Privacy Policy of 234vip1 – How We Take Care of Your Data

1Data Controller

The controller of the personal data processed under this Privacy Policy is the 234vip1, operator of the platform available at 234vip1.best. The controller is responsible for all decisions regarding the processing of personal data of Brazilian users of the platform, in accordance with the General Data Protection Law (LGPD – Law No. 13,709/2018).

The 234vip1 Data Protection Officer (DPO) can be reached at privacidade@234vip1.best for matters specifically related to personal data processing, exercise of data subject rights, and questions about this policy.

2Personal Data We Collect

2.1 Data provided directly by you

When you register and use 234vip1, you voluntarily provide the following data:

2.2 Automatically collected data

While you use the platform, 234vip1 automatically collects the following technical data:

• Device data: device type, operating system, browser version, screen resolution
• Connection data: IP address, country of access, internet service provider
• Browsing data: pages visited, session time, clicks, betting sequence
• Cookies and identifiers: session cookies, preference cookies, device identifiers
• Location data: country and state based on IP address (we do not collect GPS location)

2.3 Betting Data and Financial History

234vip1 keeps a complete record of all bets placed, deposits, withdrawals, and bonus transactions. This history is required for the VIP Program to function, for cashback calculations, for fulfilling legal obligations, and for resolving disputes. This data is stored for a minimum of 5 years after account closure, in accordance with Brazilian legal requirements applicable to the sector.

3How We Use Your Data

234vip1 uses the personal data collected exclusively for the following purposes:

• Operating your account and services: process bets, deposits via Pix, boleto, credit/debit card, PicPay, Mercado Pago, and TED, withdrawals, and all platform features
• Identity verification (KYC): confirm the user is 18 or older, verify the CPF, and ensure each CPF has only one active account
• Fraud and money laundering prevention: monitor suspicious activity, meet financial compliance obligations, and report to authorities when required
• VIP Program and benefits: calculate points, determine VIP level, calculate and credit weekly cashback, and manage active bonuses
• Customer support: answer questions, resolve disputes, and provide support in Portuguese 24 hours a day
• Service communications: notify you about confirmed bets, processed withdrawals, VIP level changes, and important account updates
• Consent-based marketing: send promotions, bonuses, and updates only to users who have opted in to receive such communications
• Platform improvement: analyze usage patterns in an aggregated and anonymized manner to improve the user experience
• Compliance with legal obligations: comply with regulatory requirements, court orders, and requests from competent Brazilian authorities

4Legal Basis for Processing (LGPD)

234vip1 processes personal data only when there is a valid legal basis under the LGPD. The legal bases used are:

• Performance of a contract (art. 7º, V): processing required to operate the account, handle bets, process Pix payments, and withdrawals — the primary basis for most data processing activities
• Compliance with a legal obligation (art. 7º, II): identity verification (KYC), anti-money laundering, mandatory financial records, and compliance with court orders
• Legitimate interest (art. 7º, IX): fraud prevention, platform security, aggregated usage analytics to improve the service
• Consent (Art. 7, I): marketing communications by email, SMS, or push notifications – you may withdraw this consent at any time

5Data Sharing with Third Parties

5.1 Required operational partners

234vip1 shares personal data only with the following types of partners, and strictly to the extent necessary for each purpose:

• Payment processors: to process transactions via Pix (Banco Central/DICT), boleto bancário, credit/debit card, PicPay, and Mercado Pago. These partners receive only the data necessary to complete the specific transaction.
• Identity verification providers: to verify the authenticity of identity documents during the KYC process. Documents are transmitted in encrypted form and are not stored on provider servers after verification.
• Game and slots providers: to provide the catalog of over 3,000 casino games, slots, and crash games. These providers receive an anonymous session identifier, not the user's personal data.
• IT infrastructure and hosting: servers in data centers with security certifications. 234vip1 requires these partners to sign data processing agreements and maintain the same security standards as the platform.

5.2 Authorities and Legal Obligations

234vip1 may share personal data with Brazilian government, regulatory, or judicial authorities when required by law, court order, or when necessary to fulfill anti-money laundering and counter-terrorism financing obligations. In such cases, 234vip1 shares only the data required by the specific legal instrument.

5.3 What we never share

234vip1 never shares users' personal data with advertisers, data brokers, programmatic advertising platforms, or any third party for commercial purposes. This includes betting history, game preferences, deposit and withdrawal amounts, and any other identifiable user information.

6Cookies and Tracking Technologies

6.1 Types of cookies used

234vip1 uses the following types of cookies:

• Essential cookies: required for the basic operation of the platform – session authentication, bet slip, language preferences. These cannot be disabled without affecting platform functionality.
• Analytical cookies: collect aggregated data on how users navigate the platform to identify areas for improvement. Data is anonymized prior to analysis.
• Preference cookies: remember account settings such as preferred odds, favorite sports, and interface preferences.
• Security cookies: detect suspicious behavior, unauthorized access attempts, and potentially fraudulent activity.

6.2 Cookie management

You can manage cookie preferences through your browser's settings panel. Disabling non-essential cookies will not prevent you from using the platform, but may affect some personalization features. Essential cookies cannot be disabled as they are required for secure account functionality.

