Privacy Policy — How 99ltd Protects Your Personal Data

1 Who We Are

99ltd is the operator of the online betting and casino platform accessible at 99ltd.io. We provide sports betting markets — including cricket (BPL, IPL, T20 World Cup), football, kabaddi, and other sports popular among Bangladeshi players — as well as live casino games, slot games, and related entertainment services.

For the purposes of this Privacy Policy, "99ltd", "we", "us", and "our" refer to the operator of the 99ltd platform. "You" and "your" refer to any individual who accesses, browses, registers on, or otherwise uses the 99ltd platform. "Personal Data" refers to any information that identifies or could reasonably be used to identify a natural person, either alone or in combination with other available information.

This Privacy Policy applies to all personal data collected, stored, processed, or shared by 99ltd in connection with the operation of the platform, including data collected through the website at 99ltd.io, payment processing systems, customer support interactions, and promotional communications.

2 Data We Collect

99ltd collects personal data in the following categories. We do not collect data beyond what is reasonably necessary for the purposes described in Section 4 of this Policy.

2.1 Account Registration Data

When you create a 99ltd account, we collect the following information:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Residential address, including city, district, and postcode
• Contact mobile number
• Email address
• Username and encrypted account password
• Preferred currency (Bangladeshi Taka, ৳)

2.2 Identity Verification Data

To comply with Know Your Customer (KYC) and anti-money laundering obligations, 99ltd may collect:

• Copies of government-issued identification documents (National ID card, passport, or driving licence)
• Proof of residential address (utility bill, bank statement, or equivalent document)
• Proof of ownership of the payment method used (e.g., screenshot of bKash or Nagad account in the same name)
• Selfie photographs or facial identification images where required for verification

2.3 Financial Transaction Data

When you make deposits or withdrawal requests on 99ltd, we collect:

• Payment method type (bKash, Nagad, Rocket, Upay, Visa, Mastercard)
• Transaction amounts in Bangladeshi Taka (৳)
• Transaction reference numbers and timestamps
• Partial payment account identifiers (e.g., masked mobile banking numbers)

99ltd does not store full card numbers or full mobile banking PINs. All payment processing is handled by accredited third-party payment service providers using PCI-DSS compliant infrastructure.

2.4 Platform Usage Data

During your use of the 99ltd platform, we automatically collect technical and behavioural data, including:

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser version
• Session start and end timestamps (Bangladesh Standard Time, UTC+6)
• Pages visited, games played, bet amounts, and game outcomes
• Responsible gaming tool settings and usage (deposit limits, cooling-off periods)

2.5 Customer Support Data

When you contact 99ltd support via live chat, email, or WhatsApp, we retain records of the communication, including the content of messages, the nature of your query, and any resolution steps taken. These records are used for quality assurance, dispute resolution, and service improvement.

3 How We Collect Data

99ltd collects personal data through the following channels:

• Directly from you — when you complete the account registration form, submit identity verification documents, initiate payment transactions, or contact support.
• Automatically through the platform — via server logs, session tracking, and cookies when you browse or interact with the 99ltd website.
• From third-party service providers — identity verification agencies and payment processors may share verification outcomes or transaction status updates with us as part of the service they provide to 99ltd.
• From fraud prevention systems — risk-scoring and fraud detection tools may provide us with supplementary data to protect the security of your account and the platform.

4 Why We Use Your Data

99ltd uses the personal data it collects for the following specific purposes:

5 Legal Basis for Processing

99ltd processes personal data on one or more of the following legal grounds, depending on the specific processing activity:

• Contract Performance: Processing is necessary to create and manage your account, process your deposits and withdrawals, and deliver the gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable anti-money laundering laws, KYC requirements, and other offshore regulatory obligations.
• Legitimate Interests: Processing is carried out to protect the security of the platform, prevent fraud, improve service quality, and detect prohibited conduct — provided these interests do not override your fundamental privacy rights.
• Consent: Where you have opted in to receive promotional emails or marketing communications, processing is based on your consent. You may withdraw your consent at any time by contacting [email protected].

6 Sharing Your Data

6.1 Permitted Third-Party Recipients

99ltd does not sell, rent, or trade your personal data to third parties. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment Service Providers: bKash, Nagad, Rocket, Upay, and card network processors (Visa, Mastercard) receive the minimum data required to authorise and process your transactions.
• Identity Verification Providers: Third-party KYC service providers receive copies of your identity documents and associated data solely for the purpose of verifying your identity and age.
• Fraud Prevention and Risk Services: Specialist fraud detection providers may receive device identifiers, IP address data, and transaction metadata to assist in identifying and preventing fraudulent activity on the platform.
• Regulatory Authorities: 99ltd may disclose personal data to competent authorities if required to do so by applicable law, court order, or official regulatory request.
• Technology Infrastructure Providers: Cloud hosting and infrastructure providers that support the operation of the 99ltd platform may process personal data on our behalf under strict data processing agreements.

