Data Protection

39gg Privacy Policy – Your Data, Protected

This document describes how the 39gg collects, stores, uses, and protects its users' personal data in full compliance with Brazil's General Data Protection Law (LGPD — Law No. 13.709/2018). We write in plain language because you have the right to understand exactly what happens with your information.

Last updated: January 2026 Language: Brazilian Portuguese LGPD Compliant

What This Policy Guarantees You

39gg's concrete commitments to every player's privacy

Full LGPD Compliance

The 39gg operates in full compliance with the General Data Protection Law (Lei nº 13.709/2018). This means every piece of data collected has a specific purpose and a clear legal basis. You have the right to know what data we hold about you and can request correction, portability, or deletion at any time.

256-Bit SSL Encryption

All communication between your phone or computer and the servers of the 39gg is encrypted with 256-bit SSL — the same standard used by Brazil's largest digital banks, such as Nubank, Itaú, and Bradesco. Your login credentials and financial information are never transmitted in plain text over the internet.

Data Never Sold to Third Parties

The 39gg does not sell, rent, or transfer your personal data to third parties for commercial purposes. Data is only shared with partners in situations strictly necessary for service delivery — such as processing Pix transactions — and always under a confidentiality agreement.

Minimal and Proportional Data Collection

We collect only the data genuinely needed to deliver our service, meet legal obligations, and keep the platform secure. We don't ask for unnecessary information and don't retain data beyond the legally required period. The principle of data minimization is built into the design of the 39gg.

Full Control Over Communications

You decide whether you want to receive marketing communications from the 39gg. You can unsubscribe from promotional emails and push notifications at any time through your account settings or via the link in any email we send — no hassle, no need to contact support.

Accessible DPO & Portuguese-Language Support

The 39gg has a Data Protection Officer (DPO) available to handle requests related to your personal data. To exercise any right guaranteed under the LGPD, simply reach out via 24/7 support in Portuguese — live chat, email, or WhatsApp — and your request will be processed within the legally required timeframes.

1. Introduction

Player privacy is taken seriously at 39gg. This Privacy Policy was written so you can understand, clearly and without unnecessary legal jargon, how we handle your personal data when you use the platform at https://39gg.click.

The 39gg acts as the data controller for the personal data you provide during registration, when making deposits via Pix or other methods, when playing casino games and crash games, when betting on sports such as Brasileirão and UFC, and when interacting with our support team. Each of these interactions may involve the processing of personal data, always on an adequate legal basis and for a legitimate purpose.

This policy is an integral part of our Terms and Conditions. By creating your account, you confirm that you have read and understood how your data is handled. If you have any questions about this policy, our support team is available 24 hours a day in Portuguese via live chat or by email at contato@39gg.click.

In summary: The 39gg only collects what it needs, uses your data solely for the purposes described in this policy, does not sell your data to third parties, and upholds all rights provided under the LGPD. It's that simple.

2. Data Controller

The controller responsible for processing your personal data is the operator of the platform 39gg, available at https://39gg.click. For any questions related to the protection of your personal data, you may contact our Data Protection Officer (DPO) through the channels below:

  • Email: contato@39gg.click
  • Live chat: available 24 hours a day directly on the site, with an average response time of under 2 minutes
  • WhatsApp: available for privacy and data protection inquiries

The DPO of 39gg is responsible for receiving and processing all requests related to data subjects' rights, ensuring that data processing complies with the LGPD, and serving as the point of contact with the National Data Protection Authority (ANPD).

3. Personal Data Collected

The 39gg collects personal data across three main categories, described below:

3.1 Data you provide directly

  • Registration data: full name, CPF, date of birth, email address, mobile number, and password (stored in hashed format, never as plain text).
  • Identity verification data (KYC): government-issued photo ID (RG or CNH), a selfie for facial recognition, and proof of address — collected only when required to fulfill legal anti-money laundering obligations.
  • Financial data: Pix key, credit or debit card details (processed by a PCI-DSS certified gateway, never stored directly by 39gg), transaction history on the platform.
  • Support communications: chat content, emails, and calls with our support team, recorded for quality assurance and security purposes.

