Privacy Policy for
af99 Platform Users

1 Introduction

af99 ("we", "us", "our") operates the online gaming and sports betting platform accessible at af99.im (the "Platform"). In the course of providing our services to players in Bangladesh and internationally, af99 collects, processes, stores, and in some cases shares personal data relating to registered players and platform visitors.

af99 takes data privacy seriously. We are committed to handling your personal information with care, transparency, and in accordance with internationally recognised data protection principles. This Privacy Policy sets out in plain terms what data we collect, why we collect it, how long we keep it, who may access it, and what rights you have in relation to your own data.

This policy should be read alongside the af99 Terms and Conditions, which govern the overall relationship between you and af99. Where this Privacy Policy and the Terms and Conditions address the same subject matter, this Privacy Policy shall take precedence with respect to data protection matters.

2 Personal Data We Collect

af99 collects the following categories of personal data from players and platform visitors. We collect only the data that is necessary for the purposes described in this policy.

Data Category	Examples	Purpose
Identity Data	Full name, date of birth, gender, nationality, National ID or passport number	Account registration, KYC verification, age verification
Contact Data	Email address, phone number, residential address (city, district, division)	Account communications, support, fraud alerts
Financial Data	bKash/Nagad/Rocket mobile wallet numbers, transaction history, deposit and withdrawal records	Payment processing, AML compliance, withdrawal verification
Technical Data	IP address, device type, browser type, operating system, session timestamps	Platform security, fraud prevention, technical support
Usage Data	Pages visited, games played, bet history, session duration, feature interactions	Service improvement, responsible gaming monitoring, personalisation
Communications Data	Support chat transcripts, email correspondence, feedback submissions	Customer service, dispute resolution, quality assurance
Verification Documents	Scanned copies of National ID, passport, utility bills, payment method screenshots	KYC compliance, withdrawal processing, identity confirmation

af99 does not collect sensitive special-category data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data unless explicitly required by law or to meet a specific regulatory obligation, in which case you will be separately informed.

3 How We Collect Your Data

af99 collects personal data through the following channels and interactions:

• Direct submission: When you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or respond to a promotion, you provide data directly to af99.
• Automated collection: When you access the af99 platform, our servers and analytics tools automatically collect technical and usage data including your IP address, device identifiers, browser characteristics, and navigation behaviour.
• Cookies and similar technologies: af99 uses cookies and local storage to maintain session continuity, remember your preferences, and gather aggregated analytics. See Section 7 for full details on our cookie practices.
• Third-party game providers: Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may pass anonymised gameplay event data to af99 for the purpose of resolving disputes and verifying game outcomes. These providers do not share your identity data with af99 beyond what you have already submitted at registration.
• Payment partners: When you transact via bKash, Nagad, Rocket, Upay, or other payment providers, those providers may confirm transaction status and mobile wallet identifiers to af99 for reconciliation purposes.
• Identity verification services: Where af99 engages a third-party KYC verification provider, that provider may return a verification result and a risk score to af99. The raw identity documents you submit are handled in accordance with that provider's own privacy standards.

4 How We Use Your Personal Data

af99 uses your personal data strictly for the following purposes. We do not use your data for purposes that are incompatible with those set out below, and we do not sell your personal data to third parties for marketing purposes.

• Account management: To create, maintain, and administer your af99 account, verify your identity, and provide you with access to the platform's full range of features.
• Payment processing: To facilitate deposits and withdrawals via bKash, Nagad, Rocket, Upay, and other supported payment methods, and to maintain accurate financial records in compliance with anti-money laundering obligations.
• Legal and regulatory compliance: To meet our obligations under applicable anti-money laundering (AML), counter-terrorist financing (CTF), and Know Your Customer (KYC) regulations, including verifying player age (21+), identity, and source of funds where required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account takeovers, multi-account abuse, bonus fraud, and any other activity that may harm the platform or its players.
• Customer support: To respond to your enquiries, resolve disputes, investigate complaints, and maintain records of interactions for quality assurance purposes.
• Responsible gaming: To monitor gameplay patterns that may indicate problem gambling behaviour, to enforce self-exclusion or account limits set by you, and to fulfil our duty of care obligations toward players.
• Platform improvement: To analyse aggregated usage data, identify technical issues, improve game offerings, and enhance the overall player experience on af99.
• Marketing communications: With your explicit consent, to send you promotional offers, bonus notifications, and platform updates by email. You may withdraw consent at any time by contacting [email protected] or clicking the unsubscribe link in any marketing email.

