99ad Privacy Policy — How We Handle Your Personal Data

1. About This Policy

1.1 This Privacy Policy ("Policy") describes how 99ad ("we", "us", "our") collects, uses, stores, and discloses personal data relating to individuals ("you", "the player") who visit or register an account on the 99ad platform at 99ad.io ("the Platform").

1.2 This Policy forms part of the broader legal framework governing your use of 99ad, alongside the Terms & Conditions and the Responsible Gaming Policy. By registering an account or continuing to use the Platform, you acknowledge that you have read this Policy and consent to the data practices described herein.

1.3 This Policy applies to all personal data collected through the Platform, including data submitted during registration, data generated through your use of our games and payment services, and data collected automatically through your device or browser. It does not apply to third-party websites or services that may be referenced on the Platform.

1.4 This Policy is written in English. Where a translation is provided for convenience, the English version takes precedence in all matters of interpretation.

2. Data We Collect

2.1 We collect personal data in three broad categories: data you provide to us directly, data we generate through your activity on the Platform, and data we collect automatically from your device. The table below summarises the specific types of data we collect and the context in which each type is gathered.

2.2 Data You Choose Not to Provide. Certain data fields are mandatory for account registration and KYC verification. If you decline to provide mandatory data, we may be unable to open your account, process payments, or comply with our responsible gaming obligations.

3. How We Use Your Data

3.1 99ad processes your personal data only for clearly defined and legitimate purposes. We do not use your data for purposes that are incompatible with those for which it was originally collected. The primary purposes for which we use your data are as follows:

• Account Management: To create, verify, maintain, and administer your 99ad account, including processing your login credentials and keeping your profile up to date.
• Payment Processing: To process deposits and withdrawals via bKash, Nagad, Rocket, Upay, and affiliated Bangladeshi banking partners, and to maintain accurate transaction records.
• Identity Verification (KYC): To verify your identity and age as part of our Know Your Customer obligations, to confirm that you meet the 21+ age requirement, and to prevent fraudulent or duplicate account creation.
• Platform Delivery: To deliver games, promotions, and platform features; to personalise your experience based on your game preferences and activity history; and to ensure consistent platform performance across devices.
• Security and Fraud Prevention: To detect and investigate suspicious account activity, attempted fraud, money laundering, and bonus abuse; to protect both 99ad and its player community from harm.
• Responsible Gaming: To monitor your gaming activity for signs of problem gambling; to administer deposit limits, self-exclusion periods, and cool-off requests; and to fulfil our responsible gaming obligations.
• Customer Support: To respond to your enquiries, complaints, and support requests, and to maintain records of communications for quality assurance and dispute resolution purposes.
• Legal Compliance: To fulfil our obligations under applicable laws and regulations, including anti-money laundering requirements, and to respond to lawful requests from competent authorities.
• Platform Improvement: To analyse aggregated, anonymised usage data in order to improve the Platform's design, performance, game selection, and user experience.
• Marketing Communications: Where you have given explicit consent, to send you promotional offers, bonus notifications, and platform news via SMS or email. You may withdraw this consent at any time.

4. Legal Basis for Processing

4.1 99ad processes your personal data on one or more of the following legal bases, depending on the specific processing activity in question:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account creation, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including KYC, anti-money laundering, and responsible gaming obligations.
• Legitimate Interests: Processing carried out for 99ad's legitimate business interests, such as fraud detection, platform security, and anonymised analytics — provided these interests are not overridden by your rights and interests.
• Consent: Processing carried out on the basis of your freely given, specific, and informed consent — most notably for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing & Disclosure

5.1 99ad does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your personal data only in the limited circumstances described below.

5.2 Payment Service Providers. To process your deposits and withdrawals, we share necessary transaction data with payment partners including bKash, Nagad, Rocket, Upay, and affiliated Bangladeshi banks. These partners receive only the data necessary to complete the relevant transaction and are bound by their own privacy obligations.

5.3 Game Technology Providers. The games available on the 99ad platform are powered by third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. These providers may receive anonymised session data necessary to deliver game functionality. They do not receive your personally identifiable information beyond what is technically required for game delivery.

5.4 Identity Verification Partners. To complete KYC checks, we may share identity documents and associated data with specialist identity verification service providers operating under strict confidentiality agreements.

5.5 Legal and Regulatory Disclosure. We may disclose your personal data to competent law enforcement authorities, regulatory bodies, or courts where we are legally required to do so, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of 99ad, our players, or the public.

5.6 Business Transfers. In the event of a merger, acquisition, or sale of all or part of 99ad's business assets, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and of any changes to this Policy that result from it.

5.7 In all cases of data sharing, 99ad applies appropriate contractual and technical safeguards to protect your data and requires all recipients to treat your personal information with the same standard of care that we apply.

6. Cookies & Tracking Technologies

6.1 99ad uses cookies and similar tracking technologies to enhance your experience on the Platform, to maintain your session state, and to gather aggregated analytics data about Platform usage.

6.2 Essential Cookies. These cookies are strictly necessary for the Platform to function. They maintain your login session, remember your account preferences, and ensure secure access. The Platform cannot function properly without them, and they cannot be disabled.

6.3 Analytics Cookies. We use analytics cookies to understand how players navigate and use the Platform — for example, which game categories are visited most frequently and where players encounter difficulties. This data is collected in aggregated, anonymised form and is used solely to improve Platform performance.