3.2 Automatically Collected Data

  • Browsing data: IP address, browser type and version, operating system, device used (mobile, tablet, or desktop), pages visited, session duration, and links clicked.
  • Geolocation data: approximate location based on IP address, used solely for eligibility verification and fraud prevention. 39gg does not collect precise GPS location from your device.
  • Gameplay behavior data: betting history, most-used games, access times, amounts wagered, and withdrawals made — used for experience personalization, fraud detection, and responsible gambling monitoring.

3.3 Data received from third parties

In some cases, the 39gg may receive data from partners, such as game providers (for dispute resolution purposes) and payment providers (for transaction confirmation via Pix and boleto bancário). This data is always handled with the same level of protection applied to data collected directly.

Data Category Examples Primary Purpose
Identification Name, CPF, date of birth Registration and eligibility verification
Contact Email, mobile number Communication, support and notifications
Financial Pix key, transaction history Processing deposits and withdrawals
Technical IP, device, browser Security and fraud prevention
Gaming behavior Betting history, favorite games Personalization, responsible gambling
Identity (KYC) RG/CNH, proof of address Legal verification, money laundering prevention

4. Purpose of Data Use

The 39gg uses your personal data solely for the purposes described below. No data is used for purposes other than those listed without your express consent:

  • Service delivery: account creation and management, processing deposits via Pix and other methods, withdrawal approval, and access to casino games, crash games, and Sports Betting.
  • Identity verification and eligibility: confirmation that the user is 18 or older, CPF verification with the Receita Federal, and prevention of platform access by individuals under active self-exclusion.
  • Security and fraud prevention: detection of multiple accounts created with the same CPF, identification of anomalous access patterns, anti-money laundering measures in line with regulatory requirements.
  • Compliance with legal obligations: meeting financial compliance requirements, responding to requests from competent authorities, maintaining legally required records.
  • Experience personalization: displaying relevant games based on your usage history, personalizing promotions and offers within the 39gg.
  • Customer support: resolving queries and disputes, and continuously improving our support based on past interactions.
  • Responsible gambling monitoring: identification of behavioral patterns that may indicate problem gambling, for proactive provision of the responsible gambling tools available at the 39gg.
  • Marketing communications: sending emails about promotions, new games, and features — only to users who have opted in to receive these communications. Unsubscribing is available at any time.

5. Legal Basis for Processing

All personal data processing carried out by 39gg relies on at least one of the legal bases set out in Article 7 of the LGPD:

  • Contract performance (art. 7, V): processing is necessary to provide the services you agreed to when creating your 39gg account — such as processing your Pix deposits and releasing your withdrawals.
  • Compliance with a legal obligation (art. 7º, II): obligations related to anti-money laundering, age verification, and responding to requests from competent authorities.
  • Legitimate interest (art. 7, IX): security activities, fraud prevention, and service improvements — always limited to what is strictly necessary and in full respect of your fundamental rights.
  • Consent (art. 7º, I): for sending marketing communications and personalizing offers, based on consent that you may withdraw at any time.
Transparency: If you'd like to know the specific legal basis for the processing of any of your data not listed above, just ask the 39gg. We'll respond in plain language, without unnecessary legal jargon.

6. Data Sharing

The 39gg does not sell your personal data to third parties. Sharing only occurs in situations strictly necessary for service delivery or when required by law:

6.1 Payment processing partners

To process your deposits and withdrawals via Pix, boleto bancário, credit/debit card, PicPay, and Mercado Pago, the 39gg shares only the minimum data necessary with the payment processors involved. These partners are contractually required to handle your data with the same level of security and confidentiality applied by 39gg.

6.2 Game Providers

To resolve disputes over casino game results, crash games (Aviator, Spaceman, JetX), or other titles, it may be necessary to share session data with the game provider (such as Spribe, Pragmatic Play, or Evolution). Only data from the disputed session is shared — never full financial data.

6.3 Competent authorities

The 39gg may be legally required to share data with the relevant authorities — such as the Receita Federal, Banco Central, Ministério Público, or the Judiciary — upon formal legal request. In such cases, only the minimum data required by the request is shared, and whenever legally permitted, the user is notified.

