ee99 Privacy Policy

1. Introduction

This Privacy Policy governs the collection, use, storage, and disclosure of personal information by ee99, the operator of the online betting and casino platform accessible at ee99.bar (hereinafter referred to as "ee99", "we", "us", or "our"). This Policy applies to all registered players, visitors, and users of the ee99 platform, including those accessing the platform from Bangladesh and other jurisdictions.

By registering an account, accessing the website, or using any service offered by ee99, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with the terms of this Policy, you must discontinue use of the platform immediately.

This Privacy Policy should be read in conjunction with the ee99 Terms and Conditions, which are available at ee99.bar/terms-conditions. In the event of any conflict between this Privacy Policy and the Terms and Conditions on matters relating to personal data, this Privacy Policy shall take precedence.

2. Information We Collect

2.1 Registration and Identity Information

When you create an account on ee99, we collect the following personal information:

• Full legal name as it appears on your government-issued identification.
• Date of birth to verify that you meet the 21+ age requirement.
• Email address for account communications, security alerts, and support.
• Mobile phone number for account verification and two-factor authentication.
• Residential address including city (e.g., Dhaka, Chittagong, Sylhet, Khulna) and district.
• Username and encrypted password for account access.

2.2 Identity Verification (KYC) Documents

As part of our Know Your Customer (KYC) verification process, we may collect copies of:

• National ID card (NID) or Smart Card issued by the Bangladesh Election Commission.
• Valid passport.
• Bangladesh driving licence.
• Proof of address documents such as utility bills or bank statements.
• Selfie photographs for biometric identity confirmation where required.

2.3 Financial and Transaction Information

To process deposits and withdrawals, we collect:

• Mobile banking account numbers and registered phone numbers (bKash, Nagad, Rocket, Upay).
• Bank account details including bank name (e.g., BRAC Bank, City Bank, Dutch-Bangla Bank, Islami Bank, Sonali Bank), account number, and branch information.
• Transaction reference numbers and timestamps.
• Deposit and withdrawal amounts in Bangladeshi Taka (৳).
• Card details (Visa/Mastercard) where applicable — card numbers are never stored in full; only masked card data is retained.

2.4 Technical and Usage Data

We automatically collect certain technical data when you access the ee99 platform:

• IP address and approximate geolocation.
• Device type, operating system, and browser version.
• Session duration, pages visited, and features used.
• Betting and gaming history, including wager amounts, game selections, and outcomes.
• Login timestamps and access logs.
• Cookie identifiers and similar tracking technologies (see Section 8).

2.5 Communications Data

When you contact ee99 customer support via email ([email protected]) or live chat, we retain records of those communications — including the content of your messages, the date and time of contact, and the resolution of any queries — for quality assurance, training, and audit purposes.

3. How We Use Your Information

ee99 uses the personal information we collect for the following specific purposes:

ee99 does not use your personal data for any purpose that is incompatible with the purposes listed above. If we wish to use your data for a new purpose, we will update this Privacy Policy accordingly and, where required, seek your fresh consent.

4. Legal Basis for Processing

ee99 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and ee99 — specifically, to provide the betting and gaming services you have registered to access, process your transactions, and manage your account.
• Legal Obligation: Processing is necessary to comply with applicable legal requirements, including anti-money laundering (AML) regulations, KYC obligations, and lawful requests from regulatory or law enforcement authorities.
• Legitimate Interests: Processing is necessary for ee99's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services — provided these interests are not overridden by your fundamental privacy rights.
• Consent: For specific processing activities such as sending promotional communications and setting non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw your consent at any time by contacting [email protected].

5. Data Sharing and Disclosure

5.1 Authorised Third-Party Service Providers

ee99 shares your personal data with a limited number of trusted third-party service providers who assist us in operating the platform. These providers are contractually bound to process your data solely on our instructions and in accordance with applicable data protection standards. Categories of authorised recipients include:

• Payment processors: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and partnered Bangladeshi banks — to facilitate your deposits and withdrawals.
• KYC/Identity verification providers: Third-party services used to verify your identity documents where automated verification is employed.
• Game technology providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed game studios — limited to data necessary for game session management and dispute resolution.
• IT infrastructure providers: Hosting, cloud storage, and cybersecurity service providers who maintain the technical infrastructure of the ee99 platform.
• Customer support tools: Platforms used to manage support tickets and live chat sessions, where relevant conversation data is processed.

5.2 Legal and Regulatory Disclosure

ee99 may disclose your personal data to competent legal or regulatory authorities when required to do so by law, court order, or other binding legal process. Such disclosures may include, but are not limited to, sharing data with financial intelligence units in connection with anti-money laundering investigations or cooperating with law enforcement agencies in cases of suspected fraud or criminal activity.

