Your Privacy Matters
at 99s9

1 Introduction

99s9 operates the online casino and sports betting platform accessible at 99s9.io (the "Platform"). We are committed to protecting the privacy of every individual who registers an account, visits the platform, or interacts with our services in any way.

This Privacy Policy sets out, in clear and formal terms, what personal data 99s9 collects from players, the purposes for which that data is used, the circumstances under which it may be shared with third parties, and the rights available to you as a data subject. This policy applies to all data processing activities carried out by 99s9 in connection with the operation of the platform.

By registering an account on the 99s9 platform, you confirm that you have read and understood this Privacy Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree with any part of this policy, you must not register an account or use the platform.

This Privacy Policy should be read alongside the 99s9 Terms & Conditions, which govern your use of the platform more broadly. References to "we", "us", and "our" throughout this policy refer to 99s9.

2 Data We Collect

99s9 collects personal data from players through a variety of means, including direct input during registration, automated collection during platform use, and information provided by third-party partners where applicable. The categories of personal data we collect include the following:

2.1 Registration Data

• Full legal name
• Date of birth
• Email address
• Mobile phone number
• Residential address (city and district, such as Dhaka, Chittagong, Sylhet, or Khulna)
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued identification documents (National Identity Card, passport, or driving licence)
• Proof of address documentation (utility bill, bank statement, or similar)
• Selfie or liveness verification image where required by our KYC provider

2.3 Financial Data

• Transaction history (deposits and withdrawals), including amounts in BDT (৳)
• Payment method type (e.g., bKash, Nagad, Rocket, Upay, Visa, Mastercard)
• Mobile banking account numbers associated with bKash, Nagad, or Rocket transactions (used solely for transaction matching and anti-fraud purposes)

2.4 Gaming Activity Data

• Games played, bet amounts, session durations, and win/loss records
• Betting preferences, favourite game categories, and interaction patterns with the platform
• Bonus and promotion usage history

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Access timestamps and navigation paths within the platform

2.6 Communications Data

• Content of support enquiries and formal complaints submitted to the 99s9 support team
• Records of email correspondence between you and 99s9
• Live chat transcripts where the live chat feature is used

The table below summarises the primary data categories, the collection method, and the legal basis on which 99s9 processes each category:

3 How We Use Your Data

99s9 uses the personal data it collects for specific, documented purposes only. We do not process personal data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes of our data processing are as follows:

• Account operation: To create and manage your player account, authenticate your identity at login, and enable you to access all platform features.
• Transaction processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods, and to maintain accurate financial records.
• Identity verification: To verify your age (21+ requirement) and identity in compliance with our Know Your Customer (KYC) obligations, and to prevent underage gambling.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, duplicate accounts, and other security threats to the platform and its players.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behaviour, to enforce deposit limits and self-exclusion requests, and to comply with responsible gaming obligations.
• Customer support: To respond to enquiries, resolve disputes, process complaints, and provide assistance via our 24/7 English-language support service.
• Platform improvement: To analyse aggregated, anonymised usage data to improve the performance, design, and content of the 99s9 platform.
• Legal compliance: To meet our obligations under applicable law, including responding to lawful requests from regulatory or law enforcement authorities.
• Marketing communications: Where you have given explicit consent, to send you promotional offers, bonus notifications, and platform updates by email or SMS. You may withdraw this consent at any time (see Section 12).

4 Data Sharing

99s9 does not sell, rent, or otherwise transfer your personal data to unaffiliated third parties for their own marketing or commercial purposes. Your data may be shared with the following categories of third parties only where strictly necessary to deliver our services or to comply with applicable law:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, Visa, and Mastercard — solely to process deposit and withdrawal transactions.
• KYC and identity verification providers: Third-party identity verification services engaged by 99s9 to validate player identity documents and perform age verification checks.
• Fraud prevention and AML providers: Specialist third-party services used to screen transactions and player activity against fraud databases and anti-money-laundering watchlists.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive session tokens or player identifiers necessary to deliver their game content within the 99s9 platform. These providers operate under their own privacy and data protection frameworks.
• Legal and regulatory authorities: Where required by applicable law, court order, or a lawful request from a government or regulatory body, 99s9 may disclose personal data without prior notice to you.

All third-party service providers that process personal data on behalf of 99s9 are required to implement appropriate technical and organisational security measures and to handle that data in accordance with applicable data protection standards.

5 Cookies & Tracking Technologies

99s9 uses cookies and similar tracking technologies to operate the platform, maintain session state, analyse usage patterns, and (where you have consented) deliver relevant promotional content. The following types of cookies are used on the platform:

You can manage or withdraw your cookie consent at any time through your browser settings. Please note that disabling strictly necessary cookies may impair the functionality of the 99s9 platform, including your ability to log in and place bets.

6 Data Retention

99s9 retains personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. The following retention principles apply:

• Active accounts: Personal data is retained for the full duration that your account remains active on the platform.
• Closed accounts: Following account closure — whether initiated by you or by 99s9 — personal data is retained for a minimum of five (5) years to comply with financial record-keeping and anti-money-laundering obligations.
• KYC documents: Identity verification documents are retained for a minimum period consistent with applicable legal requirements, which in most cases is at least five (5) years from the date of verification.
• Transaction records: All deposit and withdrawal records are retained for a minimum of five (5) years from the date of the transaction.
• Support communications: Records of support interactions are retained for three (3) years from the date of the last interaction, or longer if the interaction relates to an unresolved dispute.
• Marketing data: Where consent to marketing communications has been withdrawn, your email address and contact preferences will be suppressed from marketing lists immediately and retained in a suppression list to ensure we do not contact you again.

