3539bet Privacy Policy – Data Protection and LGPD

1Who Controls Your Data

A 3539bet, the operator of the platform available at 3539bet.best, is the controller responsible for processing the personal data of users registered on the platform. For the purposes of this Privacy Policy, "controller" has the same meaning as defined by the LGPD: the legal entity that makes decisions regarding the processing of personal data.

A 3539bet has appointed a Data Protection Officer (DPO), responsible for serving as the communication channel between data subjects, the company, and the National Data Protection Authority (ANPD). The DPO can be contacted by email at privacidade@3539bet.best or through customer support, available 24 hours a day on the platform.

By creating an account on 3539bet or simply accessing the platform, you acknowledge that you have read and understood this policy. If you disagree with any aspect described here, we recommend that you do not use the platform's services.

2What Personal Data We Collect

A 3539bet collects different categories of personal data depending on how you interact with the platform. We organize this data into three main groups:

Data you provide directly when registering and using your account:

• Full name, date of birth, and CPF;
• Email address and mobile phone number;
• Full residential address (street, neighborhood, city, state, zip code);
• Banking details and Pix keys for processing deposits and withdrawals;
• Government-issued ID (RG, CNH) and proof of address when requested for KYC verification;
• Communication preferences and account settings.

Data collected automatically during use of the platform:

• IP address and approximate location data;
• Device type, operating system, and browser version;
• Pages visited, time spent, and browsing patterns;
• Betting history, game activity, and financial transactions;
• Session data, cookies and device identifiers;
• Access logs with the date, time, and actions performed on the platform.

Data obtained from third parties for verification and security purposes:

• CPF verification against official Brazilian databases for fraud prevention;
• Anti-fraud verification data from partners specialized in payment security;
• Information from responsible gambling restriction lists, where required by law or regulation.

3How and Why We Use Your Data

The personal data collected by 3539bet are used exclusively for the purposes described below. For each purpose, we also indicate the legal basis that authorizes the processing under the LGPD:

• Creating and managing your account: your registration data is required to identify you on the platform and ensure that only you have access to your account;
• Processing deposits and withdrawals: banking details and Pix keys are used exclusively to process financial transactions you have requested. No payment data is shared beyond our financial processing partners;
• Identity verification (KYC): CPF and document verification is mandatory under legal requirements and anti-money laundering regulations, and also protects you against misuse of your identity;
• Fraud prevention and security: we monitor access patterns and transactions to identify suspicious activity that may indicate fraud, money laundering or misuse of the platform;
• Account communications: we send email and SMS notifications about transactions, security updates, bet confirmations, and relevant account information. These communications are essential and cannot be disabled;
• Marketing communications: with your express consent, we may send you offers, promotions and news from the 3539bet. You can opt out of these communications at any time in your account settings;
• Platform improvement: browsing and usage data is analyzed in aggregate and anonymized form to identify technical issues, improve the user experience and develop new features;
• Responsible gambling: we monitor betting patterns to identify behaviors that may indicate problem gambling and offer proactive support when needed;
• Compliance with legal obligations: we retain transaction records and registration data as required by tax legislation, financial regulations and anti-money laundering rules in force in Brazil.

A 3539bet will never use your data for purposes incompatible with those described above without your prior and explicit consent.

4Legal Basis for Processing (LGPD)

Every data processing operation carried out by 3539bet is grounded in at least one of the legal bases set out in Article 7 of the LGPD. The table below summarizes the main bases we rely on:

Where processing is based on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing carried out prior to withdrawal. Consent withdrawal for marketing communications can be done directly in your account settings at 3539bet or through support.

5Data Sharing with Third Parties

A 3539bet does not sell your personal data. Sharing with third parties occurs only in the following specific and controlled situations:

• Payment processors: banking and transaction data is shared with partners responsible for processing Pix, boleto bancário, credit and debit cards, Mercado Pago and PicPay, solely to complete the transactions you request. These partners operate as data processors under the LGPD;
• Game providers: your username and session data are shared with game providers (PG Soft, Pragmatic Play, Evolution Gaming and others) to enable gameplay. These providers do not receive complete personal data such as your CPF or banking details;
• Identity verification services: your CPF and submitted documents are verified through specialized anti-fraud and KYC services to confirm the authenticity of your registration;
• IT infrastructure providers: hosting, CDN, and digital security providers access data only to the extent necessary to keep the platform running, under contracts with strict confidentiality and data protection clauses;
• Public and judicial authorities: when required by law, court order, or request from a competent authority (Federal Revenue Service, COAF, Public Prosecutor's Office), the 3539bet provides the required data, always within the limits permitted by law;
• Corporate restructuring processes: in the event of a merger, acquisition, or sale of assets of 3539bet, users' data may be transferred to the new controller, who will be required to follow this policy or notify users of any changes.

All third parties that receive personal data from users of 3539bet are contractually required to handle this information with the same level of security and confidentiality required by this policy and by the LGPD.

6Cookies and Tracking Technologies

A 3539bet uses cookies and similar technologies to enhance your experience on the platform. See the types of cookies we use:

• Essential cookies: required for the platform's core functionality — authentication, session security and language preferences. These cookies cannot be disabled without affecting how the platform operates;
• Performance cookies: collect anonymized data on how users navigate the 3539bet, which pages are most visited and where technical errors occur. This data helps us continuously improve the platform;
• Functional cookies: remember your personal preferences — such as language, betting settings, and preferred layout — so you don't have to reconfigure them on every visit;
• Analytics cookies: allow us to understand aggregate user behavior for internal analytics purposes. Data is processed in aggregated form and does not identify you individually;
• Affiliate cookies: when you access the 3539bet through an affiliate link, a cookie records that origin to ensure accurate commission attribution. This cookie does not collect any additional personal data.