5 Legal Basis for Processing

af99 processes your personal data on the following legal bases, depending on the specific processing activity involved:

• Contractual necessity: Processing your identity, contact, and financial data is necessary to fulfil our contractual obligations to you under the af99 Terms and Conditions — for example, to process your deposits and withdrawals and to provide access to games.
• Legal obligation: Certain processing activities — particularly KYC verification, AML record-keeping, and age verification — are required by applicable law or by the terms of af99's international gaming licence. We are legally obligated to carry out this processing regardless of your preferences.
• Legitimate interests: af99 processes technical and usage data to detect fraud, prevent security breaches, and maintain the integrity of the platform. These interests are balanced against your privacy rights and we take steps to minimise the intrusiveness of such processing.
• Consent: Where we send you direct marketing communications or set non-essential cookies, we rely on your explicit, freely given consent. You have the right to withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing and Disclosure

af99 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share your data only in the following strictly defined circumstances:

• Service providers and processors: af99 engages carefully selected third-party providers to support platform operations — including payment processors (bKash, Nagad, Rocket), identity verification services, cloud hosting providers, email delivery services, and analytics platforms. These processors are contractually bound to process your data only on af99's instructions and in accordance with this Privacy Policy.
• Game providers: Providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive the minimum data necessary to deliver their game content and to resolve technical disputes. They do not use your data for their own independent marketing purposes.
• Regulatory and law enforcement authorities: Where required by applicable law, a court order, or a lawful request from a competent authority, af99 will disclose the minimum amount of personal data necessary to comply. af99 will notify you of such a request where legally permitted to do so.
• Fraud prevention agencies: af99 may share data with recognised fraud prevention and AML screening services to protect the platform and its players from financial crime. Information provided to these agencies may be used by other organisations to perform similar checks.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of af99's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and of any material change to this Privacy Policy that results from it.

All third parties who receive your personal data from af99 are required to implement appropriate technical and organisational security measures and to handle your data in a manner consistent with this Privacy Policy.

7 Cookies and Tracking Technologies

af99 uses cookies, web beacons, and similar tracking technologies to operate and improve the platform. Cookies are small text files placed on your device by your browser when you visit the af99 website. They allow the platform to recognise your device, maintain your session, and remember your preferences across visits.

af99 uses the following categories of cookies:

• Strictly necessary cookies: These are essential for the platform to function. They enable you to log in to your account, navigate between pages, and complete transactions. These cookies cannot be disabled without impairing core platform functionality.
• Performance and analytics cookies: These collect anonymised information about how players use the platform — such as which pages are visited most often and whether error messages are encountered. This data helps af99 identify performance issues and improve the user experience.
• Functional cookies: These remember choices you make on the platform (such as language preferences or game settings) to provide a more personalised experience during your session.
• Marketing and targeting cookies: With your consent, af99 may use cookies to track your interactions with promotional content and to deliver relevant offers. These cookies may be set by af99 or by trusted advertising partners.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and receive a warning before a cookie is stored. Please note that disabling strictly necessary cookies will affect your ability to use certain platform features, including account login.

8 Data Retention

af99 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, to meet our legal and regulatory obligations, and to resolve any disputes that may arise. The following indicative retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following permanent account closure, in compliance with AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with financial reporting and AML obligations.
• KYC verification documents: Retained for a minimum of five (5) years following your last transaction or account closure, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the most recent interaction, unless a dispute relating to that interaction remains unresolved, in which case records are retained until the dispute is fully resolved.
• Marketing consent records: Retained for as long as you hold an active account with af99 or until you withdraw consent, whichever is earlier.
• Technical and usage logs: Retained for up to twelve (12) months from the date of collection for security and fraud prevention purposes.

