xx99 Privacy Policy — Your Data, Your Rights
We are committed to protecting the privacy of every player on the xx99 platform. This policy explains exactly what data we collect, why we need it, and how we keep it safe.
1. Introduction
xx99 ("xx99", "we", "us", "our") operates the xx99 online gaming platform and is the data controller responsible for the personal information collected through the platform. This Privacy Policy explains how xx99 collects, uses, stores, shares, and protects personal data relating to registered account holders and visitors to the xx99 website. It also sets out the rights you have in relation to your personal data and how to exercise them.
This Privacy Policy applies to all users of the xx99 platform, regardless of whether they access the platform from Bangladesh or elsewhere. By creating an account or using the xx99 platform, you acknowledge that you have read this Privacy Policy and consent to the data practices described herein. If you do not agree to this Privacy Policy, you should not use the xx99 platform.
2. What Personal Data We Collect
Depending on how you use the xx99 platform, we may collect the following categories of personal data:
Identity Data
Full name, date of birth, and copies of identity documents submitted for KYC verification.
Contact Data
Mobile phone number and email address provided during registration or account updates.
Financial Data
bKash, Nagad, Rocket, or bank account identifiers used for deposits and withdrawals, plus transaction records.
Technical Data
IP address, browser type and version, device model, operating system, and session timestamps collected automatically.
Gaming Activity
Bet history, game session logs, wager amounts, win/loss records, and responsible gaming tool usage.
Communications
Records of messages sent to our support team, including support ticket contents and response history.
3. How We Collect Your Data
xx99 collects personal data through the following means:
- Directly from you, when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or update your account settings.
- Automatically, through server logs, cookies, and similar tracking technologies that record technical and behavioural data each time you interact with the xx99 platform.
- From payment service providers such as bKash, Nagad, Rocket, and Upay, who confirm transaction details when you make a deposit or initiate a withdrawal.
- From identity verification partners, where xx99 uses a third-party KYC service to validate identity documents provided during account verification.
4. How We Use Your Personal Data
xx99 uses the personal data it holds about you for the following purposes:
- To create and manage your xx99 account, including processing your registration, verifying your identity, and maintaining your account balance and transaction history.
- To process deposits and withdrawals in BDT, including verifying payment account ownership and communicating with payment service providers to settle transactions.
- To deliver and improve the platform's gaming and betting services, including personalising game recommendations, resolving technical issues, and monitoring platform performance.
- To comply with legal and regulatory obligations, including anti-money laundering (AML) checks, Know Your Customer (KYC) verification, and the reporting of suspicious activity to the relevant authorities where required by law.
- To provide customer support, including responding to your enquiries, resolving disputes, and processing complaints in relation to your xx99 account or any transactions.
- To send you transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — that are necessary for the operation of your account.
5. Legal Basis for Processing
xx99 processes personal data only where a lawful basis exists. The primary legal bases on which xx99 relies are:
Contractual Necessity
Processing your identity, contact, and financial data is necessary to fulfil the contract between you and xx99 — that is, to operate your account, process payments in BDT, and provide the gaming and betting services you have signed up for. Without this data, xx99 cannot deliver the core services of the platform.
Legal Obligation
xx99 is required by law to verify the identity of account holders (KYC), perform AML checks, retain financial records for specified periods, and report certain activities to the relevant authorities. This processing is mandatory and cannot be waived.
Legitimate Interests
Where neither contractual necessity nor legal obligation applies, xx99 may process personal data on the basis of its legitimate interests — for example, to detect and prevent fraud, to protect the security and integrity of the platform, and to improve the quality of the services offered. xx99 ensures that its legitimate interests are not overridden by your privacy rights and that processing is proportionate to the purpose pursued.
6. Sharing Your Personal Data
xx99 does not sell or rent personal data to third parties. xx99 may share personal data with the following categories of recipient only where strictly necessary:
- Payment service providers (bKash, Nagad, Rocket, Upay, Visa, Mastercard) — to process deposits and withdrawals in BDT on your behalf. These providers receive only the transaction data required to execute the payment.
- KYC and identity verification partners — to verify identity documents you submit. These partners are contractually bound to process your data only for verification purposes and to maintain strict confidentiality.
- Game technology providers (including Pragmatic Play, Evolution Gaming, NetEnt, Spribe, Ezugi) — to deliver game sessions. These providers may receive session identifiers and game activity data in order to operate game rounds. They do not receive full identity or payment data.
