as99 Privacy Policy

as99 ("we", "us", "our", or "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use the as99 platform available at as99.im (the "Platform"). This Privacy Policy describes how as99 collects, uses, stores, shares, and protects personal information relating to registered players and visitors across Bangladesh and other jurisdictions where the Platform is accessed.

This Policy is intended to be read in conjunction with the as99 Terms & Conditions. By registering an account on as99 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any aspect of this Policy, you should cease using the Platform immediately.

For the purposes of applicable data protection law, as99 acts as the data controller in respect of personal data collected through the Platform. As data controller, as99 determines the purposes and means by which personal data is processed and bears primary responsibility for ensuring that such processing complies with applicable legal obligations.

All data protection enquiries, access requests, and complaints should be directed to the as99 support team using the contact details provided in Section 14 of this Policy. as99 will acknowledge all formal data protection requests within five business days of receipt and will endeavour to resolve them within thirty calendar days, consistent with applicable law.

as99 collects the following categories of personal data from players and platform visitors:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (required to verify that you meet the 21+ age requirement)
• Residential address, including city and district (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar)
• Email address registered to your as99 account
• Mobile phone number linked to your account and, where applicable, to your bKash, Nagad, or Rocket wallet
• Nationality and country of residence

3.2 Identity Verification (KYC) Data

• Scanned or photographed copy of your National ID card, passport, or driving licence
• Proof of residential address document (utility bill, bank statement, or official correspondence dated within three months)
• Selfie or live photograph where required as part of biometric verification
• Proof of payment method ownership (bKash, Nagad, Rocket, Upay account confirmation screenshot)

3.3 Financial and Transaction Data

• Deposit transaction records including amounts in Bangladeshi Taka (৳), timestamps, and payment method used
• Withdrawal request records and processing status
• Account balance history and betting/gaming transaction logs
• Payment method identifiers (e.g., last four digits of a card, bKash or Nagad mobile number) — full payment credentials are never stored on as99 servers

3.4 Technical and Usage Data

• IP address and approximate geolocation at the time of login and transaction
• Device type, operating system, browser type, and version
• Session duration, pages visited, games played, and interaction logs
• Cookies and similar tracking technology data (see Section 9)

3.5 Responsible Gaming Data

• Any deposit limits, loss limits, session time limits, cooling-off periods, or self-exclusion instructions you have set or requested
• Records of responsible gaming tool activations and their effective dates

3.6 Communications Data

• Records of live chat conversations, email correspondence, and support ticket exchanges between you and the as99 support team
• Feedback, complaints, and dispute records
• Marketing consent status and communication preference records

as99 collects personal data through the following channels and mechanisms:

• Direct provision by you: When you register an account, complete the KYC verification process, make a deposit or withdrawal, contact our support team, or update your account settings, you directly provide us with personal data.
• Automated collection: When you access and use the Platform, certain technical and usage data is collected automatically through server logs, cookies, and similar technologies without requiring any action on your part.
• Third-party payment providers: When you make a deposit or withdrawal via bKash, Nagad, Rocket, Upay, or bank transfer, the relevant payment provider may share transaction confirmation data with as99 to verify and complete your transaction.
• KYC verification partners: Where as99 engages a third-party identity verification service to assist with document authentication, that provider may return a verification result and associated data to as99 as part of the KYC process.
• Game data providers: When you participate in games supplied by third-party studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi, gameplay event data is transmitted to as99 to record the outcome of each game round and settle your account accordingly.

as99 processes personal data only for specific, defined purposes and always on a recognised lawful basis. The primary purposes for which we process your data are set out below:

