99fd Privacy
Policy & Data Rights

1 Introduction

This Privacy Policy ("Policy") describes how 99fd ("99fd", "we", "us", "our") collects, uses, stores, and discloses personal information obtained from individuals ("Member", "you", "your") who access or use the 99fd website at https://99fd.io and all associated services, games, and features (collectively, the "Platform").

By registering a 99fd account or using the Platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. This Policy forms part of our Terms & Conditions and should be read alongside our Responsible Gaming Policy.

We are committed to handling your personal data with the highest standards of care, transparency, and security. If at any point you have questions about how your data is handled, please contact us using the details in Section 13.

2 Personal Data We Collect

99fd collects personal data through several channels: directly from you when you register or interact with the Platform, automatically through your device and browser as you use the Platform, and in limited circumstances from trusted third-party service providers.

2.1 Data You Provide Directly

• Identity data: Full legal name, date of birth, and gender as provided during registration
• Contact data: Email address and mobile phone number (including the number linked to your bKash, Nagad, Rocket, or Upay wallet)
• Address data: Residential address in Bangladesh (district, division, and postal code), as required for KYC verification
• Identity verification documents: National Identity Card (NID), passport, or driving licence submitted during KYC, together with any proof-of-address documents
• Payment data: Transaction reference numbers and the payment method account name associated with your bKash, Nagad, Rocket, Upay, or bank account. Full payment credentials are processed exclusively by your payment provider and are never stored on 99fd servers.
• Account preferences: Responsible gaming settings, notification preferences, deposit limits, and self-exclusion elections made within your account dashboard
• Support communications: Any information you provide when contacting 99fd customer support by email or live chat

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers
• Usage data: Pages visited, games launched, betting history, session start and end times, clickstream data, and feature interactions
• Geolocation data: Approximate location derived from your IP address, used to verify that you are accessing the Platform from Bangladesh and to apply jurisdiction-appropriate responsible gaming measures
• Cookie and tracking data: Data collected via cookies and similar technologies as described in Section 6

2.3 Data from Third Parties

We may receive limited personal data about you from third parties in the following contexts: identity verification bureaus and KYC service providers confirming the authenticity of your submitted documents; payment processors confirming the status of deposit and withdrawal transactions; and fraud prevention services flagging accounts associated with known suspicious activity.

3 How We Use Your Personal Data

The table below summarises the primary purposes for which 99fd processes your personal data:

4 Legal Basis for Processing

99fd processes your personal data under the following legal grounds:

• Performance of a contract: Processing necessary to create and operate your account, process transactions, and deliver the services you have requested
• Legal obligation: Processing required to comply with anti-money laundering (AML) laws, KYC requirements, responsible gaming regulations, and financial record-keeping obligations
• Legitimate interests: Processing carried out for fraud prevention, platform security, improving user experience, and communicating important account information, where those interests are not overridden by your data protection rights
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Data Sharing and Disclosure

99fd does not sell your personal data to any third party. We share data only in the following limited and controlled circumstances:

5.1 Service Providers

We engage carefully selected third-party service providers who process data on our behalf, under strict contractual data protection obligations. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, and partner banks — to facilitate BDT transactions
• KYC and identity verification providers: To authenticate your identity documents and confirm age eligibility
• Game platform providers: Including Evolution Gaming, Pragmatic Play, Spribe, Ezugi, NetEnt, and Microgaming — who receive anonymised session tokens to deliver game content. These providers do not receive your full identity data.
• IT infrastructure and cloud hosting providers: Who host Platform servers and data storage under confidentiality agreements
• Fraud prevention and AML screening services: Who help 99fd identify and block suspicious account activity

5.2 Legal and Regulatory Disclosure

99fd may disclose personal data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, or where necessary to protect the rights, property, or safety of 99fd, its members, or the public. We will notify you of any such disclosure where we are legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 99fd's business assets, your personal data may be transferred to the acquiring entity. We will provide notice of such a transfer and ensure that your data continues to be protected under terms no less protective than this Policy.

6 Cookies and Tracking Technologies

99fd uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and in limited cases, deliver relevant promotional content to opted-in members.

6.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings, display preferences, and last-used game categories, to provide a more personalised experience.
• Analytical cookies: Collect anonymised or pseudonymised data about how members navigate the Platform, which features are used most, and where errors occur. This data is used to improve Platform performance.
• Marketing cookies (consent-based only): Used only when you have explicitly opted in to marketing communications. These help 99fd present contextually relevant promotional offers to returning members.

