you close your browser; anonymized performance data may be retained for a longer period for aggregate analysis.

Once the applicable retention period expires, data is securely deleted or permanently anonymized so that the data subject can no longer be identified.

9. Your Rights as a Data Subject

The LGPD grants you, as the data subject, a set of rights that 193bet is fully committed to upholding. Here is what you can request:

10. Protection of Minors

193bet's services are intended exclusively for individuals aged 18 (eighteen) or older. The platform does not knowingly collect data from minors.

During registration, users confirm they meet the minimum age requirement. 193bet conducts age verification as part of the KYC process — users who cannot confirm they are of legal age will have their access suspended until the matter is resolved.

If you believe a minor has misused the platform or that a child's data was collected without parental or guardian consent, please contact us immediately at contato@193bet.biz with the subject line "Protection of Minors". 193bet will take immediate steps to investigate and remove any data involved.

11. Changes to this Privacy Policy

193bet may update this Privacy Policy periodically to reflect changes in data practices, new services offered, or updates to applicable legislation.

When significant changes are made, 193bet will notify users via their registered email or through a prominent notice on the platform with reasonable advance notice — generally 15 days before the changes take effect.

The date of the most recent update is always shown at the top of this page. Continued use of 193bet's services after a new version of this Policy is published constitutes acceptance of the updated terms.

We recommend visiting this page periodically to stay informed about how your data is handled.

12. Contact the Data Protection Officer (DPO)

To exercise your rights as a data subject, get answers about this Policy, or report any privacy-related concern regarding your data at 193bet, you can reach us through the following channels:

• Email: contato@193bet.biz (subject line: "Privacy – LGPD" or "DPO – Data Subject Request")
• Live chat: Available 24 hours a day, 7 days a week, directly on the 193bet platform

193bet responds to all data subject requests within 15 business days, as required by Art. 18 of the LGPD. For more complex cases, this deadline may be extended, and you will be notified in advance with an explanation.

If you are not satisfied with the response you receive, you have the right to file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD), the regulatory body responsible for enforcing the LGPD in Brazil.