we99 Privacy Policy

1. Introduction

We99 ("we", "us", "our") is committed to protecting the privacy of all individuals who access or use the we99 online betting platform at https://we99.im (the "Platform"). This Privacy Policy explains how we collect, use, store, share, and protect your personal data, and describes the rights you hold in relation to that data.

This Policy applies to all users of the Platform, including registered account holders, visitors who browse without registering, and individuals who contact our support team. By accessing the Platform or creating an account, you acknowledge that you have read and understood this Privacy Policy and agree to the processing of your personal data as described herein.

This Privacy Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated by reference and form part of the overall agreement between you and we99.

2. Data Controller

We99 operates as an internationally incorporated offshore entity and acts as the data controller for all personal data collected through the Platform. As data controller, we99 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable international data protection standards.

For all privacy-related enquiries, data subject access requests, or complaints, please contact our Data Protection team at: [email protected]

3. Data We Collect

We99 collects personal data across several categories depending on how you interact with the Platform. The table below summarises the main data types collected:

Data Category	Examples	When Collected
Identity Data	Full name, date of birth, nationality, gender	At registration and KYC verification
Contact Data	Email address, mobile number, residential address	At registration and account updates
Financial Data	bKash number, Nagad number, Rocket number, bank account details, transaction history	At deposit, withdrawal, and KYC
KYC Documents	National ID, passport, driving licence, utility bill, selfie with ID	At identity verification stage
Technical Data	IP address, device type, browser, operating system, session timestamps	Automatically on each platform visit
Behavioural Data	Betting history, game preferences, login frequency, deposit patterns	During active platform use
Communications Data	Live chat transcripts, email correspondence, support ticket content	When you contact support

We99 does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required by law or responsible gaming obligations (for example, where a player voluntarily discloses a gambling problem to our support team).

4. How We Collect Data

We99 collects personal data through the following channels:

• Direct interactions: Data you provide when you create an account, complete KYC, make a deposit or withdrawal, place a wager, or contact support.
• Automated technologies: When you visit the Platform, we automatically collect technical and behavioural data via server logs, session tracking, and first-party cookies (see Section 10).
• Third-party payment processors: When you use bKash, Nagad, Rocket, Upay, or linked bank channels to transact, those providers share transaction confirmation data with we99 to enable us to credit or debit your account accurately.
• Identity verification partners: In processing KYC checks, we may use third-party verification services that cross-reference the documents you submit against official databases to confirm authenticity.
• Fraud prevention systems: We receive risk signals and device fingerprint data from third-party anti-fraud tools to help us detect and prevent fraudulent account activity.

5. How We Use Your Data

We99 uses personal data collected from players for the following specific purposes:

• Account management: Creating, maintaining, and securing your we99 account; authenticating your identity at login; communicating account-related updates.
• Transaction processing: Processing deposits via bKash, Nagad, Rocket, and bank channels; processing withdrawal requests; reconciling balances; investigating payment disputes.
• Identity verification (KYC): Verifying that you meet the minimum age requirement of 21 years; confirming your identity to comply with anti-money-laundering obligations; validating your payment method ownership.
• Fraud prevention and security: Detecting unusual account activity, flagging suspicious betting patterns, investigating potential terms violations, and preventing unauthorised access to accounts.
• Responsible gaming: Monitoring betting behaviour to identify potential problem gambling indicators; applying deposit limits, cooling-off periods, or self-exclusions as requested or as required by platform policy.
• Platform improvement: Analysing aggregated and anonymised usage data to improve game offerings, fix technical issues, and enhance the overall player experience.
• Customer support: Responding to support requests, resolving disputes, and maintaining records of communications for quality assurance.
• Legal compliance: Retaining records as required by anti-money-laundering law; responding to lawful requests from regulatory or law enforcement authorities.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have not opted out of such communications. You may opt out at any time by contacting support.

6. Legal Basis for Processing

We99 processes your personal data under the following legal bases:

• Contractual necessity: Processing required to fulfil the agreement between you and we99, including account creation, transaction processing, and KYC verification.
• Legal obligation: Processing required to comply with applicable anti-money-laundering, counter-terrorist-financing, and data retention laws.
• Legitimate interests: Processing carried out for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests do not override your fundamental rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing

We99 does not sell, rent, or trade your personal data to any third party for commercial purposes. We share data only in the following limited circumstances:

• Payment service providers: bKash, Nagad, Rocket, Upay, Visa, Mastercard, and linked Bangladeshi banking partners receive the minimum data necessary to process your financial transactions.
• Identity and KYC verification partners: Third-party providers that assist in verifying the authenticity of identity documents submitted during account verification. These partners are bound by strict confidentiality agreements.
• Anti-fraud and security providers: Specialist fraud detection services receive technical data (IP address, device fingerprint, session data) to assess account risk. No unnecessary personal data is shared with these providers.
• Game content providers: Studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive a pseudonymous player identifier (not your full name or contact details) to enable game session management and resolve any in-game disputes.
• Legal and regulatory authorities: Where we99 is required by law, court order, or competent regulatory authority to disclose personal data, we will comply with that obligation and, where legally permissible, notify you of the disclosure.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets of we99, player data may be transferred to the successor entity, subject to equivalent privacy protections.