- Law enforcement and regulatory authorities — where xx99 is required by law to disclose personal data, for example in response to a court order, warrant, or regulatory investigation. xx99 will disclose only the minimum data required by law and will, where legally permitted, notify affected account holders.
All third parties with whom xx99 shares personal data are subject to contractual obligations requiring them to keep that data secure, to process it only for the stated purpose, and not to use it for their own commercial or marketing activities.
7. Data Retention
xx99 retains personal data only for as long as is necessary for the purposes for which it was collected, and in any case for no longer than required by applicable law. In practice, this means the following retention periods apply: account and identity data is retained for the duration of your account plus a minimum of five years following account closure, to comply with AML and financial record-keeping obligations. Transaction records are retained for a minimum of five years from the date of the transaction. Gaming activity logs are retained for a minimum of three years. Support communications are retained for two years from the date of the last communication in a thread.
When personal data is no longer required, xx99 deletes or anonymises it in a manner that makes recovery impossible. Where deletion is not immediately feasible due to backup or archiving requirements, the data is securely isolated until deletion can be completed.
8. Your Privacy Rights
You have the following rights in relation to the personal data that xx99 holds about you. To exercise any of these rights, contact xx99 support via the email address in the platform footer. xx99 will respond to all valid rights requests within a reasonable timeframe.
Right of Access
You may request a copy of the personal data xx99 holds about you, including what categories of data are held, why they are held, and with whom they have been shared.
Right to Rectification
If any personal data xx99 holds about you is inaccurate or incomplete, you may request that it be corrected or completed without undue delay.
Right to Erasure
You may request that xx99 delete your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations that prevent immediate deletion.
Right to Object
You may object to xx99 processing your personal data on the basis of legitimate interests. xx99 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests.
Right to Data Portability
Where processing is based on your consent or on contractual necessity, you may request that xx99 provide your personal data in a structured, commonly used, machine-readable format so that you may transfer it to another service provider.
Please note that some rights are subject to conditions and exemptions. For example, xx99 cannot erase data that it is legally required to retain, and cannot provide data portability for data processed solely on the basis of legitimate interests. xx99 will explain any applicable limitation when responding to your request.
9. Cookies and Tracking Technologies
xx99 uses cookies and similar tracking technologies to operate the platform, remember your preferences, maintain your login session, and analyse how players interact with the site. Cookies are small data files stored on your device by your browser when you visit the xx99 platform.
Essential Cookies
Certain cookies are strictly necessary for the xx99 platform to function. These include session cookies that keep you logged in during your visit, security cookies that protect against cross-site request forgery, and preference cookies that remember your language and display settings. These cookies cannot be disabled without impairing core platform functionality.
Analytics Cookies
xx99 uses analytics cookies to understand how players navigate the platform, which pages are most visited, and where technical errors occur. This data is aggregated and does not identify individual players. You may disable analytics cookies through your browser settings; doing so will not affect your ability to use the xx99 platform but will limit our ability to improve the service over time.
10. Security of Your Personal Data
xx99 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, and unlawful processing. These measures include SSL encryption for all data transmitted between your device and the xx99 platform, secure password hashing, role-based access controls that limit which staff members can view sensitive data, and regular security reviews of the platform's infrastructure.
While xx99 takes all reasonable precautions to protect your data, no internet-based platform can guarantee absolute security against all threats. You are responsible for keeping your own login credentials confidential and for notifying xx99 support immediately if you believe your account has been compromised. xx99 will never ask you for your password via email, SMS, or any support channel.
11. Children's Privacy
The xx99 platform is strictly for adults aged 21 and above. xx99 does not knowingly collect or process personal data relating to persons under the age of 21. If xx99 becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed. If you are a parent or guardian and believe that a person under your care has registered on xx99, please contact xx99 support immediately via the email address in the footer.
12. Changes to This Privacy Policy
xx99 reserves the right to update or replace this Privacy Policy at any time. When material changes are made, xx99 will update the "Last updated" date at the top of this page and, where reasonably practicable, notify registered account holders via the contact details associated with their account. It is your responsibility to review this Privacy Policy periodically to remain informed of how xx99 uses your personal data.
Your continued use of the xx99 platform following the publication of any updated Privacy Policy constitutes your acceptance of the revised policy. If you do not accept any change to this Privacy Policy, you must stop using the xx99 platform and may request closure of your account by contacting support via the email address listed in the footer.
13. How to Contact Us
If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or have a concern about how xx99 has handled your personal data, please contact the xx99 support team using the email address below. xx99 aims to respond to all privacy-related enquiries within 10 business days.
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