Privacy Policy

1 Introduction

99exch is committed to protecting the privacy and personal data of every player who uses our platform. We operate as an online entertainment and sports betting exchange, and in the course of providing our services, we necessarily collect and process certain categories of personal information. This Privacy Policy has been prepared to explain, in plain and transparent terms, exactly how that data is handled.

We understand that players in Bangladesh place considerable trust in us when they share their personal details, financial information, and payment data. We take that trust seriously. Every data processing activity conducted by 99exch is performed for a specific, legitimate purpose and is supported by an appropriate legal basis. We do not sell your personal data to third parties, and we do not use your data for purposes beyond those stated in this Policy.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming policy. If you have any questions about how your data is processed, please contact our support team using the details provided in Section 14 of this Policy.

2 Data We Collect

99exch collects personal data from players in the following categories. We collect only what is necessary for the stated purposes and do not request data that is excessive or irrelevant to the delivery of our services.

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, gender	Account registration, age verification, fraud prevention
Contact Data	Mobile number, email address, home address	Account management, support communications, OTP delivery
Verification Documents	National ID (NID), passport copy, utility bill	KYC / AML compliance, identity verification, withdrawal processing
Financial Data	bKash / Nagad wallet numbers, Rocket / Upay accounts, card details (last 4 digits only)	Deposit processing, withdrawal verification, fraud detection
Transaction Data	Deposit history, withdrawal records, bet history, bonus usage	Account management, dispute resolution, AML monitoring
Technical Data	IP address, device type, browser type, operating system, session timestamps	Platform security, fraud detection, session management
Usage Data	Games played, pages visited, time spent on platform, click patterns	Platform improvement, responsible gaming monitoring, personalisation
Communication Data	Support chat logs, WhatsApp messages, email correspondence	Customer support, dispute resolution, quality assurance

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, genetic data, biometric data, health data, or data concerning sexual orientation unless required by law or with your explicit consent.

3 How We Collect Data

99exch collects personal data through the following channels and mechanisms:

• Direct collection: Data you provide directly when registering an account, completing identity verification, contacting support, submitting a withdrawal request, or filling in any form on the 99exch platform.
• Automated collection: Technical and usage data collected automatically when you access the platform, including through cookies, server logs, and analytics tools. This data is collected whether or not you are logged in to an account.
• Payment processors: Limited transactional data received from payment partners including bKash, Nagad, Rocket, Upay, Visa, and Mastercard when you initiate deposits or withdrawals. 99exch receives only the data necessary to reconcile transactions and does not store full card numbers.
• Identity verification partners: Where third-party identity verification services are used to validate documents submitted during the KYC process, those providers may share verification results with 99exch in accordance with their own privacy policies.
• Publicly available sources: In limited circumstances, we may supplement your data with information from publicly available sources (such as sanctions lists or politically exposed person databases) for AML compliance purposes.

4 Purposes of Processing

99exch processes your personal data for the following specific purposes. We do not use personal data for any purpose that is incompatible with these stated objectives:

• Account creation and management: To register your account, authenticate your identity at login, and maintain your account in good standing throughout your relationship with 99exch.
• Age and identity verification: To confirm that all players are aged 18 or above and that their identity matches the information provided at registration. This is a mandatory requirement of our responsible gaming commitments.
• Payment processing: To process deposits via bKash, Nagad, Rocket, Upay, Visa, or Mastercard, and to verify and process withdrawal requests to your registered payment method.
• Customer support: To respond to enquiries, resolve disputes, investigate complaints, and deliver assistance via our 24/7 support team available in Bangladesh Standard Time (UTC+6).
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting, and other prohibited activities as defined in our Terms & Conditions.
• Responsible gaming: To monitor player behaviour for signs of problematic gambling and to administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion requests. Visit our Responsible Gaming page for full details.
• Platform improvement: To analyse usage patterns, test new features, and improve the overall player experience on 99exch, including across cricket betting markets, casino games, and slots.
• Marketing communications: Where you have opted in, to send promotional notifications about bonuses, seasonal offers (Eid, Pohela Boishakh, BPL season, IPL, T20 World Cup), and new game launches. You may withdraw consent at any time.
• Legal and regulatory compliance: To comply with applicable anti-money laundering requirements, data retention obligations, and any lawful requests from competent authorities.

5 Legal Basis for Processing

Every data processing activity conducted by 99exch rests on one of the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — for example, account management, payment processing, and dispute resolution.
• Legal obligation: Processing required to comply with applicable legal requirements — for example, KYC identity verification, AML transaction monitoring, and retention of financial records.
• Legitimate interests: Processing necessary for our legitimate business interests where those interests are not overridden by your rights — for example, fraud prevention, platform security, responsible gaming monitoring, and platform analytics.
• Consent: Processing based on your freely given, specific, and informed consent — for example, sending optional marketing communications about promotions and new game releases. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6 Data Sharing & Third Parties

99exch does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. We share personal data only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment service providers: bKash, Nagad, Rocket, Upay, Visa, and Mastercard receive only the data required to process your payment transactions. These providers are bound by their own privacy policies and applicable financial data protection requirements.
• Identity verification services: Third-party KYC providers engaged to verify identity documents submitted during account verification. These providers process data solely for verification purposes under strict contractual data protection agreements.
• Game providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive your account identifier and session token to facilitate gameplay. They do not receive your full personal profile or payment data.
• Fraud and security providers: Specialist third-party services engaged to assist with fraud detection, bot prevention, and AML screening. Data shared with these providers is limited to what is necessary for the specific security function.
• Legal and regulatory authorities: Where required by applicable law, court order, or lawful instruction from a competent authority, 99exch may disclose personal data to government bodies, law enforcement agencies, or financial regulators.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 99exch's business, personal data held by 99exch may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