8. International Data Transfers

We99 operates as an offshore platform, and some of the third-party service providers described above are located outside Bangladesh. When personal data is transferred internationally, we99 takes reasonable steps to ensure that appropriate safeguards are in place, including contractual data protection clauses with service providers, to maintain a standard of protection equivalent to that applied to data processed within we99's primary operating jurisdiction.

By using the Platform, you acknowledge that your personal data may be processed outside Bangladesh and consent to such transfers as described in this Policy.

9. Data Retention

We99 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following minimum retention periods apply:

• Account data and KYC documents: Retained for a minimum of five years following the date of account closure, in line with international anti-money-laundering record-keeping standards.
• Transaction records: Retained for a minimum of five years from the date of each transaction.
• Customer support communications: Retained for a minimum of two years from the date of the interaction, or longer if the communication relates to an unresolved dispute.
• Marketing consent records: Retained for as long as you remain on our marketing list, plus one year following opt-out, to evidence that communications were lawfully sent.
• Technical and session logs: Retained for up to twelve months from the date of collection for security and fraud detection purposes, then deleted or anonymised.

Upon expiry of the applicable retention period, data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an identifiable individual.

10. Cookies & Tracking Technologies

We99 uses first-party cookies and similar technologies to operate the Platform effectively. Cookies are small data files stored on your device that allow the Platform to recognise you between sessions, maintain login state, remember preferences, and collect aggregated usage statistics.

10.1 Types of Cookies Used

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your language preferences, display settings, and last-visited sections of the Platform to improve your browsing experience.
• Analytics cookies: Collect anonymised and aggregated data about how players navigate the Platform (pages visited, time spent, click patterns) to help we99 improve the service. Individual users are not identifiable from analytics data.
• Fraud detection cookies: Help identify suspicious patterns and protect player accounts from unauthorised access. These operate silently in the background and do not affect your experience.

We99 does not use third-party advertising or retargeting cookies. We do not serve behavioural advertising based on your Platform activity to external ad networks.

11. Security Measures

We99 employs a layered security architecture to protect the personal data of all players. Key measures include:

• 256-bit SSL/TLS encryption on all pages and API endpoints to protect data in transit between your device and our servers.
• One-way cryptographic password hashing using industry-standard algorithms. Passwords are never stored in recoverable plain-text form.
• Role-based access controls that restrict internal access to player data to authorised personnel with a demonstrated need. Access logs are maintained and audited.
• Intrusion detection and anomaly monitoring systems that operate continuously to identify and respond to unusual network activity or attempted breaches.
• Regular security assessments of platform infrastructure and third-party integrations to identify and remediate vulnerabilities proactively.
• Secure data centre environments with physical access controls, redundant infrastructure, and geographic data backup.

While we99 applies robust technical and organisational measures, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords, keep their device software up to date, and report any suspected account compromise to support immediately.

12. Your Rights

As a user of the we99 Platform, you have the following rights in relation to your personal data:

• Right of access: You may request a copy of the personal data we99 holds about you. We will respond to verified access requests within 30 days.
• Right to rectification: You may request correction of inaccurate or incomplete personal data. For basic profile details, you may also update information directly within your account settings.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (for consent-based processing), or where processing is unlawful. This right is subject to override by legal retention obligations, such as the five-year AML record-keeping requirement.
• Right to restrict processing: You may request that we99 pause the processing of your personal data in certain circumstances, for example while a rectification request is being assessed.
• Right to data portability: For data processed on the basis of your consent or contractual necessity, you may request that we99 provide your data in a structured, commonly used, machine-readable format.
• Right to object: You may object to the processing of your data for marketing purposes at any time. You may also object to processing based on legitimate interests, and we99 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• 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 processing carried out prior to withdrawal.

To exercise any of the above rights, please contact we99 support via in-platform live chat or by email at [email protected]. We may need to verify your identity before processing your request. We will respond within 30 days; complex requests may be extended by a further 30 days with notification.

13. Minors

The we99 Platform is strictly intended for adults. We99 enforces a minimum age of 21 years for all Bangladeshi players, and a minimum age of 18 years in all other markets. We99 does not knowingly collect personal data from individuals below the applicable minimum age.

If we99 discovers that an account has been created by a person below the minimum age, the account will be closed immediately, all wagers placed will be voided, and any deposited funds will be returned to the payment method used, subject to identity verification. If you believe a minor has created an account on the Platform, please notify us immediately at [email protected].

14. Changes to This Policy

We99 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, platform functionality, or applicable law. Material changes will be communicated to registered players via a notice posted on the Platform or by email to the registered account address, at least 7 days before the updated Policy takes effect.

The effective date at the top of this Policy will be updated each time a new version is published. Continued use of the Platform after the effective date of any revision constitutes acceptance of the updated Privacy Policy. If you do not accept the revised Policy, you must close your account before the effective date.

15. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by we99, please reach out to us through any of the following channels:

• In-Platform Live Chat: Available 24/7. Our support team can handle most data queries in real time during Bangladesh Standard Time (BST, UTC+6) business hours.
• Email: [email protected] — responses within 2 hours during BST operating hours (06:00–24:00 BST).

For formal data subject access requests or complaints that cannot be resolved through standard support, please mark your email with the subject line "Data Privacy Request" to ensure it is directed to the appropriate team.