234vi Privacy Policy – Data Protection and LGPD

1. Introduction and Data Controller

This Privacy Policy describes how the 234vi ("Platform", "we", or "234vi") collects, uses, stores, shares, and protects the personal data of users ("you" or "data subject") in accordance with the General Personal Data Protection Law (LGPD — Law No. 13.709/2018) and other applicable regulations.

The 234vi is the controller of the personal data processed under this policy. This means we are responsible for making decisions about the purposes and means of processing your data. For privacy and data protection inquiries, you can reach us at contato@234vi.net.

By creating an account, using any feature of the platform, or simply browsing the site, you acknowledge that you have read this policy and understand how your data will be handled. If you disagree with any aspect of this policy, we recommend contacting our support team before using the platform.

2. Personal Data We Collect

The 234vi collects different categories of personal data depending on how you use the platform. We only collect what is necessary for the purposes described in this policy — there is no excessive or speculative collection of information.

2.1. Registration Data

When you create your account at 234vi, we collect the information needed to identify you and operate the platform securely:

• Full name;
• CPF (Cadastro de Pessoa Física);
• Date of birth — for age verification (18+);
• Email address;
• Mobile phone number;
• Full residential address (required for KYC verification).

2.2. Identity Verification Data (KYC)

To comply with regulatory obligations for anti-money laundering and counter-terrorism financing, the 234vi may request:

• Copy of a government-issued photo ID (RG or CNH);
• Recent proof of address (utility bill, phone bill, or bank statement);
• Selfie with your ID document for identity confirmation;
• Proof of ownership of the payment method in specific cases.

2.3. Financial Data

To process deposits and withdrawals, we collect information related to the financial transactions carried out on the platform:

• Pix key used (CPF, email, phone number, or random key);
• Bank transfer details for TED transfers (bank, branch, account number — never your banking password);
• History of deposits, withdrawals, and bets placed on the 234vi;
• Credit or debit card data (processed by a PCI DSS-certified gateway — the 234vi does not store full card numbers).

2.4. Platform Usage Data

By browsing and using the 234vi, we automatically collect information about your behavior on the platform:

• IP address and approximate location;
• Device type, operating system, and browser;
• Pages visited, session duration, and browsing patterns;
• Betting history, games played, and interactions with platform features;
• Access logs with date, time, and IP address.

3. Data Processing Purposes

The 234vi uses your personal data exclusively for legitimate, necessary, and proportionate purposes. The table below summarizes the main purposes and their legal bases:

4. Sharing Data with Third Parties

The 234vi does not sell your personal data. Period. Sharing only occurs in the specific, necessary situations described below, always with appropriate protection safeguards:

4.1. Service Providers (Processors)

We share data with companies that provide services on our behalf, always under contracts that ensure data is handled appropriately in accordance with the LGPD:

• Payment gateways: to process transactions via Pix, boleto bancário, credit/debit card, PicPay, and Mercado Pago. These partners are PCI DSS certified and operate under their own security policies;
• Identity verification (KYC) providers: companies specialized in document validation and biometrics, operating under regulatory authorization in Brazil;
• Live Casino game providers: live casino games, slots, and crash games are provided by internationally certified suppliers, who receive only the data necessary to operate the games;
• IT Infrastructure: hosting providers, CDN, and security services that ensure the availability and protection of the platform.

4.2. Authorities and Legal Obligations

The 234vi may share data with government authorities, regulatory bodies, and law enforcement when required by law or court order. This includes:

• Suspicious transaction reports filed with COAF (Conselho de Controle de Atividades Financeiras);
• Compliance with court orders and requests from the Ministério Público;
• Tax information required by the Receita Federal do Brasil.

4.3. What We Never Do

The 234vi never shares your personal data with:

• Advertising companies for targeting purposes on other platforms;
• Data brokers;
• Other competing betting platforms or casinos;
• Third parties without an adequate data protection agreement.

5. Cookies and Tracking Technologies

The 234vi uses cookies and similar technologies to ensure the platform functions correctly, personalize the experience, and collect aggregated usage data. This section explains what we use and why.

5.1. What Are Cookies

Cookies are small text files stored in your browser or device when you visit a website. They allow the platform to recognize your device on subsequent visits, keeping your session information and preferences intact.

5.2. Types of Cookies Used by 234vi

• Essential cookies: required for the platform's basic operation — authentication, session management, and security. They cannot be disabled without impairing your use of the platform;
• Performance cookies: collect information about how you use 234vi to help identify errors and improve performance. Data is aggregated and anonymized;
• Functionality cookies: store your preferences, such as language and interface settings, to personalize your experience;
• Analytical cookies: allow us to understand aggregate user behavior on the platform to guide product improvements. Data is handled anonymously.

5.3. Cookie Management

You can manage or block cookies through your browser settings. Most modern browsers (Chrome, Firefox, Safari, Edge) let you view and delete stored cookies. Note that blocking essential cookies may prevent login and other features of the 234vi.

The first time you access the platform, you will see a notice about cookie use with management options. Your preference is stored for 12 months and can be changed at any time.

6. Data Retention and Deletion

The 234vi retains your personal data only for as long as necessary for the purposes for which it was collected, always respecting the minimum retention periods required by Brazilian law.