6.4 Auditors and compliance partners

For security audit purposes, verification of compliance with regulatory obligations, and responsible gambling certifications, the 39gg may share anonymized or aggregated data with specialized partners. No identifiable data is shared for this purpose.

7. Data Retention and Deletion

The 39gg retains your personal data only for as long as necessary to fulfill the purposes described in this policy or as required by law. General retention periods are:

  • Active account data: retained for the entire period the account remains active on the 39gg.
  • Financial transaction data: retained for a minimum of 5 years after the transaction, as required by Brazilian anti-money laundering legislation.
  • KYC data (identity verification): retained for up to 5 years after account closure, in accordance with regulatory requirements.
  • Support communication records: retained for up to 2 years after account closure for the purpose of resolving potential disputes.
  • Data for marketing purposes: retained while active consent exists. After unsubscribing, removed within 30 days.

Upon account closure, personal data that is not required to be retained by law is deleted or irreversibly anonymized. You may request early deletion of your data in cases where this is legally permitted by emailing contato@39gg.click.

8. Data Security

The 39gg implements strict technical and organizational measures to protect your personal data against unauthorized access, alteration, accidental disclosure, or destruction:

  • Encryption in transit: 256-bit SSL/TLS across all communication between your device and 39gg's servers.
  • Encryption at rest: sensitive data stored on our servers is encrypted at rest using modern algorithms.
  • Hashed passwords: your password is never stored in plain text. We use secure hashing algorithms with salt, meaning even 39gg staff have no access to your original password.
  • Two-factor authentication: available to all users and strongly recommended to protect account access.
  • Internal access controls: user data is accessible only to 39gg who require this information to perform their duties, with access logs recorded.
  • Continuous monitoring: automated systems monitor suspicious access attempts, brute-force attacks, and anomalous activity around the clock.
  • Penetration testing: the platform undergoes periodic security assessments carried out by external specialists to identify and address vulnerabilities before they can be exploited.

In the event of a security incident involving users' personal data, the 39gg will follow the notification procedures set out in the LGPD, informing the ANPD and affected data subjects within the legally required timeframes, with full transparency about what occurred, which data was affected, and what measures were taken.

9. Cookies and Tracking Technologies

The 39gg uses cookies and similar technologies to ensure the platform works properly, improve the user experience, and analyze site traffic. The types of cookies used are:

9.1 Essential Cookies

Required for the basic functioning of the platform — such as keeping your session active while you play, processing transactions, and ensuring secure access. These cookies cannot be disabled without affecting the performance of the 39gg.

9.2 Performance Cookies

Used to analyze how users interact with the platform — which pages are visited most, where errors occur, and load times across different connection types (including 4G, widely used in Brazil). Data is collected in aggregate and anonymized form.

9.3 Functionality Cookies

Allow the 39gg remember your preferences — such as language, display settings, and favorite games — to offer a more personalized experience in future sessions.

9.4 Marketing Cookies

Used only with your consent, to display relevant content about 39gg on other sites you may visit. You can withdraw this consent at any time through the cookie settings, accessible via the platform's footer.

Your control: When you access the 39gg for the first time, you will see a cookie banner where you can choose which categories to accept. You can review and update your preferences at any time in the platform's cookie settings.

10. Your Rights as a Data Subject

The LGPD grants you, as a data subject, a set of rights that the 39gg is committed to respecting and facilitating. You may exercise any of them through support:

1
Right of Access

Request a copy of all personal data 39gg holds about you, presented in a clear and organized format.

2
Right of Correction

Request the correction of incomplete, inaccurate, or outdated data — such as a misspelled name or an old email address.

3
Right to Erasure

Request the deletion of your personal data, in cases where 39gg has no legal obligation to retain it.

4
Right to Data Portability

Receive your data in a structured, machine-readable format for transfer to another service provider.

5
Right to Object

Object to data processing based on legitimate interest, especially for direct marketing purposes.

6
Right to Withdraw Consent

Withdraw previously given consent for processing based on that legal basis, such as marketing communications.

7
Right to Information

Know who 39gg shares your data with, the legal basis for each processing activity, and how long your data is retained.

8
Right to Petition the ANPD

If you believe your rights are not being respected, you may file a complaint with Brazil's National Data Protection Authority (ANPD).

