99ld Privacy Policy

1. Introduction

99ld ("we", "our", or "us") is committed to protecting the privacy and security of every person who uses our platform at 99ld.app. This Privacy Policy describes the personal information we collect from users in Bangladesh and elsewhere, the purposes for which that information is used, the circumstances under which it may be disclosed to third parties, the measures we take to keep it secure, and the rights available to you with respect to your own data.

By registering an account on 99ld or by continuing to use the Platform after this Privacy Policy has been published, you consent to the collection and use of your personal information as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and may request account closure by contacting [email protected].

2. Our Privacy Principles

3. Information We Collect

99ld collects personal information in two ways: information you provide to us directly when using the Platform, and information collected automatically as a result of your use of the Platform. The categories of personal information we may hold about you include:

• Identity and contact information — full name, date of birth, residential address, email address, and phone number provided at registration or during KYC verification.
• Financial information — deposit and withdrawal transaction records, payment method identifiers (such as the last four digits of a card or the mobile wallet number used), and account balance history. We do not store full card numbers or full mobile wallet PINs.
• Gaming activity — details of wagers placed, games played, bet amounts, win and loss records, session durations, and bonus usage history. This data is used for account management, dispute resolution, and responsible gaming monitoring.
• Technical data — IP address, device type, operating system, browser type and version, screen resolution, and referral URL. This data is collected automatically and used for security monitoring, fraud detection, and Platform performance optimisation.
• Communications data — records of any correspondence between you and the 99ld support team, including live chat transcripts, email threads, and support ticket history. These records are retained to help resolve disputes and to improve our customer service quality.

Where technically feasible, 99ld collects only the minimum personal data necessary for each stated purpose. We do not use facial recognition, biometric scanning, or any form of automated profiling to make decisions that have legal or significant effects on you without human review.

4. How We Use Your Information

99ld uses the personal information we collect for the following specific purposes. We do not use your data for any purpose that is incompatible with those listed below without first obtaining your explicit consent:

• Account creation and management — to register your account, verify your identity and age, manage your account settings, and communicate with you about your account status.
• Payment processing — to process deposits and withdrawals, verify payment method ownership, and maintain accurate financial records as required by anti-money laundering regulations.
• Service delivery and improvement — to provide access to games and betting markets, personalise your experience based on your activity patterns, and improve Platform features based on aggregated usage data.
• Responsible gaming — to monitor gaming patterns, identify signs of problem gambling behaviour, enforce deposit limits and self-exclusion requests, and fulfil our duty of care to players.
• Security and fraud prevention — to detect, investigate, and prevent fraudulent transactions, multiple account abuse, bonus abuse, collusion, money laundering, and other prohibited conduct listed in our Terms & Conditions.
• Legal compliance — to comply with applicable laws and regulations, respond to lawful requests from regulatory authorities, law enforcement agencies, or courts, and to retain records as required by applicable anti-money laundering and financial crime legislation.

5. Legal Basis for Processing

99ld processes your personal data on one or more of the following legal bases, depending on the specific purpose of the processing:

• Contractual necessity — processing that is necessary to perform the agreement between you and 99ld, including account registration, payment processing, and service delivery.
• Legal obligation — processing required to comply with applicable law, including KYC identity verification, anti-money laundering record-keeping, and co-operating with lawful regulatory or law enforcement requests.
• Legitimate interests — processing for purposes such as fraud prevention, Platform security, responsible gaming monitoring, and service improvement, where those interests are not overridden by your fundamental rights and freedoms.

6. Cookies and Tracking Technologies

99ld uses cookies and similar tracking technologies (such as local storage and session tokens) to operate the Platform, maintain your login session, remember your preferences, and monitor Platform performance. Strictly necessary cookies — those required for the Platform to function — are placed automatically. These cannot be disabled without breaking core Platform functionality such as login state and game session continuity.

Performance and analytics cookies help us understand how users navigate the Platform, which pages are most visited, and where technical issues occur. These cookies collect data in aggregate form and do not identify you personally. You may opt out of non-essential cookies by adjusting your browser settings. Please note that disabling certain cookies may affect your experience on the Platform. We do not use third-party advertising cookies or behavioural retargeting cookies.

