922be Privacy Policy – Your Data Protection

1. Who Controls Your Data

For the purposes of the General Data Protection Law (LGPD — Law No. 13,709/2018), the controller of personal data collected through the platform 922be (accessible at https://922be.com) is 922be itself, which is responsible for determining the purposes and means of processing data for users registered in Brazil.

This Privacy Policy applies to all 922be users, including site visitors, registered users, active bettors, and anyone who interacts with the platform in any way — whether via mobile browser, desktop, or any other internet-connected device.

Continued use of the 922be platform constitutes acceptance of this Policy. If you have any questions, concerns, or wish to exercise any right granted by the LGPD, please refer to section 13 (Contact & DPO) at the end of this document.

2. What Data We Collect

922be collects different categories of data depending on how you use the platform. The main types of information we process are described below:

2.1 Registration Data

When you create an account on 922be, we ask for the following information:

• Full legal name, as it appears on an official ID;
• CPF (Cadastro de Pessoas Físicas) — required for identity verification and compliance with Brazilian regulations;
• Date of birth — to confirm the user is at least 18 years old;
• Email address and mobile phone number;
• Full residential address (for verification and any necessary correspondence).

2.2 Identity Verification Data (KYC)

During the mandatory verification process prior to your first withdrawal, we may request:

• Scanned copy of a photo ID (national ID card, driver's license, or passport);
• Proof of address issued within the last 90 days;
• Selfie holding your ID document, when required for identity confirmation;
• Proof of payment method used (bank statement, Pix receipt, etc.).

2.3 Financial Data

To process deposits and withdrawals, we collect information related to your chosen payment method:

• Pix key (CPF, email, mobile number, or random key) for Pix transactions;
• Credit and debit card data is processed directly by the card networks (Visa, Mastercard, Elo) — 922be does not store full card numbers on its servers;
• Bank account details for TED transfers at banks such as Nubank, Itaú, Bradesco, and Banco do Brasil;
• History of deposits and withdrawals made on the platform.

2.4 Platform Usage Data

When you browse and use 922be, we automatically collect:

• IP address and approximate location data;
• Device type, operating system, and browser used;
• Pages visited, session duration, and actions taken on the platform;
• Full history of bets placed, casino games, and crash games played;
• Sports and game mode preferences.

2.5 Communication Data

When you contact 922be support via live chat, email, or WhatsApp, we record the content of those interactions for quality assurance, training, and dispute resolution purposes.

3. How We Use Your Data

922be uses the data collected exclusively for the purposes described below, all of which are necessary for the proper operation of the platform and to meet legal obligations:

• Account operation: creation, maintenance, and management of your 922be user account;
• Bet and game processing: recording, settlement, and display of Sports Betting results, crash games, and casino game outcomes;
• Financial transactions: processing of deposits via Pix, card, PicPay, Mercado Pago, boleto, and TED, as well as withdrawals to verified accounts;
• Identity verification (KYC): compliance with regulatory obligations and anti-money laundering requirements;
• Security and fraud prevention: monitoring of suspicious activity, detection of multiple accounts, and protection against platform misuse;
• Responsible gambling: identification of gameplay patterns that may indicate problem gambling behavior and activation of player protection tools;
• Customer support: resolution of inquiries, disputes, and requests submitted through 922be's support channels;
• Platform communications: sending transactional emails (registration confirmation, deposit confirmation, security alerts) and communications about bonuses and promotions, when you opt in to receive them;
• Platform improvement: analysis of aggregated and anonymized usage data to improve the user experience, site performance, and the development of new features;
• Legal compliance: compliance with obligations imposed by Brazilian law, including the LGPD, Central Bank regulations, and any applicable judicial or regulatory orders.

922be does not use your personal data for purposes not listed above without informing you in advance and, where required, obtaining your express consent.