6.2 No Sale of Personal Data

Under no circumstances does 99ltd sell, licence, or otherwise transfer your personal data to advertisers, data aggregators, or unrelated commercial third parties for marketing or profiling purposes.

7 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device by the 99ltd platform when you visit the website. They allow the platform to recognise your device, maintain your login session, remember your preferences, and collect usage analytics. 99ltd uses both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a defined period).

7.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function correctly. These include session authentication tokens and security cookies. They cannot be disabled without preventing use of the platform.
• Functional Cookies: Store your language preference, responsible gaming settings, and last-visited game categories to improve your experience.
• Analytics Cookies: Collect anonymised and aggregated data about how players interact with the platform — pages visited, session duration, and navigation paths — to help us improve the service.
• Fraud Prevention Cookies: Assist in identifying devices associated with suspicious activity or known fraudulent behaviour.

7.3 Managing Cookies

You may configure your browser to block or delete cookies at any time. Please be aware that disabling strictly necessary cookies will impair your ability to log in to and use the 99ltd platform. Instructions for managing cookies are available in the help documentation for all major browsers.

8 Data Security

99ltd implements a multi-layered security framework to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Security measures in place include:

• SSL/TLS encryption for all data transmitted between your device and the 99ltd servers
• One-way cryptographic hashing with salting for all stored account passwords
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis
• Automatic session timeout for inactive accounts to prevent unauthorised access on shared devices
• Regular security audits and vulnerability assessments of the platform infrastructure
• Segregation of production data environments from development and testing systems

While 99ltd takes all reasonable measures to protect personal data, no internet-based platform can guarantee absolute security. If you suspect that your account has been compromised, you must contact 99ltd support immediately at [email protected] so that appropriate protective action can be taken without delay.

9 Data Retention

99ltd retains personal data for the minimum period necessary to fulfil the purposes for which it was collected and to comply with applicable regulatory obligations. The following retention guidelines apply:

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, to satisfy anti-money laundering record-keeping requirements.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the date of last transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the interaction, unless the matter relates to an unresolved dispute or regulatory inquiry.
• Marketing Preference Data: Retained until you withdraw your consent to receive marketing communications or close your account, whichever occurs first.
• Anonymised Analytics Data: Aggregated usage data from which individuals cannot be identified is retained indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with 99ltd's internal data deletion procedures.

10 Your Rights

Subject to applicable law, you have the following rights in relation to the personal data that 99ltd holds about you:

• Right of Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: You may request correction of any personal data that is inaccurate or incomplete.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Restriction: You may request that we restrict processing of your personal data in certain circumstances, for example while a dispute is being investigated.
• Right to Object: You may object to processing of your personal data based on legitimate interests, including profiling for fraud prevention purposes, where your individual circumstances warrant it.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

To exercise any of these rights, please submit a written request to [email protected] (plain text — not a clickable link). 99ltd will respond to all valid data rights requests within thirty (30) days. In certain circumstances involving complex or multiple requests, this period may be extended by a further two months, and you will be notified accordingly.

11 Children's Privacy

The 99ltd platform is strictly intended for individuals who are 21 years of age or older. 99ltd does not knowingly collect personal data from any individual under the age of 21. If you believe that a minor has created an account or provided personal data to 99ltd, please contact [email protected] immediately so that the account can be suspended and the associated data removed without delay.

99ltd employs age verification checks at the registration stage and may request identity documentation to confirm the age of any player at any time. Accounts where the 21+ age requirement cannot be satisfactorily verified will be suspended pending investigation.

12 International Data Transfers

As an offshore online gaming platform, 99ltd's servers and some of its third-party service providers — including payment processors and identity verification agencies — may be located in countries outside Bangladesh. By using the 99ltd platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions other than Bangladesh.

Where personal data is transferred internationally, 99ltd takes reasonable steps to ensure that appropriate contractual or technical safeguards are in place to protect your data to a standard that is consistent with the principles set out in this Privacy Policy. Specifically, 99ltd ensures that any third-party data processors it engages are bound by data processing agreements requiring them to handle your data with equivalent care and security.

13 Changes to This Privacy Policy

99ltd reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable regulatory requirements. Where material changes are made, we will notify registered players by email (to the address associated with your account) or by displaying a prominent notice on the platform prior to the changes taking effect.

The "Effective Date" at the top of this page will be updated to reflect the date on which any revised version of the Privacy Policy comes into force. We encourage you to review this page periodically to remain informed about how 99ltd handles your personal data. Your continued use of the platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 99ltd holds about you, please contact our support team using the details below. All data protection enquiries should be submitted in English for fastest processing.

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week, directly within the 99ltd platform
• WhatsApp: +880 1700 000000 (plain text — not a clickable link)
• Response Time: 99ltd aims to respond to all written privacy enquiries within 30 days of receipt.
• Support Hours: 24/7, Bangladesh Standard Time (BST, UTC+6)