7. Sharing Your Information

99ld does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your personal data with third parties only in the following limited and controlled circumstances:

• Service providers — third-party vendors who assist 99ld in operating the Platform, including payment processors (bKash, Nagad, Rocket, Upay, Visa, Mastercard network partners), identity verification providers, cloud hosting providers, and customer support tools. All service providers are bound by contractual confidentiality obligations and may only use your data to perform services on our behalf.
• Legal and regulatory authorities — where we are required by law, court order, or regulatory directive to disclose personal data, we will do so. We will, where legally permissible, notify you of such disclosure in advance. Disclosures related to anti-money laundering investigations are subject to legal tipping-off restrictions and may not be disclosed to you.
• Business transfers — in the event that 99ld undergoes a merger, acquisition, or sale of all or a portion of its assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify affected users of any such transfer and the new entity will be required to honour the terms of this Privacy Policy.

We do not transfer your personal data to countries outside your region unless adequate safeguards are in place. All cloud infrastructure used by 99ld to store personal data is operated by providers that maintain appropriate data protection standards.

8. Data Retention

99ld retains your personal data for as long as your account is active, and for a defined period thereafter as required by applicable law or legitimate business necessity. Specifically: account and identity records are retained for a minimum of five years from the date of account closure to comply with anti-money laundering legislation; transaction records are retained for a minimum of five years from the date of the transaction; support correspondence is retained for three years from the date of the last communication.

Where retention of your data is no longer required for any of the above purposes and no legal obligation requires us to keep it, we will securely delete or anonymise your personal data. You may request early deletion of your data by contacting [email protected], subject to our legal obligations to retain certain records. We cannot delete records that we are legally required to hold, but we can restrict active processing of them during the retention period.

9. Your Rights Over Your Personal Data

Subject to applicable law and our legal obligations, you have the following rights with respect to the personal data 99ld holds about you. To exercise any of these rights, please contact [email protected] with your registered account details. We will respond to all verifiable requests within 30 days:

• Right of access — you may request a copy of the personal data we hold about you, together with information about how it is being used and with whom it has been shared.
• Right to rectification — if any personal data we hold about you is inaccurate or incomplete, you may request that we correct or complete it without undue delay.
• Right to erasure — in certain circumstances, you may request that we delete the personal data we hold about you. This right is subject to our legal obligations to retain records and may not apply where processing is necessary for compliance with a legal obligation.
• Right to restriction — you may request that we restrict the processing of your personal data in certain circumstances, for example while we investigate the accuracy of data you have disputed.
• Right to object — where we process your personal data on the basis of our legitimate interests, you may object to that processing. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise, or defence of legal claims.

99ld will not discriminate against you for exercising any of your data rights. We may need to verify your identity before processing a data rights request to ensure the security of your account.

10. Data Security

99ld implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include SSL encryption for all data in transit, bcrypt hashing for stored passwords, access controls limiting data access to authorised personnel only, regular security audits of Platform infrastructure, and automated fraud detection systems that flag suspicious activity in real time.

While we take data security seriously and apply industry-standard safeguards, no method of transmission over the internet or method of electronic storage is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 99ld will notify affected users and relevant authorities as required by applicable data protection law, without undue delay.

11. Children's Privacy

The 99ld Platform is strictly intended for adults aged 21 and above. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that we have inadvertently collected personal data from a person under 21, we will delete that data immediately and terminate the associated account without return of any deposited funds. Parents and guardians who believe that a minor in their household has registered on 99ld are urged to contact us immediately at [email protected] so that we can take prompt action.

12. Changes to This Privacy Policy

99ld reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform functionality. When we make material changes to this Policy, we will update the "Last updated" date at the top of this page and, where practicable, notify registered users via the email address associated with their account. We encourage you to review this Policy periodically to stay informed about how we protect your information.

Your continued use of the 99ld Platform after any updated Privacy Policy has been posted constitutes your acceptance of the revised terms. If you do not agree with the revised Policy, you may close your account by contacting [email protected].

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 99ld handles your personal data, please contact our support team by emailing [email protected]. Please include your registered username and a clear description of your query so that we can route your request to the appropriate team member and respond efficiently. We aim to acknowledge all privacy-related enquiries within one business day and resolve them within 30 days.