• Account registration and management — to create, maintain, and administer your as99 player account. Legal basis: performance of contract.
• Identity verification (KYC) — to confirm your age (21+), identity, and eligibility to use the Platform and to comply with anti-money laundering obligations. Legal basis: legal obligation and legitimate interest.
• Payment processing — to process your deposits and withdrawals in Bangladeshi Taka (৳) via your chosen payment method. Legal basis: performance of contract.
• Customer support — to respond to your queries, complaints, and requests submitted via live chat or email. Legal basis: performance of contract and legitimate interest.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent transactions, account abuse, money laundering, and other prohibited conduct. Legal basis: legitimate interest and legal obligation.
• Responsible gaming compliance — to maintain records of responsible gaming tool activations and to monitor for signs of problem gambling behaviour. Legal basis: legal obligation and legitimate interest.
• Platform improvement and analytics — to analyse usage patterns, improve the performance of the Platform, and personalise the player experience. Legal basis: legitimate interest.
• Marketing communications — to send you promotional offers, bonus notifications, and event-based communications (e.g., BPL season promotions, Eid offers) where you have provided consent. Legal basis: consent.
• Legal and regulatory compliance — to fulfil our obligations under applicable law, including responding to lawful requests from law enforcement or regulatory bodies. Legal basis: legal obligation.

as99 does not sell or rent your personal data to any third party. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Payment Processing Partners

To process your deposits and withdrawals, as99 shares the minimum necessary transaction data with our payment partners including bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank, and card networks such as Visa and Mastercard. These partners are contractually bound to use your data only for payment processing purposes.

6.2 KYC and Identity Verification Providers

Where a third-party provider is engaged to assist with the verification of identity documents and age, your submitted KYC documents and biometric data (if applicable) will be shared with that provider for verification purposes only. Such providers are prohibited from retaining or using your data beyond the scope of the verification service.

6.3 Game Studio and Data Providers

Game providers including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive an account identifier and gameplay event data necessary to operate their games on the as99 Platform. These providers do not receive your full personal profile or financial records.

6.4 Legal and Regulatory Disclosure

as99 may disclose personal data to law enforcement agencies, regulatory bodies, courts, or other public authorities where required to do so by applicable law, court order, or other legal process. In such cases, as99 will disclose only the minimum information required to satisfy the legal obligation.

6.5 Business Transfers

In the event that as99 undergoes a merger, acquisition, restructuring, or sale of assets, personal data held by as99 may form part of the transferred assets. In such circumstances, as99 will take reasonable steps to ensure that the acquiring party commits to data handling standards at least equivalent to those set out in this Policy, and players will be notified of any material change to the data controller.

as99 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to any longer retention period required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account relationship with as99, and for a period of five years following account closure, to meet anti-money laundering and fraud prevention obligations.
• KYC verification documents: Retained for five years from the date of submission or, where a legal obligation prescribes a longer period, for that longer period.
• Financial and transaction records: Retained for five years from the date of each transaction, consistent with standard financial record-keeping requirements.
• Support and communications records: Retained for three years from the date of the last interaction, unless the communication forms part of an ongoing dispute or legal proceeding.
• Technical and usage logs: Retained for up to twelve months from the date of collection, after which they are anonymised or deleted.
• Marketing consent records: Retained for the duration of your consent and for one year following withdrawal of consent, to demonstrate the history of consent status.

At the expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised so that it can no longer be associated with you as an identifiable individual.

as99 takes the security of your personal data seriously and has implemented a range of technical and organisational measures designed to protect it against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and as99 servers
• Encryption of sensitive data fields at rest within the as99 database infrastructure
• Role-based access controls ensuring that as99 personnel can only access personal data to the extent required by their specific job function
• Regular penetration testing and security audits of Platform infrastructure
• Multi-factor authentication options for player accounts and mandatory multi-factor authentication for all administrative staff access
• Automated fraud detection and anomalous-activity monitoring systems that flag unusual login or transaction behaviour for immediate review

While as99 employs robust security practices, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your as99 account credentials and for logging out from shared or public devices after each session. If you suspect that your account has been compromised, please contact us immediately at [email protected].

as99 uses cookies and similar tracking technologies to operate the Platform efficiently, remember your preferences, analyse usage patterns, and deliver relevant promotional content to registered players. A cookie is a small text file placed on your device by a website you visit.