4. Legal Basis for Processing (LGPD)

Every data processing operation carried out by 922be is based on at least one of the legal grounds set out in the LGPD (art. 7). The bases used are:

• Contract performance (art. 7, V): processing is necessary to fulfill the contract entered into between you and 922be at the time of registration — including the operation of bets, payment processing, and account management;
• Compliance with a legal obligation (art. 7, II): identity verification (KYC), anti-money laundering compliance, and fulfillment of requests from competent authorities;
• Legitimate interest (art. 7, IX): fraud prevention, platform security, detection of multiple accounts, and improvement of the user experience, provided these interests do not override your fundamental rights and freedoms;
• Consent (art. 7, I): sending marketing communications and promotions by email or SMS. You may withdraw consent at any time by clicking the unsubscribe link included in every communication.

5. Sharing Data with Third Parties

922be does not sell, rent, or share your personal data with third parties for commercial purposes. Data sharing occurs only in the specific situations described below, always under a confidentiality agreement and with the same level of responsibility we apply internally:

5.1 Operational Partners

To operate the platform, we share data with:

• Payment providers: Pix operators, Visa, Mastercard, Elo, PicPay, Mercado Pago, and partner banks — only the data strictly necessary to process each transaction;
• Game providers: Spribe, SmartSoft, Pragmatic Play, Evoplay, and others — anonymized session IDs for operating crash games and slots, with no full personal data;
• Identity verification services: KYC platforms that assist in validating documents submitted by users;
• Cloud infrastructure: servers and hosting services that store data with encryption at rest and in transit.

5.2 Authorities and Legal Obligations

922be may disclose personal data when required by law, court order, request from a competent regulatory authority, or in the context of money laundering and financial fraud investigations. In such cases, we disclose only the minimum information necessary to comply with the legal requirement.

5.3 What We Don't Do

• We do not sell user lists or betting profiles to advertising companies;
• We do not share your CPF, documents, or banking details with marketing partners;
• We do not allow third parties to use your data for any purpose other than those for which it was originally collected by 922be.

6. International Data Transfers

Some service providers used by 922be — such as cloud infrastructure and game providers — may process data on servers located outside Brazil. When this occurs, 922be ensures that the transfer is carried out based on one of the safeguards set out in the LGPD:

• Countries or organizations that provide an adequate level of data protection, as assessed by the National Data Protection Authority (ANPD);
• Standard contractual clauses requiring the recipient to maintain the same level of protection required under Brazilian law;
• Internationally recognized information security certifications (ISO 27001, SOC 2).

Under no circumstances does an international data transfer reduce the rights you hold as a data subject under the LGPD. You may request information about the countries and partners involved by contacting the 922be DPO.

7. Data Retention and Deletion

922be retains your data for as long as necessary to fulfill the purposes described in this policy, in accordance with the minimum retention periods required by Brazilian law:

• Active account data: retained for as long as the account remains active or as long as necessary to provide the services;
• Financial and betting data: retained for a minimum of 5 years after account closure, as required by anti-money laundering regulations and Brazilian tax obligations;
• KYC data (documents): retained for a minimum of 5 years after the last transaction, as required by law;
• Communication records (support logs): retained for 2 years for quality assurance and dispute resolution purposes;
• Cookie and browsing data: retained according to cookie type (see section 9).

7.1 Data Deletion

After account closure and once all mandatory legal retention periods have been met, 922be will delete or anonymize your personal data. You may request early deletion of data not subject to a legal retention obligation by contacting support. Your request will be reviewed and answered within 15 business days.

8. Data Security

922be employs a comprehensive set of technical and organizational measures to protect your data against unauthorized access, loss, alteration, or improper disclosure:

8.1 Technical Measures

• 256-bit SSL/TLS Encryption across all communication between the user's device and 922be's servers;
• Encryption at rest for data stored on servers — particularly KYC documents and financial data;
• Two-factor authentication (2FA) available to all users as an additional layer of account protection;
• Tokenization of payment data — card numbers are replaced with tokens during transmission, and the full number is never stored on 922be's servers;
• Continuous monitoring of suspicious access attempts, intrusion attempts, and anomalous activity on the system.