7 Cookies & Tracking Technologies

99exch uses cookies and similar tracking technologies to deliver a functional, personalised, and secure experience on the platform. A cookie is a small text file placed on your device when you visit our platform. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function correctly. These cookies enable core features such as secure login sessions, account authentication, and shopping cart functionality. They cannot be disabled without breaking essential platform features.
• Performance and analytics cookies: Collect anonymised or pseudonymised data about how players interact with the platform — pages visited, time spent, error encounters — to help us improve platform performance and user experience.
• Functional cookies: Remember your preferences such as language settings, preferred payment method, and game display options to provide a more convenient experience on return visits.
• Marketing and targeting cookies: Used where you have consented to receive personalised promotional communications. These cookies may track your activity across sessions to deliver relevant bonus offers and game recommendations.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the 99exch platform, including secure login and payment processing. Disabling other categories of cookies will not affect your ability to place bets or play games but may reduce the personalisation of your experience.

8 Data Retention

99exch retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your active account relationship with 99exch, plus a minimum of five (5) years following account closure to satisfy AML record-keeping requirements.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of each transaction, in accordance with financial record-keeping obligations.
• KYC verification documents: Retained for the duration of the account relationship plus five (5) years following closure. Copies of identity documents are stored in encrypted form and access is restricted to authorised personnel only.
• Support and communication records: Retained for three (3) years from the date of the most recent communication, to enable dispute resolution and quality assurance review.
• Technical and usage data: Typically retained for thirteen (13) months in identifiable form for security and analytics purposes, after which it is aggregated or deleted.
• Marketing consent records: Retained for the duration of your account relationship plus two (2) years, to evidence the basis on which marketing communications were sent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of identifiable information.

9 Your Rights

As a player on the 99exch platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team using the details in Section 14:

• Right of access: You have the right to request a copy of the personal data that 99exch holds about you and information about how it is processed.
• Right to rectification: You have the right to request correction of any personal data that is inaccurate or incomplete. Please keep your account details up to date through the account settings panel or by contacting support.
• Right to erasure: In certain circumstances, you may request deletion of your personal data. Please note that this right is subject to our legal obligations to retain data — for example, AML record-keeping requirements mean that transaction history must be retained for the statutory period even after account closure.
• Right to restrict processing: You may request that we restrict our processing of your data in certain circumstances — for example, where you contest the accuracy of the data or where you have objected to processing based on legitimate interests.
• Right to data portability: Where processing is based on your consent or on contractual necessity, you may request a copy of 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. You also have an unconditional right to object to processing for direct marketing purposes at any time.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal.

10 Security Measures

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

• 256-bit SSL/TLS encryption: All data transmitted between your device and 99exch servers is encrypted using industry-standard 256-bit SSL encryption — the same level of protection used by international banking institutions.
• OTP two-factor authentication: Every login session on the 99exch platform is secured by a one-time password (OTP) sent to your registered mobile number, providing a second layer of authentication beyond your password.
• Encrypted data storage: Sensitive data including identity documents, payment account references, and password hashes are stored in encrypted form within access-controlled database environments.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. 99exch staff members are granted access only to the data required to perform their specific role, and all access is logged and audited.
• Regular security assessments: 99exch conducts regular internal and third-party security reviews to identify and remediate vulnerabilities in our platform infrastructure.
• Incident response: In the event of a data security incident, 99exch maintains a documented incident response procedure. Where a breach is likely to result in a risk to affected individuals, we will notify impacted players promptly in accordance with applicable requirements.

While 99exch takes extensive precautions to protect your data, no digital platform can guarantee absolute security against all possible threats. Players are encouraged to use strong, unique passwords, to keep their mobile number up to date for OTP delivery, and to contact support immediately if they suspect unauthorised account access.

11 Third-Party Links

The 99exch platform may contain references to third-party game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. While these providers supply game content that is delivered within the 99exch platform environment, they operate their own data processing infrastructure and are subject to their own privacy policies.

99exch is not responsible for the privacy practices of third-party game providers or any other external services. We encourage players to review the privacy notices of any third party whose services they access in connection with their 99exch account. 99exch does not endorse the data handling practices of any external organisation and accepts no liability for how third parties process personal data.

12 Children's Privacy

The 99exch platform is strictly intended for adults aged 18 years and above. We do not knowingly collect personal data from individuals under the age of 18. Registration by anyone under 18 is prohibited under our Terms & Conditions, and we apply age verification controls at the point of registration and during withdrawal processing to enforce this requirement.

13 Policy Updates

99exch reserves the right to update this Privacy Policy at any time. When we make material changes to this Policy, we will publish the revised version on this page with an updated effective date prominently displayed at the top of the document. Where changes are significant, we will make reasonable efforts to notify registered players via the mobile number or email address associated with their account.

Continued use of the 99exch platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes and your agreement to be bound by the revised terms. We encourage all players to review this page periodically to remain informed of how their personal data is being processed. If you disagree with any changes to this Policy, you should discontinue use of the platform and contact our support team to arrange account closure.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 99exch, please reach out to our dedicated support team using the contact details below. All contact information is for support use only and is provided as plain text — not as clickable links.

• Email: [email protected]
• WhatsApp: +880 1700 000000
• Support hours: 24 hours a day, 7 days a week (Bangladesh Standard Time, UTC+6)

For information about responsible gaming tools and self-exclusion options, please visit our Responsible Gaming page. For the full terms governing your use of the 99exch platform, please review our Terms & Conditions.