6.4 Preference Cookies. These cookies remember your Platform preferences, such as your display settings and notification choices, so you do not have to reconfigure them on each visit.

6.5 Managing Cookies. You may configure your browser to refuse non-essential cookies or to alert you when cookies are being set. Please note that disabling certain cookies may affect the functionality of the Platform. Instructions for managing cookies are available in the settings menu of all major browsers.

7. Data Retention

7.1 99ad retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to the minimum retention periods required by applicable legal and regulatory obligations.

7.2 Active Accounts. While your account remains open and active, we retain all personal data associated with your account including identity records, transaction history, game activity logs, and communications records.

7.3 Closed Accounts. Following the closure of your 99ad account, we retain your identity data, KYC documents, and transaction records for a minimum period of five (5) years from the date of closure. This retention is required to comply with anti-money laundering obligations and to enable us to respond to any disputes or regulatory enquiries that may arise after account closure.

7.4 Marketing Data. If you have consented to marketing communications, we retain your contact details for marketing purposes until you withdraw your consent. Upon withdrawal of consent, your details are removed from active marketing lists within 30 days.

7.5 Support Communications. Records of customer support interactions are retained for a period of three (3) years from the date of the interaction, to facilitate dispute resolution and continuous service improvement.

7.6 After the applicable retention period expires, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with any identifiable individual.

8. Data Security

8.1 99ad implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or destruction. Our security infrastructure includes the following measures:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the 99ad Platform is encrypted using industry-standard 256-bit SSL/TLS protocols, ensuring that your personal and payment data cannot be intercepted in transit.
• Secure Data Storage: Personal data is stored on secure servers with access controls restricting visibility to authorised personnel only. Storage systems are protected by firewalls, intrusion detection systems, and regular security audits.
• Access Controls: Internal access to personal data is granted on a strict need-to-know basis. Staff members with access to player data are subject to confidentiality obligations and undergo regular data protection training.
• Payment Security: Payment transaction data is processed through encrypted channels. 99ad does not store full payment account credentials on its own servers — payment authentication is handled directly by the relevant payment service provider.
• Incident Response: In the event of a data security incident that poses a risk to your rights and freedoms, 99ad will take immediate remedial action and notify affected players without undue delay.

8.2 While 99ad takes all reasonable steps to protect your data, no system is entirely immune to risk. You are responsible for maintaining the security of your own device and for keeping your 99ad login credentials confidential. If you suspect your account has been compromised, contact [email protected] immediately.

9. Your Privacy Rights

9.1 As a 99ad account holder, you hold a number of rights in relation to the personal data we hold about you. These rights are described below. To exercise any of these rights, please contact us at [email protected] with the subject line "Privacy Rights Request". We will respond within 30 calendar days of receiving a valid request.

• Right of Access: You have the right to request a copy of the personal data we hold about you, together with information about how that data is processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct it without undue delay.
• Right to Erasure: In certain circumstances, you have the right to request that we delete your personal data. This right is subject to our legal obligation to retain certain data for minimum periods as described in Section 7 above.
• Right to Restriction: You may request that we restrict the processing of your personal data in circumstances where you contest its accuracy, where processing is unlawful, or where we no longer need the data but you require it for legal purposes.
• Right to Data Portability: Where processing is based on your consent or on a contractual basis, you may request that we provide your personal data 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 our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent — most notably for marketing communications — you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

9.2 Identity Verification for Rights Requests. To protect your data from unauthorised disclosure, we will verify your identity before responding to any privacy rights request. We may ask you to provide a copy of your NID or other identification document as part of this verification process.

10. Children & Minors

10.1 The 99ad platform is strictly for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, you must not register an account, make a deposit, or participate in any game on the Platform.

10.2 If 99ad becomes aware that it has collected personal data from an individual under the age of 21, that account will be immediately suspended, all data associated with the account will be securely deleted, and any deposits will be returned in accordance with our responsible gaming procedures.

10.3 If you believe that a minor has registered an account on 99ad, please notify us immediately at [email protected] so that we can take prompt remedial action.

11. Third-Party Links & Services

11.1 The 99ad Platform may contain references to third-party game providers, payment partners, or informational resources. This Policy applies solely to data processed by 99ad directly and does not extend to any third-party websites, services, or applications that you may access in connection with your use of the Platform.

11.2 We encourage you to review the privacy policies of any third-party services you interact with. 99ad is not responsible for the privacy practices or content of third-party services and accepts no liability for data processed by them.

12. Changes to This Policy

12.1 99ad reserves the right to update or amend this Privacy Policy at any time. Revised versions will be published at 99ad.io/privacy-policy with an updated effective date shown at the top of the document. Where changes are material, we will use reasonable efforts to notify registered players via their registered mobile number or email address before the changes take effect.

12.2 Your continued use of the Platform following publication of a revised Policy constitutes your acceptance of the updated terms. If you disagree with any change to this Policy, you should stop using the Platform and contact us to close your account.

13. Contact Us

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 99ad processes your personal data, please contact our support team:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: "Privacy Policy Enquiry" or "Privacy Rights Request"
• Response Time: We aim to acknowledge all privacy-related enquiries within 24 hours and to provide a substantive response within 30 calendar days.
• Support Hours: 24 hours a day, 7 days a week, Bangladesh Standard Time (UTC+6)

13.2 For responsible gaming concerns, self-exclusion requests, or deposit limit adjustments, please use the same email address with the subject line "Responsible Gaming Request". Full details of available responsible gaming tools are available on our Responsible Gaming page.