8.2 Organizational Measures

• Access to personal data restricted to employees with a proven operational need (principle of least privilege);
• Regular team training on data protection and information security;
• Confidentiality agreements with all partners that process data on behalf of 922be;
• A security incident response plan, including notification to the ANPD and affected users in the event of a significant breach, as required by the LGPD.

9. Cookies and Tracking Technologies

922be uses cookies and similar technologies to ensure the platform functions correctly, improve the user experience, and analyze site performance. Below we explain the types of cookies we use:

9.1 Essential Cookies

Required for the platform's core functionality — such as keeping you logged into your account, processing bets, and securing your sessions. These cookies cannot be disabled without affecting how the platform works. Retention period: session duration or up to 30 days to keep your login active.

9.2 Performance & Analytics Cookies

Used to analyze how users navigate 922be — which pages receive the most visits, where navigation issues occur, and how the site can be improved. Data is collected in aggregated and anonymized form. Retention period: up to 13 months.

9.3 Functionality Cookies

Allow the platform to remember your preferences — such as language, preferred payment method, and betting settings. Retention period: up to 12 months.

9.4 How to Manage Your Cookies

You can manage, disable, or delete cookies at any time in your browser settings (Chrome, Safari, Firefox). Keep in mind that disabling essential cookies may prevent you from accessing your 922be account. On mobile devices, cookie management options are available in the settings of your installed browser.

10. Your Rights as a Data Subject (LGPD)

The LGPD grants you, as the data subject, a set of rights that can be exercised at any time with 922be. See below what you can request:

To exercise any of these rights, please contact the 922be DPO at privacidade@922be.com or via the platform's live chat. Your request will be reviewed and answered within 15 business days, as provided under the LGPD.

11. Minors

The 922be platform is intended exclusively for individuals aged 18 years of age or older. We do not intentionally collect or process personal data from minors. The CPF provided at registration is used to verify the user's age against the Brazilian Federal Revenue Service (Receita Federal) database.

If 922be identifies that data from a minor was collected — whether due to false information provided during registration or unauthorized use of an adult's account — the data will be deleted immediately, the account will be closed, and access will be permanently blocked.

Parents or guardians who identify unauthorized use of the platform by a minor in their care should contact 922be support immediately via live chat or at contato@922be.com so that the appropriate measures can be taken with the utmost urgency.

12. Changes to this Policy

922be may update this Privacy Policy periodically to reflect changes in data processing practices, new legal requirements, or platform improvements. Material changes will be communicated to registered users by email and/or via a prominent notice on the site at least 7 days before taking effect.

The "last updated" date at the top of this page indicates when the current version was published. We recommend reviewing this Policy periodically to stay informed about how 922be protects your data. Continued use of the platform after a new version takes effect constitutes acceptance of the updated terms.

If you disagree with any material change to this Policy, you have the right to close your account and request deletion of data not subject to a legal retention obligation, as described in section 7.

13. Contact, DPO & Complaints

To exercise your rights as a data subject, ask questions about this Privacy Policy, or file a complaint, you can reach 922be through the channels below — all available 24 hours a day, 7 days a week, in Brazilian Portuguese:

• DPO (Data Protection Officer) email: privacidade@922be.com — for formal requests related to rights under the LGPD;
• General support email: contato@922be.com — for general questions about privacy and data use;
• Live chat: available directly on the 922be platform, with a target response time of under 2 minutes;
• WhatsApp: available in the platform chat for registered users.

922be has appointed a Data Protection Officer (DPO) responsible for overseeing LGPD compliance and handling data subject requests. If your request is not answered within the expected timeframe, or if you believe your rights have not been properly respected, you may file a complaint directly with the National Data Protection Authority (ANPD), pursuant to art. 18, § 1 of the LGPD.