To exercise any of these rights, reach us via the 24/7 live chat on the site or send an email to contato@39gg.click with the subject line "LGPD Request – [your right]". The 39gg will respond within 15 business days as required by the LGPD, though in most cases the turnaround is much faster.

11. Minors

The platform 39gg is intended exclusively for users aged 18 and over. The 39gg does not intentionally collect personal data from minors. During registration, the CPF provided is verified to confirm that the holder is 18 years of age or older.

If it is found that data from a minor was inadvertently collected, that data will be deleted immediately and the account will be closed. If you are a guardian of a minor and believe they have created an account on 39gg, please contact us immediately at contato@39gg.click so we can resolve the situation as quickly as possible.

The 39gg recommends that those responsible for minors keep their devices, passwords, and Pix keys secure to prevent unauthorized access to the platform.

12. Changes to This Policy

The 39gg may update this Privacy Policy periodically to reflect changes in data processing practices, regulatory updates, or new platform features. The date of the last update is always shown at the top of this page.

When changes are material — such as updates to the purposes for which data is used or to the partners with whom we share information — the 39gg will notify users by registered email at least 7 days before changes take effect.

Continued use of the platform after the effective date of any changes constitutes acceptance of the updated policy. If you do not agree with the changes, you may request account closure before the effective date by contacting support.

Version history: Previous versions of this Privacy Policy are available upon request from 39gg. If you'd like to compare the current version with a previous one, simply send an email to contato@39gg.click with the subject line "Privacy Policy History" and include the date you're interested in.
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Privacy FAQs at 39gg

The most common questions from players about how we handle their data

No. The 39gg does not sell, rent, or share your personal data with third parties for external marketing purposes. Your data is used exclusively to provide platform services, fulfill legal obligations, and, with your consent, send communications from 39gg itself. If you receive any communication from another company claiming to have obtained your data through 39gg, contact us immediately — this is not something we do and may be a sign of a scam attempt.

To request deletion of your data, please contact 39gg via live chat (available 24/7) or send an email to contato@39gg.click with the subject line "LGPD Request – Data Deletion". We will respond within 15 business days. Important: some data must be retained by legal obligation — such as financial transaction records, which must be kept for a minimum of 5 years under anti-money laundering legislation. In such cases, we will clearly inform you which data cannot be deleted and why, and will erase everything else.

No. Your password is never stored in plain text on 39gg. We use salted cryptographic hash algorithms — meaning we store only a mathematical "fingerprint" of your password, which cannot be reversed. Not even the engineers responsible for the database have access to your original password. That's why, if you forget your password, the process is a reset (creating a new one), not a recovery of the old one. 39gg will also never ask for your password through any communication channel — if that happens, treat it as a fraud attempt and let us know immediately.

The 39gg stores your registered Pix key (CPF, email, phone number, or random key) to process your withdrawals efficiently. This information is protected by the same encryption standards applied to all sensitive data on the platform. The 39gg does not store your full banking details — such as branch, account number, and beneficiary information — beyond what is required for each transaction. Data from each completed Pix transaction is retained by legal obligation for financial audit purposes, as required by Brazilian regulations.

Upon account closure, the 39gg initiates a two-stage data cleanup process. In the first stage, data that does not need to be retained by law — such as game preferences, browsing history, and account settings — is deleted or irreversibly anonymized within 30 days. In the second stage, data that must be kept by legal requirement — such as financial transaction records and KYC documents — is retained for the periods prescribed by law (generally 5 years), but remains internally inaccessible except for compliance purposes and responses to legal requests. You will receive a confirmation email detailing which data has been deleted and which will be retained due to legal obligations.
Responsible Gambling: The 39gg also uses gameplay behavior data to identify patterns that may indicate problem gambling, with the goal of offering proactive support. To access responsible gambling tools — deposit limits, self-exclusion, and session timers — visit Responsible Gambling. Prohibited for users under 18.
Terms and Conditions: This Privacy Policy is an integral part of the Terms and Conditions of the 39gg. In the event of any conflict between this document and the Terms and Conditions regarding data protection, the interpretation most protective of the user shall prevail. Questions? Reach us via 24/7 live chat.

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