5.3 No Sale of Personal Data

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of ee99's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer via a prominent notice on the platform or by email, and the acquiring entity will be required to honour the terms of this Privacy Policy with respect to your data.

6. Data Retention

ee99 retains your 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. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with standard AML record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• KYC documentation: Retained for five (5) years from the date of verification or account closure, whichever is later.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless the communication relates to an active dispute or investigation.
• Technical/usage logs: Retained for up to twelve (12) months for security and fraud analysis purposes, then anonymised or deleted.
• Marketing consent records: Retained until you withdraw your consent or for three (3) years from the date of last engagement, whichever is earlier.

Once the applicable retention period has expired, your personal data will be securely deleted or anonymised in such a way that it can no longer be attributed to you as an identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and analytical purposes.

7. Data Security

ee99 implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ee99 servers.
• Encrypted storage of sensitive personal data, including identity documents and financial information, using AES-256 encryption at rest.
• Access controls: Role-based access restrictions ensuring that only authorised ee99 personnel can access personal data, with all access activity logged and audited.
• Firewalls and intrusion detection systems monitoring the platform's infrastructure around the clock.
• Regular security audits and penetration testing conducted by qualified cybersecurity professionals.
• Two-factor authentication (2FA) options available for player accounts to add an additional layer of login security.
• Incident response procedures to detect, contain, and notify affected individuals in the event of a data breach, as required.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by the ee99 website when you visit. They allow the platform to recognise your device, remember your preferences, and provide a more personalised and efficient experience. ee99 also uses similar technologies such as web beacons, local storage objects, and session tokens for analogous purposes.

8.2 Categories of Cookies We Use

8.3 Managing Cookies

You can control and manage non-essential cookies through your web browser settings. Most modern browsers allow you to block, delete, or restrict cookies. Please note that disabling essential or security cookies may impair your ability to log in, maintain a session, or use certain features of the ee99 platform. Instructions for managing cookies are available in the help documentation of your specific browser.

ee99 does not use cookies to serve targeted advertising from external advertising networks, and we do not share cookie data with third-party marketers.

9. Your Privacy Rights

As a registered player on ee99, you have the following rights in relation to your personal data. To exercise any of these rights, contact our support team at [email protected] with your account details and a clear description of your request. We will respond within ten (10) business days.

• Right of Access: You have the right to request a copy of the personal data ee99 holds about you, along with information about how it is being used and on what legal basis.
• 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 or updated promptly.
• Right to Erasure ("Right to be Forgotten"): You may request that ee99 delete your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under AML and KYC regulations.
• Right to Restriction of Processing: You may request that we restrict the processing of your personal data in specific circumstances — for example, while a correction request is being resolved.
• Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where we rely on legitimate interests as the legal basis, if you believe your privacy rights outweigh those interests.

10. Minors and Age Restriction

The ee99 platform is strictly intended for adults aged 21 years and above. ee99 does not knowingly collect personal data from individuals under the age of 21. If we become aware that a registered account belongs to a person under 21, or that personal data has been collected from a minor, we will immediately suspend the account, delete the associated data to the extent permitted by law, and take appropriate remedial action.

Parents and guardians are encouraged to use parental control tools and monitoring software to prevent minors from accessing online gambling platforms. If you believe a minor has registered on ee99 or has accessed the platform using your credentials, contact [email protected] immediately and we will investigate and act without delay.

11. International Data Transfers

ee99 operates as an offshore platform and its server infrastructure may be located in jurisdictions outside of Bangladesh. As a result, your personal data may be transferred to, stored, and processed in countries other than your country of residence. These countries may have data protection laws that differ from those applicable in Bangladesh.

Where personal data is transferred internationally, ee99 takes all reasonable steps to ensure that adequate safeguards are in place to protect your data, including contractual obligations on receiving parties to maintain security and privacy standards consistent with those described in this Policy.

By using the ee99 platform and agreeing to this Privacy Policy, you consent to the international transfer of your personal data as described in this section.

12. Changes to This Policy

ee99 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will notify registered players by posting a prominent notice on the ee99 platform and, where appropriate, by sending a notification to your registered email address.

The "Last Updated" date at the top of this document will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the ee99 platform after any changes to this Policy constitutes your acceptance of those changes.

If you disagree with any changes made to this Privacy Policy, you have the right to close your account and request deletion of your personal data, subject to the retention obligations described in Section 6.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way ee99 handles your personal data, please contact our support team using the details below. Our customer support team is available 24 hours a day, 7 days a week, and responds in English to all players across Bangladesh including those based in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, and Mymensingh.

When submitting a data subject request, please include your registered username, the email address associated with your ee99 account, a clear description of your request, and any relevant details that will help us locate your records and respond accurately. We may need to verify your identity before processing your request to protect the security of your account.