Privacy Policy of 93dcom – Your Data, Our Responsibility

1 Who We Are – Your Data Controller

A 93dcom is the controller of the personal data collected through the platform available at 93dcom.best and in associated applications. For the purposes of the LGPD, "controller" refers to the entity that makes decisions about how personal data is collected, stored, and used.

Our contact channel for matters related to this Privacy Policy is the email contato@93dcom.best. For requests specifically related to your rights as a data subject (access, correction, deletion, portability), use the same address with the subject line "LGPD – Data Subject Rights".

2 What Personal Data We Collect

93dcom collects personal data at different points during your interaction with the platform. Below is an organized overview of the types of data collected and when:

2.1 Data You Provide Voluntarily

Most of the personal data 93dcom holds about you was provided directly by you at registration, during the identity verification process, or when contacting support. You control what you share — though some data is required to use certain features (such as identity verification to process withdrawals).

2.2 Automatically Collected Data

When you access 93dcom on your mobile device or desktop browser, some technical data is collected automatically: IP address, device type, operating system, and session cookies. This data is used to keep your account secure, detect suspicious access, and optimize platform performance. You cannot disable the collection of technical data essential to security without being unable to use the platform.

3 How We Use Your Personal Data

93dcom uses your personal data exclusively for the following purposes:

• Operate your account: create and maintain your active account, authenticate logins, process deposits via Pix, boleto, and card, and execute withdrawals via Pix or bank transfer;
• Identity verification: fulfill KYC (Know Your Customer) obligations required by anti-money laundering regulations applicable to the sports betting market in Brazil;
• Fraud prevention: detect and prevent unauthorized access, use of multiple accounts, money laundering, and other activities prohibited by the Terms and Conditions;
• Customer support: answer your questions, resolve complaints, and keep a support history to ensure consistent service;
• Marketing communications: send 93dcom offers, promotions, and updates by email or push notification — always with the option to unsubscribe at any time;
• Compliance with legal obligations: respond to requests from regulatory, tax, or judicial authorities in accordance with Brazilian law;
• Platform improvement: analyze usage patterns in aggregate and anonymized form to improve the experience, performance, and features available on 93dcom.

4 Legal Basis for Data Processing

The LGPD requires that all personal data processing have a legal basis. 93dcom relies on the following legal bases, as set out in art. 7 of Law No. 13,709/2018:

• Contract performance (art. 7, V): to operate your account, process bets, deposits, and withdrawals — activities essential to the platform's terms of use;
• Compliance with a legal obligation (art. 7, II): for KYC activities, anti-money laundering compliance, and responding to requests from competent authorities;
• Legitimate interest (art. 7, IX): for fraud prevention, platform security, and aggregated usage analysis to improve our services;
• Consent (art. 7, I): for sending marketing communications — which you can withdraw at any time without affecting your account access.

5 Data Sharing with Third Parties

93dcom does not sell users' personal data. We share data only in the following situations and with the following categories of partners:

5.1 Essential Operating Partners

• Payment processors: institutions that process Pix, boleto bancário, credit/debit card, PicPay, and Mercado Pago transactions. We share only the minimum data required to process each transaction;
• Identity verification providers: specialized companies in document verification and biometric authentication that assist with the KYC process;
• Casino game providers: slots, Live Casino, and crash game providers receive session identifiers only — never full personal data such as tax ID or home address;
• Infrastructure providers: hosting, CDN, and network security services that support the technical operation of the 93dcom platform.

5.2 Competent Authorities

93dcom may share data with regulatory, tax, law enforcement, or judicial authorities when required by law or court order. In such cases, we share only the minimum necessary and, where legally permitted, notify the data subject before sharing.

5.3 Transfers in Corporate Reorganizations

In the event of a merger, acquisition, or sale of 93dcom assets, users' personal data may be transferred as part of the transaction. In such cases, you will be notified in advance, and the new controlling entity will be required to comply with this Privacy Policy until a new version is published.

6 Cookies and Tracking Technologies

The 93dcom platform uses cookies and similar technologies to ensure proper functionality, personalize your experience, and monitor account security. The types of cookies used are:

• Essential cookies: required to keep your session active, process bets, and ensure secure login. These cannot be disabled without compromising platform functionality;
• Performance cookies: collect anonymized information about how users interact with the platform, helping us identify bottlenecks and improve the experience;
• Preference cookies: remember your settings, such as language, favorite sports, and notification preferences;
• Marketing cookies: used to display relevant content based on your interests. You can decline these cookies in your browser settings without losing access to the platform.