6.1. Retention Periods

• Active account data: retained for as long as your account remains active at 234vi;
• Financial data and betting records: retained for a minimum of 5 years after the last transaction, as required by tax and anti-money laundering legislation;
• Identity verification data (KYC): retained for a minimum of 5 years after account closure;
• Access and security logs: retained for 6 months, in accordance with the Marco Civil da Internet (Law No. 12.965/2014);
• Support communications: retained for 2 years for dispute resolution purposes.

6.2. Account Closure and Data Deletion

When you request account closure at 234vi, data is anonymized or deleted, except for data that must be retained to fulfill legal obligations. Data subject to retention is kept in a restricted environment and used solely for the purpose of meeting that legal obligation.

The data deletion process is irreversible. We recommend downloading your betting and transaction history before requesting account closure, in case you need that information for personal or tax purposes.

7. Data Security

The 234vi implements robust technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or accidental or unlawful destruction.

7.1. Technical Measures

• Encryption in transit: all communications between your device and our servers are protected by 256-bit SSL/TLS;
• Encryption at rest: sensitive data stored on our servers is encrypted;
• Two-factor authentication (2FA): available to all users of the 234vi, recommended for accounts with a transaction history;
• Continuous monitoring: intrusion and anomaly detection system operating 24 hours a day;
• Penetration testing: the platform undergoes regular security audits conducted by specialized teams;
• Internal access control: access to user data is role-restricted and recorded in auditable logs.

7.2. Incident Response

In the event of a data breach that poses significant risk to data subjects, the 234vi is committed to:

1. Identify and contain the incident as quickly as possible;
2. Notify the National Data Protection Authority (ANPD) within 72 hours of confirming the incident, as required by the LGPD;
3. Notifying affected account holders by email with clear information about what happened, which data was involved, and what steps were taken;
4. Document the incident and remediation actions for audit purposes.

8. Your Rights as a Data Subject (LGPD)

The LGPD grants you, as a personal data subject, a comprehensive set of rights. At the 234vi, all of these rights can be exercised by emailing contato@234vi.net with the subject line "LGPD Request". We respond within 15 business days.

9. Data of Minors

The 234vi does not provide services to individuals under 18 and does not knowingly collect personal data from children or adolescents. Platform registration requires confirmation of legal age, verified by CPF and identity documentation.

If we become aware that data from a minor has been inadvertently collected, that data will be deleted immediately and the associated account will be closed. Parents or guardians who identify misuse of the platform by a minor should contact our support team at contato@234vi.net so the matter can be handled as a priority.

Processing data from individuals under 18 constitutes a serious violation of the Terms and Conditions of the 234vi and may result in notification to the relevant authorities.

10. International Data Transfers

Some of the service providers used by the 234vi — such as internationally certified Live Casino game providers and cloud infrastructure services — may process data on servers located outside Brazil.

When this occurs, the 234vi ensures that the transfer is carried out in compliance with art. 33 of the LGPD, using mechanisms such as:

• Contracts with specific data protection clauses;
• Transfers only to countries with a level of data protection equivalent to Brazil's, as assessed by the ANPD;
• Compliance certifications and seals internationally recognized by the receiving partners.

Under no circumstances will users' critical financial data — such as Pix key details or banking information for withdrawals — be transferred to servers outside Brazil without the appropriate security controls in place.

11. Privacy and Responsible Gambling

The 234vi uses gameplay behavior data — betting frequency, wager amounts, session times, and deposit patterns — to identify users who may be developing problematic gambling habits. This processing is based on the legitimate interest of protecting user well-being and is an industry-recommended practice.

When our system or support team identifies risk patterns, we may proactively reach out to provide information about responsible gambling tools available on the platform, such as deposit limits, breaks, and self-exclusion. This outreach is never commercial in nature — it is always focused on user well-being.

Data used for responsible gambling monitoring is treated with the utmost confidentiality and is not shared with third parties for any purpose. To learn more about the available tools, visit our Responsible Gambling.

12. Changes to This Privacy Policy

The 234vi may update this Privacy Policy periodically to reflect changes in our services, applicable legislation, or industry practices. The process for communicating relevant updates is:

1. Email notification to all users with an active account, with a minimum of 15 days' notice for material changes;
2. A prominent update notification displayed on the platform during the transition period;
3. Updating the "Last updated" date at the top of this document;
4. Previous versions of this policy are kept available for review upon request.

Continued use of the platform after a new version of this policy takes effect constitutes acceptance of the updated terms. If you do not agree with the changes, you may request account closure before the effective date, with no penalties applied to your real BRL balance.

13. How to Exercise Your Rights and Contact the DPO

To exercise any right under the LGPD or to clarify questions about how your personal data is handled by the 234vi, you can reach us through the following channels:

• Email: contato@234vi.net — use the subject line "LGPD Request" and describe in detail the right you wish to exercise. We respond within 15 business days;
• Live chat: available directly on the platform with a response time of under 5 minutes for general inquiries. For formal rights requests, the email channel is recommended to maintain a record;
• WhatsApp: available for urgent account security issues.

If you are not satisfied with the response from the 234vi regarding the processing of your data, you have the right to file a complaint directly with the Autoridade Nacional de Proteção de Dados (ANPD), as provided in art. 18, § 1º, of the LGPD. Before contacting the ANPD, we recommend trying to resolve the matter directly with us — our team handles the vast majority of cases within the legal timeframe.