9.1 Types of Cookies Used

• Essential cookies: Strictly necessary for the Platform to function. These include session authentication cookies that keep you logged in during your visit and security cookies that help detect fraudulent activity. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Used to remember your preferences, such as your preferred language setting and last-used payment method, to provide a more personalised experience on return visits.
• Analytical cookies: Used by as99 to collect aggregated, anonymised statistics about how players interact with the Platform — for example, which games are most popular or which pages generate the most support queries. This data informs Platform improvements.
• Marketing cookies: Used to deliver promotional communications that are relevant to your activity on the Platform. These are only activated where you have provided consent to receive marketing communications.

9.2 Managing Cookies

You may control and manage cookies through your browser settings. Most modern browsers allow you to block or delete cookies, or to receive a warning before a cookie is stored. Please note that disabling essential cookies will impair your ability to use core Platform features, including logging in to your as99 account. For instructions on managing cookies in your specific browser, refer to your browser's help documentation.

As a player on the as99 Platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact the as99 support team at [email protected] with the subject line "Data Rights Request" and a description of the right you wish to exercise. as99 will verify your identity before processing any request.

as99 will respond to all verified data rights requests within thirty calendar days of receipt. In complex cases, this period may be extended by a further two months, in which case as99 will notify you of the extension and the reason for it within the initial thirty-day period. There is no fee for exercising your data rights under normal circumstances.

The as99 Platform is strictly for adults aged 21 and above. as99 does not knowingly collect personal data from any individual under the age of 21. As part of the account registration and KYC process, as99 verifies the age of all players before permitting access to real-money gaming and betting features.

If as99 becomes aware that personal data has been collected from an individual who is under 21 years of age, we will immediately suspend the relevant account, delete the data in question, and take such further steps as may be required to address the situation, including notification to relevant authorities where applicable.

In the course of operating the as99 Platform and engaging third-party service providers such as game studios, payment processors, and KYC verification partners, your personal data may be transferred to and processed in countries outside Bangladesh. These countries may have data protection laws that differ from those applicable in Bangladesh.

Where such international transfers occur, as99 takes appropriate steps to ensure that your personal data remains protected to a standard at least equivalent to that described in this Privacy Policy. These steps may include:

• Entering into data processing agreements with third-party recipients that incorporate contractual clauses requiring them to protect your data to an equivalent standard
• Transferring data only to recipients located in countries or jurisdictions that maintain an adequate level of data protection as assessed by as99
• Applying encryption and access controls to data before it is transferred internationally

By using the as99 Platform and providing your personal data, you acknowledge that your data may be transferred internationally as described in this section, subject always to the safeguards outlined above.

as99 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or the services we offer. When we make material changes to this Policy, we will notify registered players by publishing a revised version on the Platform with an updated "Last Updated" date at the top of the document.

Where a change is particularly significant — for example, a change to the legal basis on which we process your data, or the introduction of a new category of data sharing — as99 will take additional steps to bring the change to your attention, which may include sending a notification to your registered email address.

Your continued use of the as99 Platform after the publication of a revised Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. The current version of the Privacy Policy is always accessible at as99.im/privacy-policy.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way as99 handles your personal data, please contact our support team using the details below. All privacy-related communications are handled with strict confidentiality and will be addressed within five business days of receipt.

• Email: [email protected] — please include "Privacy Policy Enquiry" or "Data Rights Request" in the subject line
• Live Chat: Available 24/7 via the as99 Platform, Bangladesh Standard Time (BST, UTC+6)
• Response time: We aim to acknowledge all privacy-related enquiries within five business days and to resolve them fully within thirty calendar days

as99 takes all privacy complaints seriously. If you are not satisfied with our response to a privacy concern you have raised, you may have the right to escalate your complaint to an appropriate supervisory authority or data protection body in your jurisdiction.