You can manage your cookie preferences in your browser settings. Most browsers allow you to block or delete specific cookies. Please note that disabling essential cookies may prevent your account from functioning correctly on 3539bet.

7How We Store and Protect Your Data

The security of your data is a technical and operational priority at 3539bet. Security measures in place include:

• Encryption in transit: all communication between your device and the servers of 3539bet is protected by TLS 1.3 with 256-bit SSL certificates;
• Encryption at rest: sensitive data stored on our servers — including banking details and documents — is encrypted using AES-256 algorithms;
• Access control: only staff with a proven operational need are granted access to users' personal data, under a least-privilege model with a full audit log of every access;
• Multi-factor authentication: all internal systems of 3539bet that process user data require multi-factor authentication for all staff members;
• Continuous monitoring: intrusion detection systems and security monitoring operate 24 hours a day to identify and respond to unauthorized access attempts;
• Secure backups: data backups are performed regularly and stored in geographically separate locations, encrypted to the same standard as primary data;
• Security testing: we conduct periodic penetration tests carried out by specialized firms to identify and fix vulnerabilities before they can be exploited.

Although 3539bet employs robust security measures, no system is completely impenetrable. In the event of a security incident that compromises your data, 3539bet will notify affected data subjects and the ANPD within a maximum of 72 hours of becoming aware of the incident, as required by the LGPD.

8How Long We Retain Your Data

A 3539bet retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, in compliance with mandatory legal retention periods. Retention periods vary by data type:

• Registration data and active account data: retained for the full duration of your account and for 5 years after closure, in accordance with the Brazilian Civil Code and applicable tax legislation;
• Financial transaction records: retained for 10 years as required by anti-money laundering regulations (Law No. 9.613/1998) and the Central Bank of Brazil;
• Access and security logs: retained for 6 months as required by the Brazilian Internet Civil Rights Framework (Law No. 12,965/2014), and may be extended in cases of fraud investigation or litigation;
• Identity verification documents (KYC): retained for 5 years after account closure, in accordance with applicable regulatory requirements;
• Performance cookie data: retained for a maximum of 12 months, after which they are automatically deleted or anonymized;
• Support communications: conversation history and support tickets retained for 2 years for quality assurance and dispute resolution purposes.

Once retention periods expire, data is permanently deleted or irreversibly anonymized so it can no longer be linked to you as a data subject.

9Your Rights as a Data Subject (LGPD)

The LGPD grants you, as the data subject, a set of rights that 3539bet is fully committed to upholding. See what these rights are and how to exercise them:

To exercise any of these rights, please contact our privacy team by email at privacidade@3539bet.best or via the platform's live chat. We will respond to your request within 15 business days, as provided under the LGPD. In more complex cases, this deadline may be extended by an additional 15 days with written justification.

10Minors

A 3539bet is a betting and gaming platform intended exclusively for individuals aged 18 and over. In full compliance with Brazilian law and best responsible gambling practices, we implement technical and procedural measures to prevent underage access:

• Mandatory CPF verification at registration, which automatically flags users who are below the minimum age;
• Identity documentation is required for age verification during the KYC process before the first withdrawal;
• Monitoring systems that detect inconsistencies between the declared date of birth and usage patterns;
• Immediate account closure where it is confirmed that the account holder is under 18 years of age, with reimbursement of any deposits made.

A 3539bet does not intentionally collect personal data from individuals under 18. If you are a parent or legal guardian and believe a minor has created an account on the platform, please contact our support team immediately so we can act quickly.

Legal guardians wishing to protect minors in their care from accessing betting platforms may use parental control software or content filtering tools to block access to 3539bet.

11International Data Transfers

To operate a Sports Betting platform with the world's leading game and technology providers, 3539bet may carry out international data transfers in specific, controlled circumstances.

The circumstances in which data may be transferred outside Brazil include:

• Sharing with game providers such as PG Soft, Pragmatic Play, Evolution Gaming and others, who may process session data on servers located in other countries;
• Use of cloud infrastructure services from global providers with internationally distributed servers;
• Sharing with security and anti-fraud partners that operate globally.

Every international data transfer carried out by 3539bet complies with Article 33 of the LGPD, which requires that the recipient country or international body provide a level of personal data protection adequate to that established under Brazilian law, or that equivalent contractual safeguards exist (standard contractual clauses, recognized certifications, or binding corporate agreements).

12Changes to This Policy and How to Contact Us

A 3539bet may update this Privacy Policy periodically to reflect changes in our data practices, new legal requirements, or improvements to our processes. The most current version will always be available on this page, with the date of the last update shown at the top of the document.

When we make material changes that significantly affect your rights or how your data is used, we will notify you at least 15 days in advance via:

• Email address registered to your account on 3539bet;
• Notification in the account dashboard upon logging into the platform;
• A prominent notice on the platform's home page.

Continued use of the services of 3539bet after the changes take effect constitutes acceptance of the updated version of the policy. If you do not agree with the changes, you may close your account and request deletion of your data as described in section 9.

Last updated: January 2026. Version 2.1.