6.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block, delete, or receive alerts about cookies. Please note that disabling functional or analytical cookies may degrade your experience on the Platform. For strictly necessary cookies, no opt-out is available as they are required for secure Platform operation.

7 Data Security

99fd implements a layered security framework designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 99fd servers
• Encryption at rest for all stored personal data and identity documents
• Strict access controls ensuring that only authorised 99fd personnel with a legitimate operational need can access member data
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security specialists
• Two-factor authentication (2FA) available on all member accounts and mandatory for 99fd staff accessing internal systems
• Automated monitoring systems that detect and alert on unusual access patterns or potential data breach events in real time

In the unlikely event of a data breach that poses a risk to your rights and freedoms, 99fd will notify affected members promptly and take all reasonable steps to contain and remediate the breach.

8 Data Retention

99fd retains your personal data for as long as your account is active and for a defined period after account closure, in order to meet our legal, regulatory, and responsible gaming obligations. Specific retention periods are as follows:

• Active account data: Retained for the duration of your account's active status plus a minimum of five years following account closure, in accordance with AML record-keeping requirements
• KYC and identity documents: Retained for a minimum of five years following the last transaction on your account
• Transaction records: Retained for a minimum of five years for financial audit and AML compliance purposes
• Support communications: Retained for three years from the date of the interaction, unless the matter has given rise to a dispute, in which case records are retained until the dispute is fully resolved
• Analytical and usage data: Retained in anonymised or aggregated form for up to three years for Platform improvement purposes
• Marketing consent records: Retained for the duration of your consent and for two years following withdrawal of consent, as evidence of your opt-in history

Once the applicable retention period has expired, data is securely deleted or anonymised so that it can no longer be linked to your identity.

9 Your Data Protection Rights

As a 99fd member, you hold the following rights in respect of your personal data. To exercise any of these rights, contact us at the details provided in Section 13:

• Right of access: You may request a copy of all personal data 99fd holds about you. We will respond within 30 days of receiving a valid request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to restriction of processing: You may request that we temporarily restrict the processing of your data while you contest its accuracy or the lawfulness of our processing.
• Right to data portability: Where processing is based on your consent or on the performance of a contract, you may request your data in a structured, machine-readable format.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications, non-essential cookies), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing carried out on the basis of legitimate interests, including profiling for marketing purposes.

We will not charge a fee for exercising your rights in ordinary circumstances. Where requests are manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or decline the request, with written explanation.

10 Children's Privacy and the 21+ Rule

The 99fd Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is performed as part of the account registration process and may be reinforced through KYC document checks.

If 99fd discovers or has reason to believe that an account has been registered by a person under 21, the account will be immediately suspended, all activity on the account reviewed, and any funds associated with the account handled in accordance with our Terms & Conditions and applicable law. Any personal data collected in connection with an underage account will be deleted promptly once the matter has been resolved.

If you are a parent or guardian and believe that a minor has registered a 99fd account, please contact us immediately at [email protected] so we can take appropriate action.

11 Third-Party Links and Integrations

The 99fd Platform may contain integrations with or references to third-party services, including payment providers such as bKash and Nagad, and game content delivered via providers such as Evolution Gaming and Pragmatic Play. While we take care to work only with reputable partners, 99fd is not responsible for the privacy practices of third-party services operating under their own separate privacy policies.

When you initiate a payment via bKash, Nagad, Rocket, or Upay, you are interacting with that provider's interface and their data practices apply to that transaction. We encourage you to review the privacy policies of all third-party services you interact with in connection with your 99fd account.

12 Changes to This Privacy Policy

99fd reserves the right to update or amend this Privacy Policy at any time. Where changes are material — for example, if we begin collecting a new category of personal data or change how existing data is used — we will notify you by email to your registered address and by posting a prominent notice on the Platform prior to the change taking effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the Platform following notification of a material change constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you should stop using the Platform and may request account closure by contacting support.

13 Contact Us — Data Queries and Rights Requests

For any questions, concerns, or formal requests relating to your personal data and privacy rights under this Policy, please contact the 99fd data team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject line for rights requests: "Data Rights Request — [Your Registered Name]"
• Response time: We aim to acknowledge all data-related enquiries within 48 hours and to provide a substantive response within 30 days
• Support hours: 24 hours a day, 7 days a week

For questions about responsible gaming account controls, please also visit our Responsible Gaming page, where detailed guidance on self-exclusion, deposit limits, and support resources is available.