Upon expiry of the applicable retention period, af99 will securely delete or anonymise your personal data so that it can no longer be associated with you as an individual.

9 Data Security

af99 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security practices include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the af99 platform
• Encryption of sensitive data at rest, including financial records and identity documents
• Role-based access controls ensuring that af99 staff may only access personal data that is necessary for their specific job function
• Regular security audits, vulnerability assessments, and penetration testing of the platform infrastructure
• Multi-factor authentication requirements for administrative access to systems that hold personal data
• Staff training on data protection obligations and secure data handling procedures

While af99 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, af99 will notify you without undue delay and will take immediate steps to contain and remediate the breach.

You are responsible for keeping your af99 account credentials secure. If you believe your account has been compromised, contact support immediately at [email protected].

10 Your Data Protection Rights

As a data subject, you hold the following rights in relation to the personal data af99 holds about you. af99 will respond to all valid rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, af99 may extend this period by a further sixty (60) days, with prior notification to you.

• Right of access: You have the right to request a copy of all personal data af99 holds about you, together with information about how it is being used.
• Right to rectification: You have the right to request that af99 corrects any personal data that is inaccurate or incomplete. Basic account details such as email address can be updated directly from within your account dashboard.
• Right to erasure ("right to be forgotten"): You may request that af99 deletes your personal data where there is no longer a lawful basis for retaining it. Please note that this right is subject to overriding legal obligations; af99 cannot delete data that it is required to retain for AML, KYC, or other regulatory purposes.
• Right to restrict processing: You may request that af99 limits how it uses your personal data in certain circumstances, such as while a dispute over data accuracy is being resolved.
• Right to data portability: You have the right to receive a copy of the personal data you have provided to af99 in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You also have the right to object to processing based on af99's legitimate interests, though af99 may be able to demonstrate overriding grounds for continuing that processing.
• Right to withdraw consent: Where af99 processes your data on the basis of your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

To exercise any of the above rights, please submit a written request to [email protected] clearly stating the right you wish to exercise and the specific data concerned. af99 may ask you to verify your identity before processing your request.

11 Children and Minors

The af99 platform is strictly intended for adults aged 21 years and above. af99 does not knowingly collect, process, or store personal data relating to individuals under the age of 21. Age verification is a mandatory step in the af99 account registration and KYC process.

If af99 discovers or has reason to believe that personal data has been collected from an individual who is under 21 years of age, that account will be closed immediately, all associated data will be deleted or anonymised to the extent permitted by law, and any funds in the account will be handled in accordance with the af99 Terms and Conditions and applicable regulatory requirements.

If you are a parent or guardian and believe that your child has registered an account with af99, please contact us immediately at [email protected] with full details so that we may investigate and take appropriate action without delay.

12 Third-Party Links and Services

The af99 platform may display content sourced from third-party game providers. While af99 takes care to partner with reputable providers, af99 does not control the data practices of these third parties and accepts no responsibility for the privacy practices of any third-party service beyond what is described in Section 6 of this policy.

af99 does not embed links to external third-party websites within the platform for navigation or promotional purposes. This Privacy Policy applies exclusively to personal data processed by af99 in connection with the af99 platform. It does not apply to data collected by your mobile financial service provider (e.g., bKash, Nagad) when you use their services to deposit or withdraw funds — for those interactions, please refer to the relevant provider's own privacy policy.

13 Updates to This Privacy Policy

af99 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. When material changes are made, af99 will publish the revised policy on this page with an updated effective date and, where reasonably practicable, will notify registered players via the email address associated with their account.

We encourage you to review this Privacy Policy periodically so that you remain informed about how af99 handles your personal data. Your continued use of the af99 platform following the posting of a revised Privacy Policy constitutes your acceptance of those changes. If you do not agree with an updated policy, you should contact af99 to request voluntary account closure.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way af99 processes your personal data, please get in touch using the contact details below:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available inside your af99 account dashboard after login, available 24 hours a day, 7 days a week
• Response Time: All privacy-related email enquiries will receive an acknowledgement within 48 hours and a substantive response within 30 calendar days

af99 support is available in English to players located throughout Bangladesh, including Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, and Cox's Bazar, as well as international players.