You can manage cookies through your browser or app settings. Please note that disabling essential cookies may prevent certain 93dcom features from working properly, including the login process and bet confirmation.

7 Data Storage and Retention

93dcom stores your personal data on secure servers protected by encryption both at rest and in transit. Data is retained for as long as necessary to fulfill the purpose for which it was collected, subject to the following minimum retention periods:

• Active account data: throughout the entire period your account remains active on 93dcom;
• Financial data (KYC and transactions): retained for a minimum of 5 years after account closure, in compliance with anti-money laundering regulations;
• Customer support communication data: retained for 2 years to ensure consistent customer support;
• Marketing data: retained until you withdraw your consent or request deletion.

Once the legal retention period has ended, data is anonymized or securely deleted so that the original data subject can no longer be identified.

8 Personal Data Security

93dcom implements technical and organizational measures to protect your personal data against unauthorized access, loss, alteration, or improper disclosure:

• 256-Bit SSL Encryption across all communications between your device and our servers;
• Encryption at rest for data stored in databases, especially financial data and identity documents;
• Two-factor authentication (2FA) available for your account — we strongly recommend you enable it;
• Internal access controls with a least-privilege principle: only employees with a functional need are granted access to specific data categories;
• Periodic audits security reviews conducted by internal teams and, where applicable, by external auditors;
• Incident Response Plan which defines clear procedures for detecting, containing, and reporting data breaches.

9 Your Rights as a Data Subject

The LGPD grants you, as the data subject whose personal data is processed by 93dcom, the following rights:

• Confirmation and access (art. 18, I and II): you may request confirmation that 93dcom processes your data and obtain a full copy of the information we hold about you;
• Correction (art. 18, III): you may request the correction of incomplete, inaccurate, or outdated data;
• Anonymization, blocking, or deletion (art. 18, IV): you may request that data that is unnecessary or processed in violation of the LGPD be anonymized, blocked, or deleted;
• Portability (Art. 18, V): you may request that your data be transferred to another service provider, in accordance with ANPD regulations;
• Erasure of data processed with consent (art. 18, VI): for data processed based on your consent, you may request deletion after revoking that consent;
• Information about sharing (art. 18, VII): you have the right to know which public and private entities 93dcom has shared your data with;
• Withdrawal of consent (art. 18, IX): you may withdraw any previously given consent at any time;
• Objection (art. 18, § 2): you may object to processing carried out on the basis of legitimate interest when that processing violates your rights.

To exercise any of these rights, contact the 93dcom DPO by email at contato@93dcom.best with the subject line "LGPD – Data Subject Rights". We will respond within 15 business days. In more complex cases requiring additional review, we may extend this period by a further 15 business days, with notice of the reason.

10 Minors

93dcom is an online betting platform exclusively for users aged 18 and over. We do not intentionally collect personal data from minors. Registration requires a date of birth and tax ID (CPF), both of which are verified during the KYC process.

If you believe a minor under 18 has created a 93dcom account using incorrect information, please contact our support team immediately via email or live chat. The account will be closed and any data collected from the minor will be deleted as quickly as possible once the case has been verified.

11 International Data Transfers

Some of 93dcom's technical partners — such as cloud infrastructure providers and casino game suppliers — may be located outside Brazil. When this is the case, 93dcom ensures that international transfers of personal data only take place to countries or organizations that offer an adequate level of protection, in accordance with ANPD guidelines, or through the adoption of specific contractual data protection clauses as required by the LGPD.

You can request information about specific international transfers involving your data by contacting 93dcom's DPO.

12 Changes to this Privacy Policy

93dcom may update this Privacy Policy periodically to reflect changes in legislation, our data processing practices, or the services we offer. Significant changes will be communicated by email and through a notice on the platform at least 7 days in advance.

The date of the last update is always shown at the top of this document. We recommend reviewing this policy periodically. Continued use of the platform after any changes take effect constitutes acceptance of the updated version.

13 Contact and Data Protection Officer (DPO)

For any questions about this Privacy Policy, to exercise your rights as a data subject, or to report a possible privacy violation, please contact the 93dcom:

• General email: contato@93dcom.best
• LGPD Requests: contato@93dcom.best — subject: "LGPD – Data Subject Rights"
• Live chat: available 24 hours a day, every day, directly on the 93dcom platform
• Response time: up to 15 business days for data subject requests

You also have the right to lodge a complaint with the National Data Protection Authority (ANPD) if you believe your rights as a data subject have not been respected by 93dcom.