7Data Security

234vip1 adopts the following technical and organizational measures to protect your personal data:

• Encryption in transit: all communication between your device and 234vip1's servers uses TLS 1.3 / SSL 256-bit, the same standard used by banks like Nubank, Itaú, and Bradesco
• Encryption at rest: sensitive data such as CPF numbers, Pix keys, and banking information is stored in encrypted form in our databases
• Two-factor authentication (2FA): available to all users, strongly recommended for accounts with significant balances
• Access control: 234vip1 employees have access only to the data necessary for their specific roles, governed by a role-based permissions system
• 24/7 monitoring: automated systems monitor unauthorized access attempts, anomalous activity, and potential security incidents
• Security testing: the platform undergoes periodic penetration testing conducted by specialized third-party firms
• Secure backups: data is stored across multiple locations with automatic backups to ensure availability and recovery in the event of an incident

8Data Retention and Deletion

8.1 How long we keep your data

234vip1 retains personal data for the following periods:

• Registration and account data: for as long as the account remains active. After closure, for an additional 5 years to meet legal obligations.
• Financial history (deposits, withdrawals, bets): 5 years after the last transaction, in accordance with financial compliance requirements and Brazilian tax law.
• Identity verification documents: 5 years after account closure or after the last relevant transaction.
• Security and access logs: 12 months, automatically renewed while the account is active.
• Support communications (chat and email): 3 years, to ensure a dispute resolution history is maintained.
• Marketing data (with consent): for as long as consent remains active. Once consent is revoked, marketing data is deleted within 30 days.

8.2 Data deletion after the retention period

Once retention periods expire, data is permanently deleted or irreversibly anonymized from 234vip1's systems. Anonymized data, from which it is no longer possible to identify the individual, may be retained indefinitely for aggregated statistical analysis that helps improve the platform.

9How to Exercise Your Rights as a Data Subject

To exercise any of the rights guaranteed by the LGPD, submit a request to privacidade@234vip1.best or via live chat, providing:

• Your full name and email address registered with 234vip1
• The right you wish to exercise (access, correction, deletion, portability, etc.)
• A specific description of the request

234vip1 responds to all requests within 15 business days. For complex cases requiring additional review, the deadline may be extended by a further 15 days, with prior notice to the data subject explaining the reason. To verify the requester's identity, 234vip1 may ask for confirmation of registration details before processing the request.

10Data of Minors

234vip1 is a platform intended exclusively for users aged 18 and over. We do not intentionally collect personal data from minors. Registration requires age confirmation, and the identity verification process includes date of birth verification.

If 234vip1 determines that it has collected data from a user under 18, the account will be closed immediately, the personal data will be deleted, and any deposits made will be returned to the original payment method. If you suspect that a minor has created an account on the platform, please contact us at privacidade@234vip1.best.

11International Data Transfer

In certain situations, personal data of 234vip1 users may be processed on servers located outside Brazil – primarily by cloud infrastructure providers and international casino game providers. When this occurs, 234vip1 ensures that:

• The transfer occurs only to countries with an adequate level of data protection recognized by the ANPD, or
• The receiving partner has signed standard contractual clauses compatible with the LGPD, ensuring the same level of protection required in Brazil
• Data transferred is limited to the minimum necessary for the specific purpose
• The transfer is recorded in 234vip1's data processing activity log

12Marketing Communications

12.1 Marketing opt-in

234vip1 sends marketing communications – such as promotions, weekly bonuses, new game announcements, VIP Program offers, and Sports Betting information on the Brasileirão, Copa do Brasil, and other events – only to users who explicitly consented during registration or later through their account settings.

12.2 How to unsubscribe

You can opt out of marketing communications at any time in two ways: by clicking the "unsubscribe" link in any marketing email, or by going to the "Communication Preferences" section in your account dashboard and unchecking the marketing options. Opt-outs are processed within 48 hours. Please note that you will continue to receive essential account communications (bet confirmations, withdrawals, security alerts) even after opting out of marketing, as these are necessary for the service to function.

13Security Incidents & Data Breaches

In the event of a security incident resulting in unauthorized access, loss, or exposure of personal data, 234vip1 will follow the protocol below:

• Immediate containment: isolation of affected systems and termination of unauthorized access as soon as the incident is identified
• Impact assessment: identification of affected data, number of impacted users, and potential risk to data subjects
• ANPD notification: notification to the National Data Protection Authority (ANPD) within the timeframe required by applicable regulations
• User notification: email notification to all affected users, describing what happened, which data was impacted, and what steps are being taken
• Corrective measures: implementation of technical and organizational fixes to prevent recurrence

14Changes to this Privacy Policy

234vip1 may update this Privacy Policy periodically to reflect changes in Brazilian legislation, data processing practices, or the services offered. Significant changes are communicated by email at least 7 days before taking effect. Minor changes, such as formatting corrections or clarifications that do not alter substantive content, may be made without prior notice.

The current version of this policy is always the one published at 234vip1.best/privacy-policy, with the last updated date shown at the top. Continued use of the platform after the effective date of the new terms constitutes acceptance of the changes. If you do not agree with the new terms, you may exercise your right to close your account before the effective date.

15Contact & Data Protection Officer (DPO)

For matters related to privacy, data protection, and exercising your LGPD rights, please contact 234vip1's Data Protection Officer (DPO):

• Privacy email: privacidade@234vip1.best
• General support: suporte@234vip1.best
• Live chat: available at 234vip1.best, 24 hours a day, 7 days a week

For complaints about data processing that are not resolved by 234vip1 within a reasonable timeframe, you may contact the National Data Protection Authority (ANPD), as provided under the LGPD. More information about the ANPD is available through the official channels of the Brazilian federal government.

For matters related to responsible gambling, limits, and self-exclusion, visit our Responsible Gambling. To understand the platform's terms of use, please review our Terms and Conditions.