After the applicable retention period has expired, personal data is securely deleted or anonymised so that it can no longer be linked to an individual player.

7 Data Security

99s9 implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption applied to all data in transit between your device and 99s9 servers.
• Password hashing using industry-standard cryptographic algorithms. Your account password is never stored in plain text and is never accessible to 99s9 support staff.
• Access controls: Internal access to personal data is restricted to authorised 99s9 personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Intrusion detection and monitoring: 99s9 maintains continuous monitoring of its systems to detect and respond to security threats in real time.
• Regular security assessments: The platform undergoes periodic security reviews and penetration testing to identify and address vulnerabilities.
• Incident response: In the event of a data breach that is likely to result in a risk to your rights and freedoms, 99s9 will notify affected players without undue delay and in accordance with applicable law.

8 Your Data Rights

As a player whose personal data is processed by 99s9, you have a number of rights in relation to that data. These rights are set out below. To exercise any of these rights, please contact our support team at [email protected] with your registered username and the specific right you wish to exercise.

• Right of access: You have the right to request a copy of the personal data that 99s9 holds about you. We will respond to verified access requests within 30 days.
• Right of rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account information directly through the account settings section of the platform.
• Right to erasure: In certain circumstances, you have the right to request that we delete your personal data. Please note that this right is not absolute — we may be required to retain certain data for legal or regulatory compliance purposes (see Section 6).
• Right to restriction: You may request that we restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of our legitimate grounds.
• Right to data portability: Where processing is based on your consent or on a contract with you, you have the right to receive the personal data you have provided to us in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to processing of your personal data where that processing is based on legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

99s9 will respond to all data rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 60 days, in which case you will be notified of the extension and the reasons for it.

9 Minors

The 99s9 platform is strictly for adults aged 21 and above. 99s9 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under the age of 21, we will immediately close the associated account, void all activity, and delete the personal data collected from that individual.

If you are a parent or guardian and you believe that a minor has registered on the 99s9 platform or has accessed the platform using your account, please contact our support team immediately at [email protected]. We will investigate and take appropriate action without delay.

10 Third-Party Links & Services

The 99s9 platform may contain references to or integrations with third-party services, including game content studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These third-party providers operate under their own privacy policies and data protection frameworks, which are independent of this Privacy Policy.

99s9 is not responsible for the privacy practices, data handling procedures, or content of any third-party service provider. When your personal data is passed to a game studio or payment provider as part of delivering the platform's services, that transfer is governed by the contractual data processing agreements in place between 99s9 and the relevant provider.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the 99s9 platform, particularly the privacy notices of your payment provider (e.g., bKash, Nagad, or Rocket) in relation to the handling of your mobile banking transaction data.

11 International Data Transfers

The 99s9 platform primarily serves players based in Bangladesh. However, some of the third-party service providers engaged by 99s9 — including KYC verification providers, fraud prevention services, and game content studios — may process personal data in jurisdictions outside Bangladesh.

Where personal data is transferred to a third country, 99s9 takes steps to ensure that appropriate safeguards are in place to protect your data. These safeguards may include:

• Contractual clauses that require the recipient to protect the data to a standard equivalent to the protections in place under this Privacy Policy.
• Engaging only with third-party providers that maintain recognised international security certifications or that operate within jurisdictions with an adequacy determination.
• Limiting the scope of data transferred internationally to the minimum necessary for the specific service being provided.

By registering an account on the 99s9 platform, you acknowledge that your personal data may be processed in jurisdictions outside Bangladesh and that 99s9 will take reasonable steps to ensure that such processing is subject to appropriate protections.

12 Marketing Communications

99s9 may send you promotional emails, SMS notifications, and in-platform messages about bonuses, new games, seasonal promotions (such as Eid, Pohela Boishakh, and BPL season offers), and platform updates — but only where you have provided explicit consent to receive such communications during the registration process or via your account settings.

You have the right to withdraw your marketing consent at any time. To do so, you may:

• Click the unsubscribe link included in any marketing email sent by 99s9.
• Update your notification preferences in the account settings section of the platform.
• Contact our support team at [email protected] and request removal from marketing communications.

Please note that withdrawing marketing consent does not affect the delivery of transactional communications — such as deposit confirmations, withdrawal receipts, password reset notifications, and security alerts — which are sent as necessary for the operation of your account and cannot be opted out of.

13 Amendments to This Policy

99s9 reserves the right to update or revise this Privacy Policy at any time. The most current version of the Privacy Policy will always be published on this page, with the effective date clearly stated at the top. We recommend that you review this page periodically to stay informed of any changes.

Where changes to this Privacy Policy are material — meaning they significantly affect how we use your personal data or the rights available to you — 99s9 will notify registered players by email to the address held on their account at least 7 days before the revised policy takes effect.

Your continued use of the 99s9 platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree to the revised policy, you must cease using the platform and request account closure before the effective date.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which 99s9 processes your personal data, please contact our support team using the details below. All privacy-related communications should be submitted in English.

Please include your registered username and the email address associated with your account in all privacy-related correspondence so that our team can locate your records efficiently. Do not include your password or full payment account numbers in any correspondence — 99s9 does not require this information to process a privacy request.